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IRS reveals latest reduction of refundable small business health care tax credit due to sequester

IRS reveals latest reduction of refundable small business health care tax credit due to sequester

On its website, IRS has revealed that small tax-exempt employers claiming the refundable portion of the small business health care tax credit under Code Sec. 45R will see a 6.8% reduction in the amount of their refund payments. The reduction is a required “sequestration” spending cut under the Balanced Budget and Emergency Deficit Reduction Act […]

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Corporation’s untimely refund claim not saved by informal refund or waiver doctrines

Corporation’s untimely refund claim not saved by informal refund or waiver doctrines

Chief Counsel Advice 201540012 In Chief Counsel Advice (CCA), IRS has determined that a corporation’s refund claim stemming from foreign tax credits (FTCs) was untimely under Code Sec. 6511(d)(3)(A), where it was filed more than 10 years after the return for that year was originally due. IRS further concluded that the corporation failed to satisfy […]

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IRS request comments on property qualifying for the Sec. 48 energy credit

IRS request comments on property qualifying for the Sec. 48 energy credit

Notice 2015-70, 2015-42 IRB In a Notice, IRS has requested comments on issues that should be addressed in proposed regs on the definition of certain types of property under Code Sec. 48.Comments must be received by Feb. 16, 2016. Background.For purposes of computing the investment credit under Code Sec. 46, Code Sec. 48(a)(1) provides, in part, […]

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U.S. court rejects AIG, Bank of NY Mellon tax credit appeals

U.S. court rejects AIG, Bank of NY Mellon tax credit appeals

NEW YORK (Reuters) – A U.S. appeals court on Wednesday rejected efforts by American International Group Inc and Bank of New York Mellon Corp to recoup hundreds of millions of dollars of foreign tax credits that the Internal Revenue Service did not allow. By a 3-0 vote, the 2nd U.S. Circuit Court of Appeals in New York […]

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IRS clarifies timing of income tax effects of retroactive extension of fuel tax credits

IRS clarifies timing of income tax effects of retroactive extension of fuel tax credits

Notice 2015-56, 2015-35 IRB In a Notice, IRS has provided that the required income tax addback for the credits for biodiesel fuel blenders and for certain sales or uses of alternative fuels, that were earned as a result of the retroactive extension of those credits by the Tax Increase Prevention Act of 2014 (the Act), […]

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Tax Court had no jurisdiction to credit taxpayer’s claimed overpayment

Tax Court had no jurisdiction to credit taxpayer’s claimed overpayment

Del-Co Western, TC Memo 2015-142 The Tax Court has ruled that, in a case brought by a taxpayer for review of an IRS collection due process (CDP) hearing, it did not have jurisdiction to credit an overpayment that taxpayer alleged it had made because that overpayment was not an “available credit.”  Click here for the […]

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Passthrough of rehab credit to lessee results in lessee income equal to 100% of credit

Passthrough of rehab credit to lessee results in lessee income equal to 100% of credit

Chief Counsel Advice 201505038   In Chief Counsel Advice (CCA), IRS has concluded that where a lessor qualifies for the Code Sec. 47 rehabilitation credit but elects to treat his lessee as qualifying for the credit, the lessee must include in his gross income, over a period of years, 100% of the credit amount, notwithstanding […]

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Court of Appeals Affirms District Court’s Denial Of Research Tax Credits For Funded Contracts

Court of Appeals Affirms District Court’s Denial Of Research Tax Credits For Funded Contracts

Geosyntec Consultants, Inc. (CA 11, 1/29/2015) 115 AFTR 2d ¶ 2015-384   The 11th Circuit, affirming the district court, found that Geosyntec was not eligible for research tax credits for research expenses incurred under two “capped contracts,” because the research was funded by Geosyntec’s clients. Under the contracts, Geosyntec was entitled to payment regardless of […]

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California woos business with tax credits: you can get in on them

California woos business with tax credits: you can get in on them

As reported in the OC Register: Want to grow your business locally? Want to move an out-of-state company to California? You can be paid to do it. Gov. Jerry Brown’s California Competes program has allocated some $200 million in tax credits in fiscal 2016 for companies to expand in or relocate to California. State officials […]

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Payment was dividend, so “withholding tax” rule meant no foreign tax credit

Payment was dividend, so “withholding tax” rule meant no foreign tax credit

Lehman Brothers Holdings, Inc., (DC NY 5/08/2015) 115 AFTR 2d ¶ 2015-731   A district court has ruled that, under the U.S. treaty with the United Kingdom (U.K.), a payment received by a U.S. subsidiary of Lehman Brothers (Lehman) from a U.K. Lehman subsidiary was a dividend. As a result, the Code Sec. 901(k)(1)(A)(ii) “withholding […]

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Effect of TIPA on when qualified facility construction begins for energy credit

