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Applicable Federal Rates for October 2017 Released (Rev. Rul. 2017-20)

Various prescribed rates for federal income tax purposes for October 2017 have been provided by the IRS. The September 2017 rates can be found here October Interest Rates The annual short-term,...

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Alaska’s Foreign Dividends Received Deduction Applied to U.S. Subsidiary

A parent company could deduct 80% of dividends it received from a domestic subsidiary that had less than 20% of its business activity in the United States. The 100% dividends received deduction did not...

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Illinois EDGE Credit Reinstated, Modified

Gov. Bruce Rauner has signed legislation that reinstates the Growing Economy Tax Credit Act (EDGE credit) program until June 30, 2022. In addition, the legislation modifies the corporate and personal...

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Senate ACA Repeal Vote Expected Next Week

Senate Republicans will try once again to repeal and replace the Patient Protection and Affordable Care Act (ACA) (P.L. 111-148) after unsuccessful attempts this summer (TAXDAY, 2017/07/31, C.1). “It...

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Interest Paid to Affiliates Was Subject to Alabama’s Addback Requirement

A taxpayer was required to include interest paid to both U.S. and foreign related companies on its Alabama business income tax return. The interest payments did not fall under the exceptions to the...

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Internet Tax Law Rejected by State Supreme Court

A South Dakota law that required out-of-state retailers to collect and remit sales tax on internet sales was struck down by the South Dakota Supreme Court. The court held that the Internet sales tax...

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IRS Pilot Program Expands the Scope of Letter Rulings for Section 355...

The IRS has introduced a pilot program expanding the scope of letter rulings to include, for a period of time, rulings on the tax consequences of Code Sec. 355 distributions. Additionally, this...

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Alabama Affiliated Group Members Allowed to Share NOL Carryovers

The Court of Civil Appeals has affirmed the circuit court in upholding the decision of the ALJ that allowed members of an Alabama affiliated group to report NOLs incurred prior to 2007 by one group...

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Interest Income Was Non-Business Income in New Mexico

Interest income from payment-in-kind notes (PIK notes) was non-business income and not apportionable in New Mexico under the Uniform Division of Income for Tax Purposes Act (UDITPA) or U.S. Supreme...

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Virginia Offers Hurricane Irma Tax Relief

Virginia will provide tax relief to those individuals and businesses in Florida and Georgia affected by Hurricane Irma. The Department of Taxation offers extensions and penalty waivers. To qualify,...

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Tax Reform Framework Release Expected in Coming Days

Top congressional Republicans and the White House are scheduled to release their framework for tax reform legislation some time  during the week of September 25.  Meanwhile, Ways and Means Republicans...

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LB&I Directive Provides Safe Harbor for Determining QREs for Research Credit

The IRS’s Large Business & International (LB&I) Division has issued a Directive on the evidence needed to substantiate qualified research expenditures (QREs). The Directive allows examiners to...

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Weekly Report from Washington, D.C.

As taxpayers recover from recent disasters, the IRS announced more relief measures. Also, the IRS held a hearing on the new centralized partnership audit regime. Meanwhile, the Senate Finance Committee...

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Louisiana Gives Filing Extensions to Hurricane Harvey Victims

Due to Hurricane Harvey, Lousiana grants filing extensions to taxpayers whose homes, principal places of business, or critical tax records are located in declared disaster areas. Filing extensions will...

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Texas Again Extends Hotel Tax Relief

Texas has extended the suspension of the collection of state and local hotel or motel occupancy taxes for Hurricane Harvey victims and relief-effort personnel through October 23, 2017. Gov. Abbott’s...

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Wisconsin Eliminates Alternative Minimum Tax

The enacted 2017 Wisconsin budget bill makes numerous changes to personal income tax and corporation franchise and income tax. Alternative minimum tax The bill eliminates the alternative minimum tax...

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House Votes Down Disaster Tax Relief Bill

The House voted down the Disaster Tax Relief and Airport and Airway Extension Bill of 2017 on September 25 by a 245-to-171 vote, needing a two-thirds majority to pass. The bill, introduced by House...

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Senate Finance Committee Holds Hearing on ACA Repeal, Replace Bill; Now...

The Senate Finance Committee (SFC) held a hearing on September 25 examining the Graham-Cassidy proposal, the latest Senate Republican health care bill to repeal and replace the Patient Protection and...

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Tax Reform Framework Release Expected Wednesday

Top congressional Republicans and the White House are expected to release details of their tax reform framework on September 27, which will be used as a guidepost for impending legislation. The release...

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New Procedures Help FFIs Comply with FATCA’s TIN, Date of Birth Requirements...

The IRS will amend Foreign Account Tax Compliance Act (FATCA) regulations for foreign financial institutions (FFIs) that report taxpayer identification numbers and/or dates of birth for certain...

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