This document provides an overview of tax resources and the process of developing tax law in the United States. It begins by explaining the constitutional basis for taxation and then outlines the statutory development of the tax code over time, from the Revenue Act of 1913 to the current Internal Revenue Code. It also describes the roles of key entities like the IRS, Treasury Department, and Congressional tax committees in interpreting and enforcing tax law. Finally, it discusses various sources of tax guidance and case law like regulations, rulings, judicial opinions, and treatises used in researching tax issues.
OECD Public Sector Accruals Symposium - Giovanna DABBICCOOECD Governance
This presentation by Giovanna DABBICCO was made at the 14th Annual OECD Public Sector Accruals Symposium, Paris 3-4 March 2014. Find out more at http://www.oecd.org/gov/budgeting/14thannualoecdpublicsectoraccrualssymposiumparis3-4march2014.htm
The Impact of FATCA and CRS on Employee Share Plans and Share OwnershipAndrea Huck-Esposito
2015 heralds the start of US FATCA report submissions, requiring global reporting of financial accounts to the US. Following on from FATCA, the Organisation for Economic Co-operation and Development (OECD) are introducing agreements for a Common Reporting Standard (CRS). The CRS is designed to extend ‘FATCA-style’ reporting across other jurisdictions with an expectation that over 40 countries will adopt this. Join this informative discussion to better understand what FATCA and CRS means, learn about the related time frames and reporting obligations, and more importantly, find out what the impact of these regulations is to both employee share plans and share ownership. Come with questions, leave with answers on this tricky topic.
OECD Public Sector Accruals Symposium - Giovanna DABBICCOOECD Governance
This presentation by Giovanna DABBICCO was made at the 14th Annual OECD Public Sector Accruals Symposium, Paris 3-4 March 2014. Find out more at http://www.oecd.org/gov/budgeting/14thannualoecdpublicsectoraccrualssymposiumparis3-4march2014.htm
The Impact of FATCA and CRS on Employee Share Plans and Share OwnershipAndrea Huck-Esposito
2015 heralds the start of US FATCA report submissions, requiring global reporting of financial accounts to the US. Following on from FATCA, the Organisation for Economic Co-operation and Development (OECD) are introducing agreements for a Common Reporting Standard (CRS). The CRS is designed to extend ‘FATCA-style’ reporting across other jurisdictions with an expectation that over 40 countries will adopt this. Join this informative discussion to better understand what FATCA and CRS means, learn about the related time frames and reporting obligations, and more importantly, find out what the impact of these regulations is to both employee share plans and share ownership. Come with questions, leave with answers on this tricky topic.
Il carnet Buoni+ sara’ omaggiato a tutti i clienti che effettueranno un acquisto presso un negozio GameStop o sul sito www.gamestop.it fino al 31 Luglio 2015, fino ad esaurimento scorte del carnet. I buoni saranno spendibili dalla transazione successiva alla consegna del carnet e saranno validi fino al 06 dicembre 2014, e fino ad esaurimento scorte dei prodotti cui si riferiscono. Chiedi chiarimenti al nostro staff.
Alumnos destacan de la VIU la gran ventaja que ofrece de conjugar estudios y vida laboral
En un vídeo que se puede ver en Youtube
También valoran positivamente su metodología y la posibilidad de relacionarse con estudiantes de otras provincias españolas
Asimismo, resaltan la atención que reciben del profesorado y la facilidad para contactar con los docentes
Más de 450 alumnos se han enfrentado a los tradicionales exámenes de enero
Bioconservación está especializada en la fabricación de productos para la absorción de etileno, control de la humedad, instrumentos de control de calidad y seguimiento de la temperatura en tránsito.
Presentació en la 1ª Jornada en #NutriciónDeportiva Campus de Alimentación Torribera #UB #INEFC http://www.ub.edu/campusalimentacio/es/noticies/1a_jornada_nutricio_esportiva.html
In this powerpoint presentation, tax attorney Mike DeBlis discusses the mechanics of FATCA, the ripple effect that this law has had on those with unreported foreign assets, and why it is one of the most controversial laws that no one has ever even heard about.
Il carnet Buoni+ sara’ omaggiato a tutti i clienti che effettueranno un acquisto presso un negozio GameStop o sul sito www.gamestop.it fino al 31 Luglio 2015, fino ad esaurimento scorte del carnet. I buoni saranno spendibili dalla transazione successiva alla consegna del carnet e saranno validi fino al 06 dicembre 2014, e fino ad esaurimento scorte dei prodotti cui si riferiscono. Chiedi chiarimenti al nostro staff.
