In late August, the European Commission ruled that Ireland must collect $14.5 billion in back taxes from Apple. The antitrust regulator for the European Union claimed that Ireland had given Apple an extremely favorable tax arrangement for over ten years…
In the last few years, the State of New York has attempted to make major reforms to the state’s corporate income tax system. In the spring of 2014, Governor Cuomo signed into law the state’s annual budget which contained many…
Not knowing the details of a business transaction sounds preposterous on its face, especially when the ignorant taxpayer is the party which formulated the transaction. In the case of Makric Enterprises, Inc. v. Commissioner, TC Memo 2016-44, a failure to make…