Fuel Tax Refund Implementation Encounters Appropriation Hurdles
Section 6435’s fuel tax refund for downstream parties stalls due to appropriation limitations.
Tax Management Memo
Latest Tax Journals
Courts Scrutinize ERISA Fiduciary Process: Are You Prepared?
Recent Supreme Court decisions emphasize that ERISA fiduciary prudence is determined by a well-documented decision-making process rather than just investment outcomes.
Can Soaring Tech Salaries Still Qualify for R&D Tax Credits?
Elite engineers’ soaring compensation packages are complicating R&D tax credit claims under IRC §41, requiring companies to enhance their audit readiness with more rigorous documentation of qualified research activities.
Why Partnerships Are Surprised by High Imputed Underpayments
Imputed underpayments under the Bipartisan Budget Act of 2015 are often unexpectedly high due to the inclusion of non-income items in calculations, affecting partnerships during audits and Administrative Adjustment Requests.
DOJ Tax’s Dissolution Forces a High-Stakes Reset for IRS and DOJ
The DOJ Tax Division’s dissolution necessitates a post-mortem of the IRS-DOJ partnership to identify the critical elements for U.S. tax enforcement and voluntary compliance.
HR Solutions That Become Tax Problems: How to Minimize Risk
HR solutions can create unexpected tax liabilities, requiring cross-functional vigilance and proactive strategies to ensure compliance.
AI Reshapes Software R&D Tax Credits, Eligibility Landscape
AI’s integration into software development challenges traditional R&D tax credit criteria, necessitating new frameworks for eligibility.
From Tax Court to SCOTUS: Cases That May Reshape Tax Law in 2026
Key tax cases in 2026 will address economic substance, limited partnerships’ distributive shares in calculating self-employment tax, and the nondelegation doctrine related to executive authority.
How Do States Determine Trust Income Tax Nexus in the Modern Era?
State trust income tax nexus rules vary widely, requiring regular review to minimize tax exposure as courts increasingly reject perpetual nexus claims.
Estate Planners Navigate New Terrain with Creator Economy
Advising content creators requires specialized strategies to address unique priorities, assets, and income streams.
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