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TAX COURT ROUNDUP – OCTOBER 2023

The latest Federal Tax Court news, updates, and hot topics!

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CURRENT EDITION

State Tax Planning with the “80/20 Company” Exclusion

Many multinational groups find that foreign-source dividends and other income earned by domestic affiliates are fully or partially subject to state income taxation, even where the federal system provides an exemption. This state-level “leakage” can be material – particularly in high-tax jurisdictions – and is often overlooked because the income appears sheltered at the federal level. For groups with predominantly foreign operations, a starting structure or a restructuring that causes one or more domestic affiliates to qualify as an “80/20 company” can substantially reduce or eliminate state taxation on that income.

Real World Ethics: What Happens When a Judge Doesn’t Understand Tax Law

We all know how messy tax returns can get when couples who used to file jointly divorce and there are children (and tax credits) involved. It’s often difficult to explain the rules surrounding Head of Household filing status and the various tax credits available to parent-clients who have separated or divorced. But what happens when the clients misunderstand and decide to fight about it in family or divorce court? The following case study says “nothing good” can be a horrifying and frustrating answer to this question.

Explore Our Free Articles

Get a taste of our comprehensive tax planning insights with four featured articles, free for everyone.

2026 Summer Education Series Event Calendar

Think Outside the Tax Box is thrilled to bring you the 2026 Summer Education Series, sponsored by Sandy Bay! The fifth installment of this beloved annual series, we will be bringing our loyal subscribers monthly webinars featuring some of the brightest minds in tax all summer long. Each webinar will

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Contracts, Signing Bonuses, and the Substantial Presence Test

In tighter job markets, recruits are often offered signing bonuses (and sometimes moving expenses) to join a firm. Sometimes construction workers temporarily relocate to jobs in other states while they are employed by the company that hired them in their home state. This article reviews some of the foundational tax

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Exclusive Webinars for Our Subscribers

As an annual subscriber, you gain complimentary access to our series of expert-led webinars. Each session is designed to provide you with insights, skills, and knowledge to excel in your field. Discover what’s coming up and secure your spot today.

Inventory Expensing and The Cash Method: Changes from the TCJA

Join Lucien P. Gauthier as we discuss these two changes made by the TCJA in depth.​

Taking the Mystery Out of Revised Energy Credits for Individuals

Learn valuable tips to help your clients claim the new residential energy and electric vehicle credits.

Tax Season 911

Your preparedness plan to create tax savings and survive the busiest of times without falling into old habits!

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Featured Authors

Amber Gray-Fenner is an Enrolled Agent and tax practitioner specializing in tax returns, planning, and representation for individuals and small businesses. She owns Tax Therapy, LLC in Albuquerque, New Mexico.

Matt Metras, EA, owns MDM Financial Services in NY, specializing in bookkeeping and taxation for cryptocurrency clients. He’s an educator on cryptocurrency taxation and actively engages in community advocacy.

Jeff Stimpson, has been a tax and finance writer for 25 years. Hee contributes to publications like Accounting Today and Financial Advisor. His other credits include sales tax, technology, and practice management, residing in New York.

Annette Nellen is a professor and tax program director at San José State University, with extensive involvement in tax organizations and a focus on tax policy, cryptocurrency, and education.

Peter J Reilly graduated from the College of the Holy Cross, worked in CPA firms like Joseph B Cohan and Associates and CCR LLP, and now runs a tax practice while writing for Forbes.com.

Thomas Gorczynski, EA USTCP CTP, is a tax expert known for speaking and educating on federal tax law. He’s editor-in-chief of EA Journal, co-author of the PassKey Learning Systems EA Review Series, and runs a tax practice in Phoenix, Arizona.

Hear From Our Satisfied Users

Quotes from users who have benefited from Tax Law Pro, highlighting how it has helped them in their tax planning and compliance efforts.

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Think Outside the Tax Box provides tax reduction strategies along with practical
implementation advice in order to reduce your clients’ federal tax bill with ease.

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