The Louisiana Department of Revenue is Disallowing your Legitimate Interest...
One of the most confounding situations faced by corporate taxpayers engaged in a Louisiana income tax audit is the receipt of preliminary workpapers that disallow interest expense deductions with no...
View ArticleThe President Signs The Consolidated Appropriations Act, 2021. Including Tax...
On December 27th, the President signed into law a second pandemic relief package as part of a larger government funding bill passed by Congress entitled The Consolidated Appropriations Act, 2021...
View ArticleKean Miller Wins Important Louisiana Appellate Court Victory Striking Down...
The Louisiana First Circuit Court of Appeal once again recognized the primacy of legislation as a source of law in the state and that the power to tax is reserved to the Legislature alone, not the...
View ArticleLouisiana Department of Revenue Announces A Transfer Pricing Managed Audit...
On October 28, 2021, the Louisiana Department of Revenue (the “Department”) publicly announced a transfer pricing managed audit program in Revenue Information Bulletin No. 21-029 (October 26, 2021)....
View ArticleWhen to Challenge the Denial of an Interest Expense Deduction in Louisiana
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”)....
View ArticleAutomatic Extension of Time for Filing Louisiana Income Tax, Corporate Income...
UPDATE – On January 20, 2023 the Louisiana Department of Revenue revised the proposed regulations. The revisions modify the previous Notice of Intent to amend the regulations relating to the new...
View ArticleSubscription Fees for Personal Electronic Storage Capacity are not Subject to...
On January 12, 2023, the Louisiana Board of Tax Appeals (the “Board”) granted a motion for partial summary judgment in Apple, Inc. v. Samuel, Dkt. No. L01283 (January 12, 2023) and held that the...
View ArticleBusinesses with Louisiana Worker Classification Concerns Should Consider...
UPDATE – On February 15, 2023, the Louisiana Department of Revenue issued Revenue Information Bulletin (“RIB”) No. 23-010 stating that qualifying businesses can submit an application under the Fresh...
View ArticleDOJ’s Decision Not to Appeal the Fifth Circuit’s Decision in Trafigura...
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...
View ArticleLouisiana Tax Developments – The 2023 Regular Legislative Session
Because it was a fiscal session, the Louisiana Legislature enacted a number of key tax changes in the 2023 Regular Session that concluded on June 8, 2023. Below you will find the important substantive...
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