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Any Hope for Tax Reform?
Dave Camp, Republican from Michigan and House Ways and Means Committee Chair, confirmed media reports February 26 that House Speaker John A. Boehner has set aside the number one bill for use as a...
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ECJ Throws Out Holland Exit Tax
The European Commission filed an infringement procedure against the Netherlands in August 2011. On January 31, the European Court of Justice (ECJ) held that the Netherlands’ rules on exit taxation...
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IRS Makes Clear The Substance-Over-Form Doctrine Is A Tool Available Only To...
In response to a September 16, 2012 letter by a taxpayer to the IRS requesting advice regarding whether a taxpayer can exploit the substance-over-form doctrine to recast a transaction, the IRS stated...
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Deferred Tax Treatment in Holland for Reinvestment of Real Estate Profits
Earlier this month the Dutch High Court ruled that a nonresident owner of real property in The Netherlands is able to place capital gains in a reinvestment reserve, permitting rollover or tax-deferral...
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Section 1202 + 83(b) Elections Qualified Small Business Stock
Section 1202 of the Code provides that, “[i]n the case of a taxpayer other than a corporation, gross income shall not include 50 percent of any gain from the sale or exchange of qualified small...
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DOJ TRIES TO CLOSE DOWN MIAMI BASED TAX-PREPARATION OFFICE BECAUSE THE...
The DOJ asked a Miami district court to shut down a Miami tax-preparation office. The suit asserts that Olivia Greene and Walter Jefferson prepared returns with falsely-claimed credits, including fuel...
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Conservation Watch – Tax Court Denies Deduction for Charitable Contribution
In B.V. Belk Jr. et ux. v. Commissioner, 140 T.C. No. 1, the Tax Court, in an opinion by Judge Juan F. Vasquez, held that a couple was not entitled to a charitable deduction under § 170(h)(2)(C) of the...
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Whistleblower Basics
The Secretary of the IRS is permitted to pay such sums as he deems necessary to detect tax underpayment or to detect and bring to punishment persons who are guilty of violating the tax laws.[1] Any...
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Irish Apples: The Common Sense Definition of a Tax Haven?
Many people have been following the Senate Permanent Subcomittee on Investigations’ inquiries into Apple’s international tax structure over the past few weeks, especially after the Senators focused...
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Reed-Schumer Amendment to Prevent Expatriates From Re-Entering U.S.
Senators Jack Reed from Rhode Island and Chuck Schumer from New York filed an amendment to the immigration reform bill to ensure that the U.S. Department of Homeland Security may exclude from reentry...
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