The district court has made several rulings regarding Code Sec. 280E, the Code section that disallows deductions in carrying on a trade or business that consists of trafficking in controlled substances. One such ruling was that Code Sec. 7609(c)(2)(E)(i), which provides an exception to the Code's third-party summons rules where the summons is issued by…
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New Limits on Regs Trump New 385 Regs!
On November 16, 2016 we posted Treasury Issues Final & Temporary Section 385 Regs - But May Not Last Under President Trump? where we discussed that the Obama administration’s announcement of a crackdown on inversions the U.S. Treasury issued final & temporary proposed regulations that would dramatically change the taxation of corporate debt issued to related corporations…
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IRS Rescinds Termination of Foreign Certified Acceptance Agents
IRS has recently notified foreign CAAs by email that, effective Apr. 17, 2017, IRS has rescinded the termination letter that they had previously been sent. In the email, IRS stated that if a CAA's Certified Acceptance Agent Agreement was not set to expire on Dec. 31, 2016, then no further action was required on their…
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Trump Also Proposes 15% Tax Rate For Pass-Through Entities, One Time Repatriation Tax & Switch To a Territorial Tax System
On April 26, 2017 we posted Trump Proposes 15% Corp. Tax Rate & Repeal of 3.8% Obama Tax where we discussed that 15 percent tax rate for corporations, cutting the top individual tax rate from 39.6% to 35%, reducing the number of rates from seven to three and the repeal of a 3.8 percent tax on net…
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