Upcoming National Meeting

2024 Canadian Tax Workshop For U.S. Companies

The COST Canadian Tax Workshop for US Companies covers the key tax issues U.S. companies who are doing business with Canadians or in Canada need to know. The primary focus of the Workshop will be on GST, HST and Income Tax but will also cover QST, Payroll and Property Taxes. Attendees will also participate in an interactive audit session covering Canadian tax issues that they’ve been dealing with.

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Newsletters & Media

Cost Conscious

ISSUE 24-22; November 1, 2024

Controlling Property Tax Increases (Part II) – Controlling property taxes, especially given recent residential property value increases, is a focus of many state legislatures. There are several ways for states to control property tax increases by using methods such as exemptions (e.g., homestead exemptions), caps on valuation increases (e.g., California Proposition 13), automatic adjustments that

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Bloomberg TAX

Early Crypto Investor Fights $29 Million Tax for Bitcoin Forks

November 08, 2024

A Nevada executive alleges the IRS has wrongly assessed almost $29.4 million in taxes and penalties over cryptocurrency forks he says he didn't benefit from.

IRS PLR: Relief Granted for Limited Liability Company to Self-Certify as a Qualified Opportunity Fund (IRC §1400Z-2)

November 08, 2024

The IRS has published a private letter ruling on Section 1400Z-2 and Treasury Regulation Sections 1.1400Z-2 and 301.9100 granting relief to a limited liability company, classified as a partnership, by deeming taxpayer’s Form 8996 timely filed, and thereby making the election under Section 1400Z-2 and Treasury Regulation Section 1.1400Z2(d)-1(a)(2)(i) to self-certify as a Qualified Opportunity Fund. [PLR 202445007]

IRS PLR: Limited Liability Company Granted Relief to Self-Certify as a Qualified Opportunity Fund (IRC §1400Z-2)

November 08, 2024

The IRS has published a private letter ruling on Section 1400Z-2 and Treasury Regulation Sections 1.1400Z-2 and 301.9100 granting relief to a limited liability company, classified as a partnership, by deeming taxpayer’s Form 8996 timely filed, and thereby making the election under Section 1400Z-2 and Treasury Regulation Section 1.1400Z2(d)-1(a)(2)(i) to self-certify as a Qualified Opportunity Fund. [PLR 202445012]

IRS PLR: Transfers to Trust, Qualified as Settlement Fund, Excluded From Gross Income (IRC §468B)

November 08, 2024

The IRS has published a private letter ruling on Section 468B and Treasury Regulation Section 1.468B determining that a trust satisfied the three requirements of Treasury Regulation Section 1.468B-1(c) and is a qualified settlement fund for federal income tax purposes. The IRS also determined that the trust can exclude from its gross income, under Treasury Regulation Section 1.468B-2(b)(1), transfers of funds from a Court ordered trust established to aid in the administration of settlements between plaintiffs and defendants. [PLR 202445005]

IRS PLR: Trust Qualifies as Settlement Fund, Transfers to Trust Excluded From Gross Income (IRC §468B)

November 08, 2024

The IRS has published a private letter ruling on Section 468B and Treasury Regulation Section 1.468B determining that a trust satisfied the three requirements of Treasury Regulation Section 1.468B-1(c) and is a qualified settlement fund for federal income tax purposes. The IRS also determined that the trust can exclude from its gross income, under Treasury Regulation Section 1.468B-2(b)(1), transfers of funds from a Court ordered trust established to aid in the administration of settlements between plaintiffs and defendants. [PLR 202445006]

’Varian’ Irrelevant to Liberty Global Tax Refund Suit, US Says

November 08, 2024

The US Tax Court's ruling in Varian Medical Systems v. Commissioner sheds no light on Liberty Global Inc.'s $110 million tax refund appeal because it doesn't address the economic substance doctrine, the US told the Tenth Circuit.

IRS PLR: Extension Granted for Electing Optional Adjustment to Basis of Partnership Property (IRC §754)

November 08, 2024

The IRS has published a private letter ruling on Section 754, and Treasury Regulation Section 301.9100, granting an extension of time for a partnership to elect to adjust the basis of partnership property. [PLR 202445008]

Wisconsin AG Discourages Review of Catholic Nonprofit Tax Ruling

November 08, 2024

Wisconsin's attorney general says that the Supreme Court doesn't need to review a March ruling from the state's highest court that a Catholic nonprofit can't meet its religious exemption.

IRS PLR: Insurance Company Contract to be Treated as Annuity Contract (IRC §72)

November 08, 2024

The IRS has published a private letter ruling on Section 72 regarding annuities and certain proceeds of endowments and life insurance contracts. [PLR 202445015]

Treasury Urges Supreme Court to Skip Review of Tax Records Suit

November 08, 2024

The US Supreme Court should deny review of a taxpayer's lawsuit seeking records from the IRS using a confidentiality and disclosure statute in the tax code, rather than through a traditional Freedom of Information Act request, the Treasury Department said Friday.

Featured Resources

COST - Council on State Taxation

Amicus Briefs

COST - Council on State Taxation

COST Studies, Articles & Reports

2024 State and Local Amnesty Programs

Tracker of most state and local tax amnesty programs enacted and conducted in 2024.

COST - Council on State Taxation

COST Comments & Testimony

Letter to the Legislature in Opposition to Sales Tax Base Expansion to Business Inputs in Tax Reform Proposals

COST sent letters to Louisiana House Speaker, Senate President, House Ways and Means and Senate Revenue and Fiscal Affairs committees to suggest that any sales tax base expansion in the upcoming extraordinary session be limited to business-to-consumer transactions and provide for a broad exemption for business-to-business transactions or business inputs. The letter also urges Louisiana to consider