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26 Oct 2020, 3:40 am
Chiu v Chiu is the leading appellate case for that proposition. [read post]
3 Aug 2012, 6:30 am
Some readers noted flaws in my analysis. [read post]
13 Sep 2013, 1:31 pm
Wal-Mart including an analysis of the Supreme Court’s decisions in Amgen Inc. v. [read post]
4 Jun 2013, 8:45 am
Wal-Mart including an analysis of the Supreme Court’s decisions in Amgen Inc. v. [read post]
11 Jul 2012, 9:57 pm
As with the taxing power analysis by the Chief in the health care case, the bailout analysis in NAMUDNO was a total surprise. [read post]
15 Mar 2007, 6:33 am
Grable punched a little hole in that reasoning.Grable involved a state-law quiet title action that turned on whether a federal agency (the IRS) had failed to carry out its responsibilities under federal law (to provide adequate notice before seizing the property of a tax delinquent). [read post]
18 Dec 2019, 3:30 pm
Court of Appeals for the Fifth Circuit would decide Texas v. [read post]
22 Apr 2019, 4:53 pm
The public statement references both a published framework of analysis by FinHub and a response to a no-action request by the Division of Corporation Finance. [read post]
4 Jul 2024, 9:05 pm
The Internal Revenue Service (IRS) and the U.S. [read post]
19 Nov 2011, 8:40 pm
/sameness of pool of money, determines nondbtr's rts to sue 3d parties. http://t.co/q4zVrh8 B-PA: Absent express lang. in stip, funds escrowed in adeq prot stip for taxes aren't in trust for sec cr or tax body. [read post]
26 May 2013, 1:33 pm
Because the character of these and other arrangements often depends not only on the label applied, but also on both the structure of the product and the manner in which it is used, deployed and administered in conjunction with other elements of the health and cafeteria plans offered by an employer, this analysis should include both a detailed review of the particular product itself and a holistic analysis of the manner in which it will be used on the overall health and other… [read post]
6 Nov 2014, 10:59 am
The IRS decided that it does, and the Fourth Circuit agreed. [read post]
2 May 2018, 2:59 pm
Camp’s article Theory and Practice in Tax Administration is cited in the following article: Andrea Monroe, Hidden in Plain Sight: IRS Publications and A New Path to Tax Reform, 21 Fla. [read post]
26 Dec 2014, 11:38 am
”) Sections 12598 through 12599.7; Holt v. [read post]
26 Dec 2014, 11:38 am
”) Sections 12598 through 12599.7; Holt v. [read post]
26 Dec 2014, 11:38 am
”) Sections 12598 through 12599.7; Holt v. [read post]
3 Aug 2015, 12:07 pm
Since violation of these out-of-pocket maximums (as well as many other federal health benefit rules) can trigger an obligation for the employer to self-assess, self-report by filing a Form IRS Form 8928, and pay excise taxes of up to $100 per day, as well as expose the plan and its fiduciaries to ERISA lawsuits from covered persons, the Department of Labor or both, insurers and administrators also should review their group health plan provisions and their administration in… [read post]
21 Dec 2014, 4:17 am
United States In Ratzlaf v. [read post]
9 May 2018, 9:40 am
Court of Appeals for the 8th Circuit refused below to defer to IRS regulations providing that lost wages are taxable “compensation” under the RRTA. [read post]