Alumnos destacan de la VIU la gran ventaja que ofrece de conjugar estudios y vida laboral
En un vídeo que se puede ver en Youtube
También valoran positivamente su metodología y la posibilidad de relacionarse con estudiantes de otras provincias españolas
Asimismo, resaltan la atención que reciben del profesorado y la facilidad para contactar con los docentes
Más de 450 alumnos se han enfrentado a los tradicionales exámenes de enero
Bioconservación está especializada en la fabricación de productos para la absorción de etileno, control de la humedad, instrumentos de control de calidad y seguimiento de la temperatura en tránsito.
Presentació en la 1ª Jornada en #NutriciónDeportiva Campus de Alimentación Torribera #UB #INEFC http://www.ub.edu/campusalimentacio/es/noticies/1a_jornada_nutricio_esportiva.html
In this powerpoint presentation, tax attorney Mike DeBlis discusses the mechanics of FATCA, the ripple effect that this law has had on those with unreported foreign assets, and why it is one of the most controversial laws that no one has ever even heard about.
In April 2013, the Senate ‘Gang of Eight’ released its proposal for overhauling our nation’s immigration system. Call the Border Security, Economic Opportunity, and Immigration Modernization Act of 2013 (s.744), this bill proposes to eliminate the current immigration backlog, create new visa categories for high-skilled and skilled workers, overhaul our green card application system, and address the statuses of approximately 11 million undocumented workers in the United States.
Although only a bill at this point, this is the first serious effort by a bi-partisan group to address the immigration program in quite some time. In this informative webinar, attorneys Murali Bashyam and Ame Coats will educate the public on the bill and what they can expect if it, or something similar, is ultimately passed by Congress and signed by the President.
State and Local Tax Nexus Issues and the Impact on Mergers and AcquisitionsSkoda Minotti
Would you sell a home before making it attractive enough to turn a profit? Selling a business is no different. Before you plan to sell, there are essential tax implications you should understand and steps you should take to ensure smooth sailing for a successful transaction
On June 21st, the United States Supreme Court issued its long-awaited decision in South Dakota v. Wayfair, overturning the requirement that an out-of-state seller have physical presence in order for a state to require the seller to collect and remit state and local sales tax. Under Wayfair, substantial nexus exists if the taxpayer “avails itself of the substantial privilege of carrying on a business in that jurisdiction.”
Don't miss our upcoming webinars! Subscribe today!
In this webinar:
1) Attendees will be provided with an overview of the structure of our healthcare systems.
2) People will be taken through a review of the Canada Health Act.
3) Everyone will have a better understanding of the intersection between delivery vs. financing in healthcare.
View the YouTube video: https://youtu.be/qSSv11MNB5s
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Leadership Development Training: The Forgotten Aspect of Succession Planning
"Leadership is one of the most observed and least understood phenomena on earth." – James MacGregor Burns
Most organizations understand the value of succession planning, but very few have developed their future leaders. In a recent survey, 86 percent of the respondents agreed their organizations' future depended on the effectiveness of the future leadership. Yet a study found almost 75 percent of respondents felt their leadership development programs were not very effective. Today, many people have the capabilities of being a follower or a leader, depending upon the situation they are put in and the skills they are provided. In fact, Barnes and Krieger, in their seminal work, The Hidden Side of Organizational Leadership, suggested that leadership is more of a reflection of an organization rather than a person.
A "File Trademark" is a legal term referring to the registration of a unique symbol, logo, or name used to identify and distinguish products or services. This process provides legal protection, granting exclusive rights to the trademark owner, and helps prevent unauthorized use by competitors.
Visit Now: https://www.tumblr.com/trademark-quick/751620857551634432/ensure-legal-protection-file-your-trademark-with?source=share
Responsibilities of the office bearers while registering multi-state cooperat...Finlaw Consultancy Pvt Ltd
Introduction-
The process of register multi-state cooperative society in India is governed by the Multi-State Co-operative Societies Act, 2002. This process requires the office bearers to undertake several crucial responsibilities to ensure compliance with legal and regulatory frameworks. The key office bearers typically include the President, Secretary, and Treasurer, along with other elected members of the managing committee. Their responsibilities encompass administrative, legal, and financial duties essential for the successful registration and operation of the society.
WINDING UP of COMPANY, Modes of DissolutionKHURRAMWALI
Winding up, also known as liquidation, refers to the legal and financial process of dissolving a company. It involves ceasing operations, selling assets, settling debts, and ultimately removing the company from the official business registry.
