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    Navigating the IDR Process for U.S. - Based Multinational Enterprises

    By Paul DeNard, Anthony Russo, Tien Do and Elizabeth Sweigart The new information document request (IDR) process is aimed at supporting a systematic, issue-focused approach to examinations. A year into the new IDR creation approach -- and six months...

    Voluntary Tax Return Preparer Certification in Wake of Loving v. IRS

    Loving v. IRS In February 2014, the D.C. Circuit of the U.S. Court of Appeals issued its decision in Loving v. IRS , 742 F.3d 1013 (D.C. Cir. 2014) , regarding the IRS’ authority to license tax return preparers. The D.C. Circuit upheld the decision...

    Medical Marijuana Business Expenses

    by Joel S. Newman * ... Legal and Illegal [business enterprises] are treated the same way [for tax purposes] because of Comm'r v. Sullivan, 356 U.S. 27 (U.S. 1958) . In Sullivan , the Commissioner denied salary and rent deductions to an illegal...

    I Am Not Ayn Rand, But What About Me?

    My friends at the Center on Budget and Policy Priorities recently took issue with my friends at the Tax Foundation. The subject was whether tax increases harm economic growth. The Foundation published a piece written by Will McBride in December 2012 which...

    DOMA Doomed by Estate Tax Refund Claim

    The United States Supreme Court has struck down the Defense of Marriage Act (DOMA) as an unconstitutional violation of the "equal liberty" protections of the 5th Amendment. The dispute in U.S. v. Windsor * began when Edie Windsor filed a...

    Questions About Pfizer's Taxes

    Over the last five years American pharmaceutical giant Pfizer earned on average over $10 billion of annual worldwide pre-tax profits. How much of this profit was attributable to its U.S. operations? Answer: none. In fact, according to annual reports filed...

    Are Republicans Throwing in the Towel on Tax Reform?

    ... [I]n the modern era of divided government, tax reform is almost certainly going to be a bipartisan enterprise - or no enterprise at all. Which makes it all the more illuminating that House Republicans have floated the idea of passing a tax reform...

    Want New Ideas? Look Outside Washington

    by Clint Stretch Except for the fact that I headed into the Deep South in June, I was lucky to get out of Washington last week. Few in Washington would dare express the views I heard from a good-sized group of young tax professionals. They were unencumbered...

    Paz's Admissions Fuel GOP Ire, But Don't Implicate Administration

    by Jeremy Scott ... Holly Paz, the former director of rulings and agreements for the IRS Tax-Exempt and Government Entities Division, contradicts the notion that everything was confined to Cincinnati... ... Paz's assertion that there was no...

    The IRS: It's Bad Enough

    ... Over the years there have been high-ranking IRS officials who conveniently forgot that they were public servants who were supposed to serve, you know, the public. And there have been high-ranking tax administrators who have had trouble with the balance...

    It's Time to Stop Talking About Tax Reform

    Enough already: it's time to stop talking about tax reform. Not about necessary and useful changes to the tax code - by all means, let's talk about them. But let's do away with anodyne invocations of "tax reform" as a useful shorthand...

    TIGTA Report Implies A Lot, Proves Little, About Bias at the IRS

    The Treasury Inspector General for Tax Administration's report that is at the center of the current firestorm over potential political bias at the IRS... examined the names of... 296 [501(c)(3) and 501(c)(4)] organizations] and found that 98 of them...

    A World Without 501(c)(4)s

    Should we get rid of 501(c)(4)s? Last week, the New York Times put that question to a range of tax experts and got back (predictably) a range of reasonable answers. Most involved some sort of intermediate reform involving the political activities of "social...

    Targeting Tax-Exempts and Tax Reform

    by Clint Stretch Many on Capitol Hill are currently focused on the IRS's targeting of conservative groups applying for tax-exempt status as evidence of the need for tax reform. I agree we need tax reform. I doubt how dramatic it can be, whether...

    Will DOMA Issues Doom Tax Reform?

    by Clint Stretch The already grinding gears of immigration reform slowed again last week when Senator Patrick Leahy (D-VT) angered conservatives by suggesting that his committee extend to roughly 40,000 binational same-sex couples the same rights enjoyed...

    Fast Track to Nowhere

    Although the formal expiration of the debt limit is May 19, the ability of the Treasury Department to juggle some internal accounts is likely to extend the effective deadline until late summer . Nothing is certain, but the real deadline is likely to crop...

    When Tax Reform Means Soaking the Rich

    Tax reform has evolved into one of the emptier platitudes of U.S. politics. Politicians support "tax reform" in the same way that they support "a strong national defense," "fiscal responsibility," and "pro-growth economic...

    Baucus, the Marketplace Fairness Act, and Tax Reform

    by jeremy Scott ... [T]he tax community is... concerned with whether Baucus's retirement will hinder or help the chances of tax reform. The answer might lie in how Democrats handled the Marketplace Fairness Act. ... It appears that Baucus, the...

    Let's Stop With the Revenue Neutrality

    For decades, most people have believed that the success of tax reform is dependent on the reform being revenue neutral. That is, whatever happens, the tax system has to raise approximately as much revenue after as it did before. Proponents of reform want...

    Getting It Wrong: Energy Tax Policy

    by Clint Stretch Winston Churchill said that Americans can be counted on to do the right thing, after we have exhausted all other possibilities. He might have added that we usually start with the least direct and most complex approach. So it is with...

    How Important Is Deferral to Multinationals?

    by Jeremy Scott The U.S. tax system allows multinationals to effectively indefinitely defer taxes on profits earned by active foreign affiliates until that money is repatriated to the United States. Deferral as a cornerstone of tax policy dates from...

    Unkind to Charity

    There's a new whipping boy on Capitol Hill and it's not the bankers who brought down the economy, the fossil fuel companies that are heating up the planet, or the gun lobby that has figured out how to increase sales every time there's a mass...

    'Commissioner-Less'

    The Internal Revenue Service is currently without a Commissioner. Douglas Shulman, the 47 th IRS Commissioner stepped down last November . And from what I'm starting to hear, the IRS may not have a new Commissioner for as long as close to two years...

    Spam and Taxes

    ... On the surface, taxing [Internet] spam is a wonderful idea. Spam clogs the Internet, wastes our time just deleting it and continues because it makes money since you only need a few people so gullible or addled that they believe some Nigerian wants...

    Tim Johnson, Kristi Noem, and the Importance of Moderates to Tax Reform

    by Jeremy Scott Another Senate Democrat is retiring. South Dakota Sen. Tim Johnson will not seek a fourth term in 2014, leaving an open seat that Republicans will be heavily favored to pick up. Johnson's retirement brings the total number of Democrats...