Andrew Gradman of the Law Office of Andrew L. Gradman, and Abraham Finberg and Rachel Wright of AB FinWright LLP argue that new final regulations—stating that tax code Section 471(c) cannot be used to capitalize non-deductible amounts—are subject to challenge by cannabis taxpayers.
With cannabis clients, normal tax planning is reversed: the goal is to capitalize as many costs as possible, rather than to seek deductions.
Until recently, Section 280E's exception for capitalized basis was more useful to some cannabis companies than to others. Under Section 471(a) , retailers and distributors could not capitalize costs as aggressively as producers. However, Congress seemed to expand this exception in 2017, when it added Section 471(c) as part of the TCJA .
And here's another article:
Opinion: Why a carbon tax might be best for the oil industry, consumers and the climate -
The oil industry's lobbying arm, the American Petroleum Institute, suggested in a new draft statement that it might support Congress putting a price on carbon emissions to combat climate change, even though oil and gas are major sources of those greenhouse-gas emissions.
An industry calling for a tax on the use of its products sounds as bizarre as "man bites dog." Yet, there's a reason for the oil industry to consider that shift.
* * *
With the election of President Joe Biden and rising public concern about climate change, Washington seems increasingly likely to act to reduce greenhouse gas emissions. The industry and many economists and regulatory experts, ourselves included , believe it would be better for the oil industry—and for consumers—if that action were taxation rather than regulation.
New COVID-19 Stimulus Bill Pension Reforms and Expands Scope of 162m Compensation
Today, the House of Representatives passed the $1.9 trillion American Rescue Plan Act of 2021 (the "ARPA"). The ARPA has already been approved by the Senate and is expected to be quickly signed into law by President Biden.
The multiemployer pension system in the United States is currently in crisis, with over 100 multiemployer pension plans, covering more than one million participants in total, projected to become insolvent within the next 10 to 20 years. The largest and most significant of these plans, the Central States, Southeast and Southwest Areas Pension Fund (the "CSPF"), is projected to become insolvent by 2025.
Opinion: Democrats to States: No New Tax Cuts - WSJ
Democrats in Congress aren't satisfied with spending $1.9 trillion to help blue states and union friends. They've also launched a sneak attack against conservative states. Read their legislation's lips: No new state tax cuts.
Much of the relief will invariably flow to government union pension funds, which are underfunded in states like Illinois, New Jersey and Connecticut. To inoculate themselves from GOP attacks, Democrats specified in the bill that relief funds may not be used "for deposit into any pension fund." But money is fungible. States can pay out of their general funds for pensions and use the federal cash for something else.
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Colorado business community asks legislature for a timeout on new regulations and higher taxes
A coalition of business groups pleaded with Colorado lawmakers Tuesday to avoid passing any legislation, however well-intentioned, that would make it more complicated or costly to do business in the state.
“We need our state leaders to simply allow businesses to get back on their feet at this time. That is the only path back to economic recovery,” said Loren Furman, chief lobbyist with the Colorado Chamber of Commerce, which hosted the news conference on Zoom.
When Is A Tax Return "Filed"? - Tax - United States
In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency guidelines on notice of being subject to IRS scrutiny. By becoming bona fide residents of the USVI, these taxpayers were able to convert U.S.
Under the Internal Revenue Code in effect during the pre-2005 years, a U.S. citizen who was a "bona fide resident of the Virgin Islands at the close of the taxable year" was not required to report his gross income on a U.S. federal tax return, as long as he fully reported such income on a USVI tax return 1 and paid any taxes due to the U.S. Virgin Islands' Bureau of Internal Revenue (VIBIR). SeeI.R.C. § 932(c) (2004). U.S.
Massachusetts DOR Report Endorses SALT Cap Workaround - Lexology
Biden announces nominees for key Treasury positions | TheHill
"They have devoted their careers to the work of strengthening the American economy and have done it with integrity," Yellen said. "Given their extensive qualifications, I look forward to their confirmations."
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