Searching Content indexed under Income Tax by Cozen O'Connor ordered by Published Date Descending.
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The Deductibility Of Future Alimony Payments Just Might Depend On The Past
On July 22, 2019, the IRS issued an article clarifying the treatment of payments pursuant to a modified agreement.
United States
27 Sep 2019
The Income Tax Rescission Doctrine - The Code’s "Etch-A-Sketch" Tax Planning Tool
Neither the tax code nor the regulations to the tax code answer the question whether a transaction purporting to unwind or rescind an earlier transaction will be given effect so that neither transaction will be treated as having occurred for federal income tax purposes.
United States
12 Mar 2013
Fiscal Cliff Bill Extends Home Energy Efficiency Tax Credits For Businesses And Homeowners
On January 1, 2013, the U.S. Congress passed last minute legislation known as the American Taxpayer Relief Act of 2012 to avoid automatic increases in income taxes for millions of Americans, as well as draconian cuts to the budget of the federal government, that many feared would plunge the nation’s economy back into recession.
United States
8 Jan 2013
Alternative Minimum Tax: 3-Point Bulletin
Taxpayers are obligated to pay the AMT if it is higher than their regular tax rate.
United States
13 Dec 2012
With the media and American public focused on the presidential race and never-ending drama of the Republican primaries, Congress has been largely shielded from the spotlight these past few weeks.
United States
23 Mar 2012
Pallets By Themselves Not Considered Containers
In Procter & Gamble Paper Products Company v. Commonwealth, No. 768 F.R. 2009 (Pa. Commw. Oct. 13, 2011), a panel of the Commonwealth Court held that wooden pallets by themselves used in shipping were not considered "containers" and therefore cannot be considered returnable containers subject to sales tax upon their rental and use.
United States
9 Jan 2012
Tax Compromises Possible At Board Of Appeals
The Department of Revenue’s Miscellaneous Tax Bulletin 2011-02 (Nov. 16, 2011) announces a new compromise procedure at the Board of Appeals (BOA).
United States
6 Jan 2012
Philadelphia Amends Business Privilege Tax Bases, Rates & Credits & Provides Relief To New Businesses
Philadelphia City Council unanimously passed bills number 110554 and 110548-A, both of which were signed by the mayor on November 14. Bill number 110554 amends the city’s Business Privilege Tax (BPT) to allow for an exclusion to all taxpayers for a flat amount of receipts from the gross receipts portion of the tax, a pro-rata exclusion from the net income portion of the tax to account for the excluded receipts, a credit against tax to allow for use of single-factor apportionment, and a restructu
United States
19 Dec 2011
Bank Shares Tax Calculation Modified
The Commonwealth Court en banc dismissed exceptions from a panel decision and held that the calculation of Bank Shares Tax must be modified to cure a constitutional defect in the application of the tax to certain post-merger institutions.
United States
18 Aug 2011
Last Chance to Correct 409A Violations Without Having to Pay a Penalty
The IRS issued Notice 2010-6 (Notice) earlier this year, providing taxpayers with a mechanism to correct certain IRC Section 409A document errors.
United States
11 Nov 2010
If it is Not Clearly Excluded, it Must be Included: "Fair Market Value" Includes Unpaid Sales Tax in Washington State
On September 9, 2010, the Washington Supreme Court once again proved it will go to great lengths to protect policyholders in disputes with their insurers.
United States
21 Sep 2010
License for Canned Software is Taxable
The Supreme Court of Pennsylvania held that a license to use canned software is a license to use tangible personal property and is therefore taxable for Sales and Use Tax purposes.
United States
28 Jul 2010
Exemption Denied for Lack of Free Services
A panel of the Commonwealth Court reversed a trial court and held that a nonprofit corporation that provided student housing was not entitled to a charitable exemption because it did not give free or discounted services to the students.
United States
4 May 2010
No Class Action to Oppose Filing Fees
A panel of the Commonwealth Court held that a taxpayer may not proceed as a class action before a board of assessment appeals in challenging a filing fee imposed by the board.
United States
4 May 2010
Under New Jersey Law, Tax Sale Certificate Purchasers Do Not Hold A "Tax Claim" And, Therefore, Applicable Interest Rate May Be Modified
The state of New Jersey has gained a reputation as being a desirable state in which to purchase tax sale certificates, due in part to the 18% statutory interest rate that a certificate holder could obtain on his or her investment.
United States
9 Mar 2010
Foundation Not Entitled To Charitable Exemption
In an unreported opinion, the Commonwealth Court held that a nonprofit corporation with the sole purpose to support the educational mission of a charter school was not entitled to an exemption for real estate that it leased to the school.
United States
3 Feb 2010
YMCA Exempt Charity
In the third appellate decision in ten years of litigation, a commercial fitness center failed in a claim that the operation of a fitness center by a YMCA violated the prohibition against subsidizing a commercial business unrelated to the YMCA’s charitable purpose.
United States
3 Feb 2010
PEO Did Not Sell Help Supply Services
In a case of first impression, a panel of the Commonwealth Court concluded that a professional employer organization (PEO) did not sell help supply services within the meaning of the Sales and Use Tax.
United States
25 Jan 2010
Transfer Of Residence To Trust Is Taxable
A divided panel of the Commonwealth Court held that the transfer of a vacation residential property by husband and wife to themselves as trustees to benefit themselves and their children was taxable because the trust was a business trust, not an ordinary trust for realty transfer tax purposes.
United States
21 Jan 2010
Mobile Homes Are Real Estate
In two cases, a panel of the Commonwealth Court held that mobile homes were taxable as real estate for real estate tax purposes.
United States
19 Jan 2010
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