On June 21, 2018, in South Dakota v. Wayfair, Inc., ET Al (No. 17-494), the Supreme Court of the United States held that physical presence is no longer required to subject out-of-state sellers to a state’s sales tax laws. The Court’s decision in Wayfair overruled prior Supreme Court decisions in Quill Corp. v. North Dakota, […]

The 2017 Tax Cuts and Jobs Act created a new federal tax deduction for individual taxpayers of up to 20% of “qualified business income” realized by a partnership, S corporation or a sole proprietorship. While a number of limitations apply, this deduction has the potential to reduce the effective tax rate on such income by […]

Although most taxpayers would never consider relinquishing their U.S. citizenship or surrendering their status as U.S. permanent residents (i.e. expatriate), a certain minority of taxpayers in fact do so. As reported by Bloomberg, expatriation from the U.S. has been on the upswing since 2010 and a record 2,367 people relinquished their U.S. citizenship in the […]

In a recent decision, the United States Court of Appeals for the Sixth Circuit in Summa Holdings, Inc. v. Comm’r, 2017-1 U.S.T.C ¶50,155, (February 16, 2017) reversed the holding of the Tax Court, 109 TCM 1612 confirming the legitimacy of the strategy of using a Domestic International Sales Corporation (DISC) as a vehicle to fund […]