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Spin-off ruling on subsidiary with no independent current revenue

Spin-off ruling on subsidiary with no independent current revenue

Active trade or business present in subsidiary without independent current revenue but with a plan to make future product sales.

  • Nick Gruidl, Stefan Gottschalk
  • |
  • June 25, 2019
Senate passes Taxpayer First Act

Senate passes Taxpayer First Act

The Senate recently passed the Taxpayer First Act after eliminating the controversial Free File Program from the bill.

  • Patti Burquest, Alina Solodchikova, Whitney Brady
  • |
  • June 24, 2019
U.S. Supreme Court finds in-state beneficiary inadequate for trust tax

U.S. Supreme Court finds in-state beneficiary inadequate for trust tax

Highly-anticipated trust taxation case considers whether a state can tax a trust based on the residency of a beneficiary.

  • Alan Spiegelman, Brian Kirkell, Mo Bell-Jacobs
  • |
  • June 21, 2019
Taxpayers prove participation based on facts and circumstances

Taxpayers prove participation based on facts and circumstances

Tax Court found that the taxpayers established material participation despite failing other quantitative material participation tests.

  • Ed Decker, Kyle Brown, Lauren Van Crey
  • |
  • June 21, 2019
Eleventh Circuit reinforces the restorative purpose of section 1341

Eleventh Circuit reinforces the restorative purpose of section 1341

In Mihelick v. United States, the Court of Appeals for the 11th Circuit reversed the lower court ruling on substance over form.

  • Christian Wood, John Charin
  • |
  • June 20, 2019
Final regulations address taxation of ESBTs with nonresident aliens

Final regulations address taxation of ESBTs with nonresident aliens

Rules clarify how S corporation income allocated to an ESBT will be taxed when a trust beneficiary is a nonresident alien.

  • Ed Decker, T. Christopher D’Avico
  • |
  • June 17, 2019
Federal agencies finalize rules on health reimbursement arrangements

Federal agencies finalize rules on health reimbursement arrangements

The federal government adds two new health reimbursement arrangement (HRA) options for employers starting in 2020.

  • Jill Harris, Bill O’Malley
  • |
  • June 17, 2019
Hawaii enacts market-based sourcing

Hawaii enacts market-based sourcing

Effective for tax years beginning after Dec. 31, 2019, market-based sourcing adopted for services and intangibles.

  • James Barash, Brian Kirkell, Mo Bell-Jacobs
  • |
  • June 14, 2019

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