Here's a breakdown of the key aspects of winding up:
Reasons for Winding Up:
Insolvency: This is the most common reason, where the company cannot pay its debts. Creditors may initiate a compulsory winding up to recover their dues.
Voluntary Closure: The owners may decide to close the company due to reasons like reaching business goals, facing losses, or merging with another company.
Deadlock: If shareholders or directors cannot agree on how to run the company, a court may order a winding up.
Types of Winding Up:
Voluntary Winding Up: This is initiated by the company's shareholders through a resolution passed by a majority vote. There are two main types:
Members' Voluntary Winding Up: The company is solvent (has enough assets to pay off its debts) and shareholders will receive any remaining assets after debts are settled.
Creditors' Voluntary Winding Up: The company is insolvent and creditors will be prioritized in receiving payment from the sale of assets.
Compulsory Winding Up: This is initiated by a court order, typically at the request of creditors, government agencies, or even by the company itself if it's insolvent.
Process of Winding Up:
Appointment of Liquidator: A qualified professional is appointed to oversee the winding-up process. They are responsible for selling assets, paying off debts, and distributing any remaining funds.
Cease Trading: The company stops its regular business operations.
Notification of Creditors: Creditors are informed about the winding up and invited to submit their claims.
Sale of Assets: The company's assets are sold to generate cash to pay off creditors.
Payment of Debts: Creditors are paid according to a set order of priority, with secured creditors receiving payment before unsecured creditors.
Distribution to Shareholders: If there are any remaining funds after all debts are settled, they are distributed to shareholders according to their ownership stake.
Dissolution: Once all claims are settled and distributions made, the company is officially dissolved and removed from the business register.
Impact of Winding Up:
Employees: Employees will likely lose their jobs during the winding-up process.
Creditors: Creditors may not recover their debts in full, especially if the company is insolvent.
Shareholders: Shareholders may not receive any payout if the company's debts exceed its assets.
Winding up is a complex legal and financial process that can have significant consequences for all parties involved. It's important to seek professional legal and financial advice when considering winding up a company.
Military Commissions details LtCol Thomas Jasper as Detailed Defense CounselThomas (Tom) Jasper
Military Commissions Trial Judiciary, Guantanamo Bay, Cuba. Notice of the Chief Defense Counsel's detailing of LtCol Thomas F. Jasper, Jr. USMC, as Detailed Defense Counsel for Abd Al Hadi Al-Iraqi on 6 August 2014 in the case of United States v. Hadi al Iraqi (10026)
How to Obtain Permanent Residency in the NetherlandsBridgeWest.eu
You can rely on our assistance if you are ready to apply for permanent residency. Find out more at: https://immigration-netherlands.com/obtain-a-permanent-residence-permit-in-the-netherlands/.
NATURE, ORIGIN AND DEVELOPMENT OF INTERNATIONAL LAW.pptxanvithaav
These slides helps the student of international law to understand what is the nature of international law? and how international law was originated and developed?.
The slides was well structured along with the highlighted points for better understanding .
Car Accident Injury Do I Have a Case....Knowyourright
Every year, thousands of Minnesotans are injured in car accidents. These injuries can be severe – even life-changing. Under Minnesota law, you can pursue compensation through a personal injury lawsuit.
In 2020, the Ministry of Home Affairs established a committee led by Prof. (Dr.) Ranbir Singh, former Vice Chancellor of National Law University (NLU), Delhi. This committee was tasked with reviewing the three codes of criminal law. The primary objective of the committee was to propose comprehensive reforms to the country’s criminal laws in a manner that is both principled and effective.
The committee’s focus was on ensuring the safety and security of individuals, communities, and the nation as a whole. Throughout its deliberations, the committee aimed to uphold constitutional values such as justice, dignity, and the intrinsic value of each individual. Their goal was to recommend amendments to the criminal laws that align with these values and priorities.
Subsequently, in February, the committee successfully submitted its recommendations regarding amendments to the criminal law. These recommendations are intended to serve as a foundation for enhancing the current legal framework, promoting safety and security, and upholding the constitutional principles of justice, dignity, and the inherent worth of every individual.
2. It All Starts with the
Constitution
• Section 8. Clause 1. The Congress shall
have Power to lay and collect Taxes, Duties,
Imposts and Excises, to pay the Debts and provide for the
common Defense and general Welfare of the United States;
but all Duties, Imposts and Excises shall be uniform
throughout the United States.
