UPDATE – In its Action on Decision (AOD 2023-01, 2023-10 IRB 502), the Internal Revenue Service (“IRS”) announced its acquiescence to the holding of the Fifth Circuit in Trafigura Trading LLC v. United States, No. 21-20127, 29 F.4th 286 (5th Cir. 2022), i.e., that Internal Revenue Code (“IRC”) Section 4611(b)(1)(A) imposes a tax on
Internal Revenue Code
When to Challenge the Denial of an Interest Expense Deduction in Louisiana
By Jaye Calhoun, Sean McLaughlin & William Kolarik on
Posted in State and Local Taxation
Louisiana Department of Revenue income tax auditors are increasingly proposing large assessments by misapplying a formula in a Department regulation (La. Admin. Code 61:I.1130(B); the “Regulation”). The Regulation is based on a statute designed to prevent deductions related to allocable and nontaxable income and contains a formula that purports to determine a percentage of a…
Deadlines Extended for Like Kind Exchanges and Qualified Opportunity Zone Investments
By Angela Adolph on
Posted in COVID-19, State and Local Taxation
Under Section 1031 of the Internal Revenue Code, a taxpayer may sell real property (the relinquished property) and replace it with real property of a like-kind (the replacement property) without recognizing tax on the sale if certain requirements are met. Two of those requirements involve deadlines: the taxpayer must identify replacement property within 45 days…
Employer Provided Assistance for Employees Affected by the 2016 Flood
By Kean Miller on
Many employers have a number of employees who were affected by the August 2016 flooding event in Louisiana. These employers are looking for means to assist their employees in recovering from this significant disaster. Employers have a number of options for providing disaster relief assistance to their employees.
A number of employers are simply collecting…