Latest COST Conscious

ISSUE 24-08; April 19, 2024

State Corporate Income Tax Filing Methods (Part 1) – In recent years, many states have either changed or considered changing their default corporate tax filing. New Jersey adopted water’s-edge combined reporting in 2019 only to come back in 2023 with a proposal to allow the Director of Tax to “decombine” taxpayers. Maine, New Hampshire, and Vermont have studied the implementation of mandatory worl

Latest Legislative Alert

ISSUE 24-17; April 23, 2024

COST Opposes Base Erosion Study and Tax Disclosure in Minnesota; COST Opposes New California Digital Advertising Services Tax Legislation

Latest Practitioner Connection

ISSUE 24-08; April 12, 2024

GeTtin’ SALTy: Episode 26: Catch-Up with Jared Walczak at the Tax Foundation, with a Focus on Property Tax Relief – In this episode of GeTtin’ SALTy, host Nikki Dobay is joined by Jared Walczak, Vice President of Special Projects at the Tax Foundation. Jared catches Nikki up on Tax Foundation's impression of 2023, and then theydiscuss what Jared has been focused on this legislative session. Jared

BLOOMBERG TAX

Case: Taxpayer Was Liable for Additional Tax on Early Retirement Account Withdrawal; No Exception for Emergency Expenses Applied to Tax Year at Issue (T.C. Summ.) (IRC §72)

April 26, 2024

Taxpayer was liable for a 10% additional tax under I.R.C. §72(t) due to withdrawing from her retirement account before the age of 59.5, the Tax Court held in a non-precedential opinion. The taxpayer withdrew funds from her retirement account in 2018 to pay overdue rent and avoid being evicted from her home. The court rejected the taxpayer’s argument that she should be exempt from the tax because she withdrew the money due to economic hardship. The court explained that although §72(t)(2)(I) exempts certain withdrawals made for emergency expenses from the additional tax, that provision did not apply to distributions made in 2018. [Kohl v. Commissioner, T.C. Summ. Op. 2024-4 (Apr. 25, 2024)]

OECD Combined Global Minimum Tax Guide Cuts Down Document Trail

April 26, 2024

The OECD consolidated the global minimum tax's three tranches of administrative guidance and model rules to simplify the document trail and help countries implement the framework.

Poland Delays Mandatory Electronic Invoicing Until 2026

April 26, 2024

Poland will require electronic invoicing via a government-run clearinghouse starting Feb. 1, 2026, for businesses with sales in 2025 exceeding 200 million Polish zloty.

Irish Tax Office to Prioritize Global Minimum Tax Work in 2024

April 26, 2024

The Irish tax office's 2024 priorities include working with companies to apply the global minimum tax and ensuring companies have solid plans to pay off debts.

EU Calls on UN to Avoid Duplicating Global Tax Discussions

April 26, 2024

A future United Nations Framework Convention on International Tax Cooperation should help countries reform their domestic tax systems and avoid duplicating work on international tax reform, the European Union said ahead of UN tax discussions in New York.

India Inheritance Tax Dominates Election Debate as Polls Heat Up

April 26, 2024

India’s election campaigning this week was overtaken by a heated debate around wealth redistribution and an inheritance tax, with Prime Minister Narendra Modi seeking to exploit fears in a country where income inequality is among the highest in the world. 

Transfer Pricing Chat: Brazil’s Gil Mendes of Mattos Filho

April 26, 2024

After charting its own course for nearly three decades, Brazil aligned its transfer pricing framework with the international guidelines of the Organization for Economic Cooperation and Development at the beginning of this year.

Sports Team Owners Can Still Win on Taxes Despite IRS Scrutiny

April 26, 2024

Moss Adams' Clay Hodges and Daniel Quintana reviews sports partnerships' tax deduction options, saying partners should be proactive about documentation and record retention.

EU Carbon Tax Creates Challenges for Some Developing Economies

April 26, 2024

EY's Richard Albert and George Riddell discuss the impact of the EU's new carbon tax which may create significant challenges for developing economies.

Vietnam’s Corporate Incentives to Offset Minimum Tax Too Limited

April 25, 2024

Business groups are critical of Vietnam's financial support plan to soften the impact of the global minimum tax on multinationals, saying it's too vague and narrow in scope, with only large projects able to meet its eligibility conditions.