3. Statutory Basis
• The Revenue Act of 1913 also known as the Tariff Act of 1913
• Every two to three years ended up with new statue
• 1939
• Internal Revenue Code of 1939 – codification of tax law
• Changes passed as amendments proceeding years
• 1954
• Internal Revenue Code of 1954 -2yrs work by House Ways and Means
Committee result was comprehensive revision of the code including
placement
• 1986
• Tip the Sections of the 1986 and the 1954 code are generally the
same
• http://0-
intelliconnect.cch.com.catalog.fcsl.edu/scion/secure/ctx_cslguides_c
harlottelaw_edu_content_php/index.jsp?cpid=WKUS-Legal-
IC#page[1]
4. United States Code
• Internal Revenue Code contained in
Title 26
• 10% of the volumes of the USC are
about TAX
• Highest weight and authority
• http://www.charlottelaw.edu/commu
nity/law-library
5. Joint Committee “Blue Book”
• Joint Committee on Taxation (JCT)
• Post enactment general explanations of the law
• Not legislative history
• Not controlling authority
• They are cited by courts with respect
• Good place for legislative intent that you do not gain from
legislative history
• https://www.jct.gov/
6. The Process
• HR originates tax bill
• Ways and Means Committee has subject jurisdiction over federal
tax legislation
• Work on the bill- subcommittee of Ways and Means
• After markup it is reported out to the full House
• Pass- sent to Senate
• Referred to the Senate Finance Committee ( they can create
their own version)
• After markup reported to full Senate
• Pass but material difference between the bill goes to a
conference committee to reconcile the difference
• If both Chambers past the reconciled bill from committee sent
to the president
7. Legislative History
• House, Senate and Conference
reports have the most weight
• Blue Book?
• JCT offers assistance in the bill writing
process ( great source for intent)
• Made up of members of both Ways
and Means and the Finance
Committee
8. Legislative History
• If the Code language is unclear
• no reg. or case to clarify
• USCCAN, Congressional Record, Statutes at Large
• Cumulative Bulletin
http://encore.fcsl.edu/iii/encore_chasl/record/C__Rb247668__SCumulative
%20Bulletin__P0%2C3__Orightresult__X5?lang=eng&suite=chasl
• Internal Revenue bulletin
• http://apps.irs.gov/app/picklist/list/internalRevenueBulletins.html
• CCH
• http://0-
intelliconnect.cch.com.catalog.fcsl.edu/scion/secure/ctx_cslguides_charlott
elaw_edu_content_php/index.jsp?cpid=WKUS-Legal-IC#page[1]
• RIA
http://encore.fcsl.edu/iii/encore_chasl/record/C__Rb898903__SRIA__P0%2
C2__Orightresult__X5?lang=eng&suite=chasl
• Treatises
9. Regulations 2nd weight
• Treasury Department granted power via statute to interpret and administer the Code. IRS is
a division of the Treasury Department and handle the daily operation.
• Administrative pronouncements interpret or enforce tax statutes
• Regulations, Revenue rulings, Revenue procedures, Letter ruling
http://0-
intelliconnect.cch.com.catalog.fcsl.edu/scion/secure/ctx_cslguides_charlottelaw_edu_content_p
hp/index.jsp?cpid=WKUS-Legal-IC#page[2]
http://www.legalbitstream.com/
• TD issue two types of Reg.
