CNN Money: How to survive a tax audit
By Blake Ellis April 24, 2013 Published in CNN Money >>Download the PDF
Forbes: The Medical Device Tax: Stop Dreaming and Start Planning
By Dean Zerbe April 09, 2013 Published in Forbes >>Download the PDF
Government filed a motion to expedite the appeal of the Loving Decision
On April 1, 2013, the Government, on behalf of the Internal Revenue Service and the Commissioner, filed a motion in the US Court of Appeals, District Court of Columbia Circuit, to expedite the Government’s appeal of the Loving decision. The counsel for the Government argued that the appellee’s answering brief be due by May 17,…
Supreme Court Takes Case on §6662 Penalty for Overstatement of Basis
On March 25th, the Supreme Court granted the government’s petition for certiorari in United States v. Woods, No. 12-562. The issue raised in the petition concerns the applicability of the valuation overstatement penalty to an overstatement of basis. The case involves overstatement of basis attributable to a transaction lacking “economic substance” and thus disregarded for…
Governor Hassan doubles and permanently extends R&D tax credit
On March 21, 2013, Governor Maggie Hassan (NH D) signed bipartisan legislation to increase the research and development (R&D) tax credit fund to $2 million and extend it permanently. The expansion of the R&D credit is a key provision of the Governor’s innovation plan to help businesses grow and create jobs in the state of…
Proposed Startup Innovation Credit Act Would Allow R&D Credit to Offset Payroll Tax Liability
On January 31, 2013, United States Senator Christopher Coons (D) introduced bill S. 193, which would amend Sections 41 and 3111 of the Internal Revenue Code of 1986 to allow startup businesses to use a portion of the credit for increasing research activities to offset payroll taxes. Under the proposed bill, a startup business is…
House Subcommittee Weighs Effects of Medical Device Excise Tax
The House Ways and Means Subcommittee on Oversight held hearings on the impact of the I.R.C. § 4191 Medical Device Excise Tax on medical device manufacturers. The excise is 2.3% of the sales price of certain medical devices listed with the F.D
Much Ado About UCC II: Analyzing the Recent Dow Case
John Dies is a director, Jeremy Fingeret is a senior managing director, and Scott Weese is an associate in the Tax Controversy Services Department of alliantgroup LLP. Contrary to early concerns, the recent Second Circuit opinion in Union Carbide Corp. (UCC II) merely reinforces the status quo allowing taxpayers to claim any supply cost for…
