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TaxAnalysts®
Texas's Franchise Tax Not Subject to Compact Apportionment Formula, State AG Argues

The Texas franchise tax is not an income tax, and thus the taxpayer in Graphic Packaging Corp v. Hegar can't apportion its margin using the Multistate Tax Compact’s three-factor method, the Texas attorney general argued to the state supreme...

TaxAnalysts®
Remand of South Dakota Remote Sales Tax Case Could Expedite Path to U.S. Supreme Court

South Dakota's motion to remand a remote sales tax law challenge to state court was granted by a federal court January 17, giving the state a victory in its quest to overturn Quill . The U.S. District Court for the District of South Dakota's ruling...

Neil Aragones
Covered Asset Acquisitions Regulations Examined

Proposed and temporary regulations under IRC Section 901(m) affect covered asset acquisitions, which are transactions that are generally treated as asset acquisitions for U.S. income tax purposes and that either are treated as stock acquisitions or are...

Susan Calistri Boesger
Qualified Terminable Interest Property Trust Basics

The Qualified Terminable Interest Property (QTIP) Trust was a creation of ERTA-1981 pursuant to IRC § 2056(b)(7) which qualifies for the marital deduction, even if the surviving spouse is not given a general power of appointment during life or at...

LexisNexis Tax Law Community Staff
Classifying Debt and Equity

by Shahzad A. Malik J.D. LL.M and Ryan C. Gaglio J.D. * In General "There is no dearth of cases in this province of tax law. So large is their number and disparate their facts, that for every parallel found, a qualification hides in the thicket...

Neil Aragones
New Regs on Earnings Strippings Transactions

On October 13, 2016, the Treasury and IRS issued regulations [T.D. 9790 (Oct. 13, 2016)] finalizing and revising proposed regulations issued earlier in the year that targeted post-inversion earnings strippings transactions, which are certain related-party...