Effect of TIPA on when qualified facility construction begins for energy credit

Notice 2015-25, 2015-13 IRB   In a Notice, IRS has updated previous guidance on establishing the beginning of a facility’s construction, to reflect the one-year extension by the Tax Increase Prevention Act of 2014 (TIPA, P.L. 113-295, 12/19/2014) of when construction must begin on a qualified facility to be eligible for the Code Sec. 45 […]

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Tax Benefit Rule Didn’t Apply To Taxpayer’s Refundable State Tax Credits

Tax Benefit Rule Didn’t Apply To Taxpayer’s Refundable State Tax Credits

Maines, (03/11/2015) 144 TC No. 8   The Tax Court has held against a taxpayer who didn’t pay any New York state income tax due to his New York credits exceeding his New York tax liability, also received refundable New York credits, and claimed that the credits were not taxable income because New York referred […]

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IRS Establishes Program That Reallocates Gasification Project Credits

IRS Establishes Program That Reallocates Gasification Project Credits

Notice 2014-81, 2014-52 IRB In a Notice, IRS has established a third phase of the qualifying gasification project program under Code Sec. 48B (“the § Code Sec. 48B Phase III program”) to reallocate the qualifying gasification project credits that are available for allocation after the conclusion of the Code Sec. 48B Phase I program. Background. One […]

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No Homebuyer Credit Because Purchase Was on Execution of Contract, Not on Final Payment

No Homebuyer Credit Because Purchase Was on Execution of Contract, Not on Final Payment

Rose A. Wodack, TC Memo 2014-254   The Tax Court has denied a Code Sec. 36 first-time homebuyer tax credit to an individual who claimed to have purchased a home under a Wisconsin land contract in 2008 (a year during which qualifying purchases were eligible for the credit) when she made final payment under the […]

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IRS Disallows U.S. Parent’s Attempt To Claim FTC For Pre-Acquisition Taxes Paid By CFC

IRS Disallows U.S. Parent’s Attempt To Claim FTC For Pre-Acquisition Taxes Paid By CFC

Chief Counsel Advice 201444039 In Chief Counsel Advice (CCA), IRS concluded that a U.S. parent could not include foreign income taxes of a foreign subsidiary, which were paid after the subsidiary became a controlled foreign corporation (CFC) but accrued prior to that time, in the post-’86 foreign income tax pool of the subsidiary. IRS determined […]

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Bits ‘n Pieces – London mayor is poster boy for expat woes; House approves $42 billion tax break package; Gas tax – time for change?; House approves tax credit for wind energy; Britain and the Google tax

Bits ‘n Pieces – London mayor is poster boy for expat woes; House approves $42 billion tax break package; Gas tax – time for change?; House approves tax credit for wind energy; Britain and the Google tax

* London mayor is poster boy for expat tax woes. By Laura Saunders – The Wall Street Journal. Boris Johnson’s case is a perfect illustration of the dilemmas faced by many of the 7.6 million U.S. citizens living abroad as a result of U.S. authorities’ five-year campaign against secret offshore accounts. Link to The Wall […]

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Additional guidance on when qualified facility construction begins under energy credit

Additional guidance on when qualified facility construction begins under energy credit

Notice 2014-46, 2014-35 IRB In a Notice, IRS has clarified previous guidance providing two methods that taxpayers may use to establish that construction has begun on a qualified facility eligible for the Code Sec. 45 renewable electricity production tax credit. Background. Under Code Sec. 45, a credit for electricity produced from certain renewable resources is […]

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State statute cannot be “determination” for purposes of special needs adoption credit

State statute cannot be “determination” for purposes of special needs adoption credit

Lahmeyer, (DC FL 7/25/2014 ) 114 AFTR 2d ¶ 2014-5108 A district court has ruled that the requirement, for purposes of the Code Sec. 23(a)(3) credit for adopting a special needs child, that a state make a determination that the child is a special needs child, isn’t met by the fact that the child clearly […]

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Bits ‘n Pieces – Leaders reach deal on California movie and TV tax credit; Sales-based tax rates; Thank you points are taxable; Alaska loves Oil; Mississippi franchise tax

Bits ‘n Pieces – Leaders reach deal on California movie and TV tax credit; Sales-based tax rates; Thank you points are taxable; Alaska loves Oil; Mississippi franchise tax

* Governor, legislative leaders reach deal on California movie and TV tax credit. By Ted Johnson – Variety. State lawmakers and Gov. Jerry Brown announced a deal on Wednesday to extend and expand California’s movie and TV tax credit, more than tripling its size to $330 million annually. Link to Variety, bit.ly/1pIC6ap * A solution […]

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IRS closes loophole that allowed inflated foreign tax credits

IRS closes loophole that allowed inflated foreign tax credits

Notice 2014-44, 2014-32 IRB In a notice, IRS has announced that it will be issuing regs to close a loophole which taxpayers were using to avoid a provision that disallowed the foreign tax credit with respect to disposition of acquired property that has a higher basis for U.S. federal income tax purposes than for foreign […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney