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Being an "influencer" is big business. Influencer marketing has more than tripled since 2019, with an estimated worldwide market size of $24 billion ("Global Influencer Marketing Value 2016-2024," Statista (Feb. [...]

Introduction I. The Current Rules Are Incapable of Taxing Information A. Fundamental Challenges 1. The Subject of Taxation i. What Exactly Do We Want to Tax? ii. Semantics iii. Has [...], Existing and universal income tax rules are inherently incompatible with an economy in which information-based transactions play a significant role. This Article contends that income taxation is incapable of taxing information effectively. It goes on to argue that this incapability currently necessitates reform, and it offers three viable paths to such reform: consumption taxation, data taxes, and formulary taxation. The Article concludes that formulary taxation is currently the most desirable and plausible path to effective reform, owing to its promise to best stabilize and maintain the legitimacy of the international tax regime.

A wait-and-see attitude characterizes this year's global tax landscape, with the emergence of regulations like BEPS Pillar Two marking a pivotal moment. Designed to address base erosion and profit shifting, [...]

I. INTRODUCTION 1115 II. CRIMINAL INVESTIGATIONS UNDER I.R.C. 1115 [section][section] 7201, 7202, 7203, 7206, AND 7212(A) A. Legal Landscape of IRS Investigations 1115 1. Responsibility for Investigation and Prosecution 1115 [...]

As discussed by Mike Schadewald in his article in this issue, "States that Permit Combined Reporting on a Worldwide Basis," when a unitary group is required to compute its tax [...]

The states that impose corporate income taxes employ a variety of tax reporting options for groups of commonly controlled corporations, including the filing of separate company tax returns, consolidated tax [...]

I. Introduction International tax disputes often create important guidance, some obvious, some not. Aroeste is a great example. (1) Those looking no further than the surface likely consider this case [...]

In an engaging and educational Annual Conference session moderated by Cliff Mangano, chair of TEI's IRS Administrative Affairs Committee, a panel of experts discussed recent developments and trends in global [...]

In a particularly engaging session at TEI's Annual Conference and 75th Anniversary Celebration, panelists discussed the dynamic developments that have resulted in what corporate tax professionals are calling "a new [...]

Registering for sales taxes is the first step a company takes to inform a state that it operates within the state's jurisdiction and is accountable for collecting and remitting sales [...]

U.S. and foreign taxpayers alike can choose to conduct cross-border business through a variety of business entities. A business entity may be organized either in the United States or in [...]

The Bipartisan Budget Act of 2015 (BBA), P.L. 114-74, significantly changed the partnership audit and adjustment processes with the goal of making partnership adjustments less administratively burdensome. The application of [...]

The U.S. tax system is based on "voluntary compliance," meaning that taxpayers assess their tax liabilities against themselves and pay voluntarily. However, the IRS has several methods to encourage taxpayer [...]

Reversing the Tax Court, the D.C. Circuit held that the IRS has the statutory authority to assess penalties under Sees. 6038(b)(1) and (2). Background In 2004, Alon Farhy, a U.S. [...]

Federal tax collection is based on a "system of self-reporting." (1) There is a legal compulsion to be sure, but the government largely "depends upon the good faith and integrity [...]

In a recent audit report, the Treasury Inspector General for Tax Administration (TIGTA) identified opportunities for the IRS to improve the accuracy and reliability of its Centralized Authorization File (CAF) [...]

On September 5, 2023, the New Jersey Division of Taxation issued Technical Bulletin TB-109, Combined Group Filing Methods for Privilege Periods Ending on and After July 31, 2023, which describes [...]

A fact, well known in the tax community: every tax return contains at least one error. Except for the simplest Form 1040, this statement is invariably true, especially considering the [...]

I. INTRODUCTION The popularity of virtual currency and crypto assets has increased tremendously in the recent years. In fact, "[t]he U.S. is among the countries that host the highest concentration [...]

Recently, a Magistrate Judge, in an evidentiary dispute in a federal district court (1) involving the imposition of penalties arising from the non-filing by the individual of FinCEN Forms 114, [...]

The base-erosion and anti-abuse tax (BEAT) was introduced as part of the law known as the Tax Cuts and Jobs Act, P.L. 115-97, in an effort to transition the U.S. [...]

This article provides an overview of the federal tax reporting requirements by U.S. persons for foreign assets and gifts, including addressing prior noncompliance. In our globalized economy, it is increasingly [...]

Accounting for income taxes in accordance with FASB Accounting Standards Codification (ASC) Topic 740, Income Taxes, is a time-consuming and complex process. Federal and state tax laws are constantly changing [...]

March 1, 2024 RELATED March 27, 2024 Latest federal budget includes $20 billion rescission for IRS March 23, 2024 Enforcement, voluntary programs yield over $1 billion from ERC claims March [...]

I. Introduction The Internal Revenue Service ("IRS") has recently suffered several attentiongrabbing court defeats, primarily for exceeding its authority, ignoring procedures mandated by Congress, and excluding the public from the [...]

Editor's note: Given the complexity of this topic, this will be a two-part article. This first part addresses fringe benefits, federal and state tax withholding, and information reporting. The second [...]

The United States' rules for the taxation of transnational income have morphed over the years in response to changes in economic and political conditions, not to mention developments in economic [...]

February 1, 2024 Over the last four years, the IRS has reversed its performance in transfer-pricing litigation during the previous four decades and achieved unprecedented success in transfer-pricing cases dealing [...]

February 1, 2024 In October 2023, the IRS released a revised Form 8308, Report of a Sale or Exchange of Certain Partnership Interests, which is to be used for reporting [...]

January 1, 2024 In recent years, much of the discussion related to Sec. 7216 has centered around the use of foreign tax preparation centers; however, the provision has much wider-ranging [...]

Practice & Procedures 90-day deadline for filing Tax Court petition in deficiency case is jurisdictional Despite the Supreme Court's decision in Boechler, 142 S. Ct. 1493 (2022), holding that the [...]

During the course of their work, tax practitioners accumulate volumes of paper documents and electronic files (hereinafter collectively referred to as records). This often leads to questions such as: * [...]

Environmental, social, and governance (ESG) initiatives by businesses provide investors, customers, employees, and other stakeholders with insight into a company's position, strategy, and performance on sustainability-related topics. ESG focuses on [...]

Gross Income Taxpayer's argument for $1.5 million refund fails on several grounds A taxpayer was not entitled to a $1.5 million refund under a Sec. 1341 claim of right, the [...]