Now showing items 31-40 of 47
Taxation of Series LLCs in Texas: Bigger Isn’t Always Better in the Lone Star State
Texas’s Comptroller of Public Accounts announced a policy concerning the taxation of series LLCs in which all series of a series LLC should be aggregated and treated as a single taxable entity for Texas franchise tax ...
"Uncharitable” Policy for Charities: Use of Disregarded LLCs by I.R.C. § 501(c)(3) Organizations is a Trap for the Unwary in Certain States
This article explains how the imposition of the Texas Franchise Tax on Section 501(c)(3) Charities with subsidiary LLC structures in place arises. The article also discusses why there is no compelling reason for the ...
Understanding the Apportionment of Taxable Capital and Taxable Earned Surplus
This short article discusses how taxable capital and taxable earned surplus are apportioned to Texas.
S Corporation Entitled to Interest on Overpayment at the Federal Short-Term Rate Plus 2%
This article discusses Garwood Irrigation Co., where the Tax Court addressed a situation in which an S corporation had overpaid the Section 1374 corporate-level ‘built-in gains tax‘ and was entitled to recover the overpayment ...
Public Comment Requested on Potential Changes to Certain Distributions Treated as Sales or Exchanges Under Section 751(b)
This article discusses the Treasury Department and IRS recent request for comments on the approaches discussed in Notice 2006-14, 2006-8 IRB 498, in determining a partner's share of hot assets and prescribing the tax ...
Tax Court Memorandum Decision Addresses Back-to-Back Loans
This article discusses Ruckriegel, where the Tax Court addressed (in a memorandum opinion) whether the owners of an S corporation could treat certain advances as loans by them to the S corporation and use those loans to ...
The New Texas Margin Tax—Understanding the Effective Dates and Anticipated Legislative and Comptroller Guidance
The new Texas margin tax significantly changes Texas law, has a combined group reporting requirement, and has different effective dates for calendar year and fiscal year taxpayers.
Educational, Public Charity, and Federal Income Tax Exempt Organizations May Be Exempt from the Franchise Tax
Many types of organizations are eligible for a franchise tax exemption, but they must follow the Texas Administrative Code procedures to receive the exemption.
Understanding the Use Tax
The Texas use tax applies to items store, used, or otherwise consumed in Texas.
Understanding the Sales and Use Tax Exemption for Religious, Education and Public Service Organizations
Certain religious, educational, and public service organizations may obtain a sales and use tax exemption by submitting a written application to the Texas Comptroller of Public Accounts. Organizations that are automatically ...