Tax Law News and Insights

Highlights As provided in the Inflation Reduction Act (IRA), certain taxpayers may elect to receive direct payment of many of the tax credits included in the law. The U.S. Department of the Treasury and IRS recently finalized regulations on the rules and procedures regarding direct payment (sometimes referred to as...

Read More

On Feb. 14, 2024, the California Office of Tax Appeals (OTA) denied the Franchise Tax Board (FTB)'s petition for rehearing, confirming its opinion in Appeal of Microsoft Corporation. The decision allows Microsoft to include 100% of its foreign dividends in the sales factor denominator. Case Overview Microsoft, a water's-edge filer in California, appealed the...

Read More

Since the beginning of tax time, the key distinction between a partnership and a corporation has been its ability to "pass-through" U.S. federal income tax1 liability to its partners. Pass-through taxation is a notoriously difficult concept to implement. The complications of partnership tax multiply when the Internal Revenue Service (IRS) later...

Read More