• Legislative regulation
• Interpretive regulations (can be challenged)
• Issued proposed form, comment period, then issued final form
• Proposed regulation- no judicial deference
• Located in the CFR and FR
• http://www.irs.gov/Tax-Professionals/Tax-Code,-Regulations-and-Official-Guidance
11. U.S. Tax Court
• Prior to 1943 called the Board of Tax Appeals
• Handles only tax cases
• Heard by a single Judge and opinion reviewed by Chief Judge
• Chief Judge can refer to full court review
• no Jury trial in Tax Court or U.S. Claims
• Taxpayers disputing tax liability do not pay before trial but if
they lose they must pay interest
• Decisions of the tax court appealed to U.S. Court of Appeals
• Small cases division disputes $50,000 or less
• Taxpayer can pay and claim refund, if denied, they file suit in
US District Court of U.S. Claims Court
• Decisions appealed to U.S. Court of Appeals
12. Judicial Opinions- 3rd weight
• Tax court issues three types of opinions
http://ustaxcourt.gov/
• Memorandum Decisions (large number)
• Situation is disputed not interpreting the
code is not official reported
• Regular Decisions
• Dispute interpreting the Code or points never
litigated
• Decisions of Small Cases Decision
• Summary opinions not officially reported or
precedent
http://www.legalbitstream.com/
13. Opinions: Official - Unofficial
Sources
• Official
• US Tax Court Opinions
• Reports of the United States Board of Tax Appeals
• Unofficial
Tax Court Memorandum Decisions (CCH)
Tax Court Reporter (CCH)
US Tax Cases Advance Sheets (CCH)
United States Tax Cases(CCH)
American Federal Tax Reports (RIA)
Tax Court Reported Decisions(RIA)
• Tip: cases designated Taxpayer v. Commissioner = Tax Court
• Taxpayer v. United States= District Court or Claims Court
http://cslguides.charlottelaw.edu/content.php?pid=119534&sid=10
29601
14. Action on Decisions
• If IRS loses a case it issues a legal memorandum (Actions on
Decisions)
• Print reporters, Cumulative Bulletin, Tax Court website, CCH
and RIA
• Chart Cheat Sheet
15. IRS
• Guidance to the people
• Revenue Rulings- how IRS will treat a
transaction applying the law to the facts
• Revenue Procedures – public guidance on
procedural rules
• Notices and Announcements – guidance
on matters IRS deem important
16. IRS Pamphlets/ Publications
• Internal Revenue Bulletin- weekly: rulings
and procedures by IRS and other docs
• Cumulative Bulletin- issued twice a year
• Announcements, congressional
committee reports, court opinions,
delegation orders, executive orders,
notices, proposed regulations, public
laws, revenue procedures, revenue
rulings and treasury decisions
17. Guidance from Office of Chief Counsel
• Private Letter Ruling- Issued upon request address
how IRS would treat a particular transaction
• Determination letters- written statement applies tax
law principles and precedents to set facts
• Information letter – calls attention to well
established principle of tax law
• Technical Advice Memorandum- advice provided on
cases being examined but not litigated
20. RIA United States Tax Reporter
• RIA Print and online
•Code, legislative history, Treasury
regulations , Judicial Opinions,
Revenue Rulings, Revenue
Procedures, RIA Explanations
• https://a.next.westlaw.com/Browse/Home/SecondarySources
/TaxSecondarySources/ResearchInstituteofAmericaRIA?transiti
onType=Default&contextData=(sc.Default)
21. RIA Federal Tax Coordinator
• Organized by topic
• Income, gift , estate and excise tax
• Presents issues and analysis supported
by code, reg. and opinions
• https://a.next.westlaw.com/Browse/Home
/SecondarySources/TaxSecondarySources/
ResearchInstituteofAmericaRIA/FederalTax
ationRIA/FederalTaxCoordinator2dRIA?tra
nsitionType=Default&contextData=%28sc.
Default%29
22. Bloomberg BNA Tax
Management Portfolio’s
• Print and (Online fall2014)
• Three series
• U.S. Income
• Estate, gift and trust
• Foreign Income
Broken down by topic in the series. Provide
analysis, working papers - experts, bibliography
and references
http://encore.fcsl.edu/iii/encore_chasl/record/C_
_Rb490652__Stax%20portfolios__P0%2C1__Orig
htresult__X2;jsessionid=963B0645CFF48A9B9770
596337EF2528?lang=eng&suite=chasl
23. Master Tax Guide
• CCH product
• published annually
• Code sections by topic
• Citations to CCH tax treatises for further
information.
• Some case and IRS citations
• http://0-
intelliconnect.cch.com.catalog.fcsl.edu/scion/secure/ctx_cslgu
ides_charlottelaw_edu_content_php/index.jsp?cpid=WKUS-
Legal-IC#page[2]
25. Current Awareness
• Law Reviews and Journals
• BNA daily tax report
• BNA electronic commerce and law report
• Tax analyst tax report (Tax Notes) (lexis)
http://cslguides.charlottelaw.edu/content.php?pid=
571378&sid=4711610#17360557
• Tax forums - Event IRS sponsors 6 each year
• Taxtalk Today- IRS host each month online for free
• How to handle a tax controversy at the restructured
IRS and in court
• Annually (ALI ABA )
26. Databases
• Westlaw
• Classic: Add a tab (July1)
• Next: Topic- Tax
• Lexis Advanced
• Bloomberglaw – Practice Center –Tax (CSL Fall 2014)
• Fastcase-Codes and Regs (NC Bar membership)
• Proquest- Legislative history, regulations and committee
• RIA – resources through Westlaw
• CCH – Tax Database
• Hein-Historical
Websites
IRS Website
Joint Committee on Taxation
LegalBitStream
Tax Court
Regulations.gov