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IRS Agents Tighten the Thumb Screws on R&D Credit
Recent taxpayer experiences suggest that IRS agents are becoming more aggressive in denying taxpayer claims of research and development tax credits through narrow construction of the so-called...
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The SALT Cap and State Taxation of Pass-Through Entities
Among the many significant changes in the 2017 Tax Cut and Jobs Act (TCJA), individual taxpayers’ deductions for state and local taxes (SALT deductions) on federal Form 1040 Schedule A were capped at...
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Bill C-208: Intergenerational Business Transfers
On June 29, 2021, Bill C-208 was granted Royal Assent and became law in Canada. Bill C-208 amended the Income Tax Act (Canada) (the “Act”) to provide tax relief to families wishing to transfer shares...
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IRS Independent Office of Appeals
When dealing with the Internal Revenue Service during the initial stages of a tax case, whether it involves an audit, collection issue, request for penalty relief, or a proposed plan of resolution such...
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