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    International Tax Reform and the Patent Box

    Patent or innovation boxes have been a part of the United Kingdom’s tax system since 2013. [1] With Congress focused on international and business tax reform, the concept of a patent or innovation box has emerged as a possible addition to the United...

    Alcohol Taxes and Incentives - The Spirit of the Law and What's Hoppin'

    by Daniel G. Mudd * Basics of Federal Excise Tax on Alcohol Federal taxation of alcohol generally follows the same tax structure and controls as is used with other commodities and products sold in the United States which are subject to excise tax...

    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...

    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...

    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...

    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...

    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...

    'Legal Enemies of the State'!

    How does that old Wall Street saying go? Bulls make money; Bears make money; Pigs get slaughtered. Bulls in this context are easily defined, and so are Bears. Money can be measured. But it seems to me that piggy behavior is in the eyes of the beholder...

    It's Not Too Late for a War Tax

    In case you needed another reason to support a special war tax, try this on for size: The United States is still paying veterans' benefits to the children of Civil War soldiers. According to the Associated Press , two survivors are each receiving...

    America May Be on the Wrong Track, But Is Paul Ryan's the Right One?

    ... [S]adly for today's GOP, they have more than a few [bad ideas]. Take Paul Ryan's budget plan , for instance. ... Ryan runs into serious problems when he starts suggesting ways to make the tax code simpler. In particular, his emphasis...

    Things to Read, Sites to Visit

    I decided to share some of my favorite tax resources on the web. The Minnesota Taxpayer's Association has changed its name (after 87 years!) to the Minnesota Center for Fiscal Excellence . The MTA under the direction of Mark Haveman has been one of...

    A Moral Obligation to Aggressively Lobby

    In the United Kingdom a great debate is taking place about aggressive tax avoidance. On one side, David Cameron, the Conservative prime minister, says it is immoral . On the other side, most executives say they have a duty to their shareholders, and most...

    The True Meaning of Sequestration

    [Sequestration] is not about spending cuts; the White House doesn't want spending cuts. Sequester is about taxes, and, specifically, tax increases. President Obama wants rich people to pay more because they don't pay their fair share - whatever...