In 3M Companies & Subsidiaries, Inc. v. Commissioner, the Tax Court, in a 9-8 majority decision issued on February 9, 2023, sustained a proposed deficiency in income tax of $3.6 million attributable to the petitioner’s failure to include $23 million in blocked royalty income from a controlled Brazilian subsidiary based on Brazilian law on its consolidated return for 2006. The Tax Court rejected the petitioner’s argument that the regulation was invalid under Chevron U.S.A., Inc. v. Natura…
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Jerald David August was highlighted in the Forbes article, “Why Novak Djokovic and Other Top Tennis Stars Choose Monaco as Their Home.” Read the article.
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Tax attorney Jerald David August is quoted in a Law360 Tax Authority article discussing recent court rulings that restrict international travel for U.S. taxpayers with tax debts. Read the article.
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The IRS recently issued final regulations for Section 199A, which allows a 20 percent deduction from a taxpayer’s ordinary income from certain qualified trades or businesses. There is not currently a clear test to determine whether businesses are separate for purposes of the deductions. Jerry addressed a variety of key issues relating to the 199A deduction in an ALI-CLE National webinar and Tax Notes reported on the webinar in a recent article. Read the full article here and please contact Jer…
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Dream of Owning a Plane? This Tax Break Can Help. Growing up in central Connecticut in the 1980s, Joshua Siegel loved everything about flying. He couldn’t afford flying lessons, let alone his own plane, but he kept dreaming. By his 20s, he had achieved some financial success and was able to take advantage of a new tax deduction meant to spur private plane sales in the aftermath of the Sept. 11 terrorist attacks. Using the tax break, he deducted the entire cost of a new Cessna more quickly than…
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State of South Dakota v. Wayfair, Inc. et al In what portends to be the next landmark Supreme Court decision on a state’s constitutional power to impose state sales tax on interstate commerce the Court recently heard oral arguments in South Dakota v. Wayfair, Inc., et al, cert granted, 138 S.Ct. 735 (1/12/2018). The issue before the Court is whether South Dakota sales tax scheme can satisfy the requirement under the Commerce Clause by imposing sales and use tax collection on a remote seller wi…
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Reprinted From The Winter 2018 Issue Of ALI-CLE’s The Practical Tax LawyerWinter 2018 Edition On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (“TCJA”) of 2017, P.L. 115-97, which introduced a set of tax cuts and other reforms that will affect substantially all U.S. taxpayers, both corporate and individual. The key feature of the new legislation was the reduction by 40 percent of the maximum federal corporate income tax rate from 35 percent to 21 percent,…
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The new tax law enacted in December swapped out a graduated corporate tax rate topping out at 35 percent with a flat 21 percent rate across the board. While this provision, combined with the elimination of the corporate alternative minimum tax (AMT), might seem to have simplified matters considerably, attorney Jerald David August, a tax partner at Kostelanetz & Fink, LLP, who spoke at the Foundation for Accounting Education’s conference “Impact of the New Tax Law: a Sid Kess Work…
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ALI-CLE Course Materials, January 18, 2018. VCZG0118 ALI-CLE 57…JOBS ACT OF 2017 IMPAC INTERNATIONAL TAX CHANGES UNDER TCJA Jerald David August Kostelanetz & Fink, LLP New York, New York Copyright (c) 2018 The American Law Institute (c) 2018 Jerald David August. All rights reserved. VCZG0118 ALI-CLE 57 2018 WL 551477…
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