“Application of Medicare Contribution Tax of 3.8% to Certain U.S. Persons Owning Stock in A Controlled Foreign Corporation or Passive Foreign Investment Company.” Federal Taxation Developments Blog, January 13, 2013, foxrothschild.com. [Link]
“Tax Court Finds Shareholder’s Leasing of Cell Towers to S Corporation Was a Passive Activity Despite Corporation’s Grouping Such Leasing Activities as Part of the Conduct of a Trade or Business: Francis J. Dirico, et ux. v. Commissioner, 139 T.C. No. 16”. Federal Taxation Developments Blog, January 13, 2013, foxrothschild.com. [Link]
“Service Prevails before Tax Court in Self-Employment Tax Case.” Federal Taxation Developments Blog, January 13, 2013, foxrothschild.com. [Link]
“Treasury and Service Issue Final Regulations Under the Foreign Account Tax Compliance Act.” Federal Taxation Developments Blog, January 28, 2013, foxrothschild.com. [Link]
“IRS Deputy Commissioner (International), Large Business and International Division Criticizes India’s Competent Authority and Tax Administration Features.” Federal Taxation Developments Blog, February 2, 2013, foxrothschild.com. [Link]
“Treasury and Internal Revenue Service Issues Final and Proposed Regulations on the Treatment of Noncompensatory Partnership Options and Convertible Securities.” Federal Taxation Developments Blog, February 5, 2013, foxrothschild.com. [Link]
“United States and Japan Sign New Protocol to Amend the Japan-U.S. Income Tax Treaty.” Federal Taxation Developments Blog, February 12, 2013, foxrothschild.com. [Link]
“Service and Treasury Issue Final Regulations Modifying the New Markets Tax Credit Program to Promote Further Investment in Non-real-estate Businesses in Low-income Communities.” Federal Taxation Developments Blog, February 19, 2013, foxrothschild.com. [Link]
“Tax Court Sides With Service In Holding That a STARS Transaction Entered into by Bank of New York Lacked Economic Substance Despite Transactions Literal Compliance with Code.” Federal Taxation Developments Blog, February 19, 2013, foxrothschild.com. [Link]
“Third Circuit Court of Appeals Affirm’s Tax Court’s Decision in Crispin v. Commissioner in Disallowing Losses from CARDS Transaction.” Federal Taxation Developments Blog, February 19, 2013, foxrothschild.com. [Link]
“President Obama’s State of the Union Address Continues His Efforts to Obtain Corporate Tax Reforms.” Federal Taxation Developments Blog, February 19, 2013, foxrothschild.com. [Link]
“Criminal Investigation Division of the Internal Revenue Service Issues Disqualification Notices under the Offshore Voluntary Disclosure Program.” Federal Taxation Developments Blog, March 9, 2013, foxrothschild.com. [Link]
“New York Court of Appeals Rejects Amazon.Com.’s and Overstock.com’s Constitutional Challenge to the New York Internet Tax.” Federal Taxation Developments Blog, March 31, 2013, foxrothschild.com. [Link]
“Outbound Asset Transfer Guidance Under Section 367 Issued by the Treasury and Internal Revenue Service 4-10.” Federal Taxation Developments Blog, April 10, 2013, foxrothschild.com. [Link]
“Tax Court Rules In Favor of Service In TEFRA Entity Level Audit Case in Kearney Partners Fund, LLC, by and through Lincoln Partners Fund, LLC, TMP v. United States.” Federal Taxation Developments Blog, April 11, 2013, foxrothschild.com. [Link]