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Federal Taxation

  • Medtronic v. Commissioner: New Direction for Transfer Pricing Cases?

    By:
    Rita Chung, CPA
    |
    Jan 1, 2019
    For tax years 2005 and 2006, the IRS proposed a transfer pricing adjustment resulting in a tax deficiency of over $1.35 billion.  Medtronic filed a lawsuit in the U.S. Tax Court, and in June of 2016, the Tax Court issued its decision disagreeing with the IRS’s allocation of income.  

  • Altera: Legislative Intent Within Administrative Bounds

    By:
    Michael I. Billet, JD, CPA
    |
    Oct 1, 2018

    Altera Corporation & Subsidiaries (Altera Corp.) is battling the IRS in court over the validity of a federal income tax regulation that concerns Section 482 of the Internal Revenue Code (IRC).  

  • A Forensic Guide to Finding Cryptocurrency in Divorce Litigation

    By:
    Mark DiMichael, CPA, CFF, ABV, CFE and Katerina Gaebel, CPA
    |
    Sep 1, 2018
    In recent years, awareness and use of Bitcoin and cryptocurrency has risen dramatically. Cryptocurrency transactions are fast, global, decentralized, secure, and irreversible. Although cryptocurrency and blockchain technology have the ability to revolutionize commerce, cryptocurrency’s anonymous nature has made it a haven for illicit activity.  This is because while cryptocurrency transactions are all publicly viewable on a “blockchain,” the individual participants of each transaction cannot be easily determined. 

  • Accountants and Divorce Attorneys: A Marriage Made in Congress

    By:
    Joseph A. DeMarco, JD
    |
    Jul 1, 2018
    As divorce attorneys seek to navigate the impact of the Tax Cuts and Jobs Act (“TCJA”) on divorce cases, one thing appears clear: Effective advocacy for matrimonial clients will require greater reliance on accounting professionals. 

  • Rising Interest Rates are an Opportunity to Deduct Capital Loss Carryovers

    By:
    Thomas J. Boczar and Jeff Markowski
    |
    Jun 1, 2018

    Some companies currently face two concurrent challenges—first, how to accelerate the utilization of otherwise non-deductible capital loss carryovers for tax purposes and second, how to guard against the impact of rising interest rates.

  • Is That Loss Actually Deductible On Your Cannabis Investment or Loan?

    By:
    Peter Metz, CPA, and John Pellitteri, CPA
    |
    Jun 1, 2018

    At the federal level, cannabis businesses that “touch the leaf” are taxed on the sum of revenue less cost of goods sold, according to IRC section 280E. Businesses that do not touch the leaf—meaning those that indirectly benefit from cannabis activity, such as suppliers and landlords—can also claim other deductions. But if there is a loss on your investment or loan, will the loss be deductible? Although the investment might appear rosy right now, storm clouds could one day come to this industry. 

  • Taking Full Advantage of the R&D Tax Credit: Tips for Identifying, Gathering, and Documenting a Sustainable Claim

    By:
    Peter J. Scalise
    |
    May 1, 2018
    In 1981, the U.S. economy was in a recession, and research-and-development jobs were declining throughout the country. In response, Congress passed the Economic Recovery Tax Act of 1981, which included the Research and Development Tax Credit Program (hereinafter “RTCP” or “RTC”), enacted into the IRC. 
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