New Jersey recently announced the New Jersey Tax Amnesty program. The New Jersey Division of Taxation has indicated that both individuals and businesses may qualify for the program. The amnesty
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Civil Tax
New Law Eases Requirements for Combat-Zone Contractors to Claim Foreign Earned Income Exclusion
By Fox Rothschild LLP on
The Bipartisan Budget Act of 2018 eases the requirements for combat-zone contractors to claim the foreign earned income exclusion. A U.S. citizen is generally taxed on his worldwide income. The…
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An Update on Litigation of Cannabis Business Tax Issues
By Fox Rothschild LLP on
I have recently penned a Law360 article discussing lessons learned from recent tax decisions impacting cannabis businesses. We will continue to cover this topic on this blog.
To be alerted…
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Section 280E and the Harsh Reality of Double Taxation
By Fox Rothschild LLP on
There is not too much to say about the Tax Court’s latest decision involving a marijuana company. In Loughman v. Commissioner, T.C. Memo 2018-85, the operators of a Colorado…
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The High Tax Compliance Burden For Cannabis Businesses
By Fox Rothschild LLP on
Yesterday, the Tax Court issued its opinion in Alterman v. Commissioner, T.C. Memo 2018-83. This case involved the operation of a medical marijuana dispensary which was reported on Schedule…
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IRS Guidance to Field: Deep Clean Equipment Used in Cannabis Businesses Before Selling
By Fox Rothschild LLP on
Attorneys representing cannabis businesses are often faced with questions about what happens when the cannabis business has not paid its taxes and the IRS is proceeding with collection actions. No…
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District Court Holds Tax Liens Stay with Property after Conveyance
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United States v. Gerard, a recent case from the Northern District of Indiana, demonstrates how a tax lien, once attached, can stay with property even after the property is…
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Charles Rettig – From Private Practice to President Trump’s Nominee for IRS Commissioner
By Jessica Labella Kitain on
The White House released a statement on February 8, 2018 that President Trump nominated Charles Rettig as the new Commissioner of Internal Revenue Code for the remainder of a five…
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Eleventh Circuit Cuts into Presumption of Correctness Standard for IRS Assessments
By Fox Rothschild LLP on
In United States v. Stein, the Eleventh Circuit recently decided a novel – but critical – issue for taxpayers. It held that an affidavit that satisfies Rule 56 of…
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Law Firm Shareholders Liable for Trust Fund Recovery Penalties
By Fox Rothschild LLP on
The Internal Revenue Code requires employers to withhold certain taxes in “a special fund in trust for the United States” (sec. 7501(a)). IRS regulations require employers to pay these trust…
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