Taxes

The IRS has assessed $4 billion in taxes, penalties, and interest on Yum! Brands. The issue stems from a tax-deferred reorganization in 2014. Yum! Brands is now suing to prevent the IRS from collecting these funds. M&A is often among the most complicated tax issues large corporations face, which can often lead to uncertainty and scrutiny from the IRS. In this article, I discuss the Yum! Brand corporation, what happened in 2014, and why they are facing such a steep tax penalty now over a decade later. What Is The Yum! Brands Corporation? Yum! Brands is the parent company of…

Three Georgia residents have been sentenced for their involvement in a scheme to defraud the Georgia Department of Labor (GaDOL) out of tens of millions of dollars in benefits meant to assist unemployed individuals during the pandemic. Macovian Doston, 31, of Vienna, Georgia, has been sentenced to 15 years in prison, followed by three years of supervised release, and ordered to pay restitution. Shatara Hubbard, 36, of Warner Robins, Georgia, has been sentenced to 6 years in prison, followed by three years of supervised release, and ordered to pay restitution. Torella Wynn, 33, of Cordele, Georgia, has been sentenced to…

Imagine a reconstruction fund so tax-preferred it makes municipal bonds look like a comparative raw deal—that’s what the United States-Ukraine Reconstruction Investment Fund may have just created. The fund, formally established through an agreement between the U.S. and Ukraine in April, is structured as a limited partnership between two state-backed agencies: the U.S. International Development Finance Corporation (IDFC) and Ukraine’s Agency on Support Public-Private Partnership (PPP). The purported ambition is the reconstruction and rebuilding of Ukraine post-Russian invasion—with a strong preference towards a steady infusion of international capital. The fiscal kicker is that all income flowing into, within, and out…

The IRS wants you to “disclose” if you do not have at least ‘‘substantial authority’’ for your tax position. Disclosure is more than the usual listing of income or expense. It is simply an extra explanation. How much extra varies considerably, not only in legal requirements but also in practice. Sometimes, the IRS says disclosure is required. You might be claiming legal expenses for a fight with your siblings over an heirloom. Or you might be claiming that you had an ordinary loss rather than a capital one when stock became worthless. When To Disclose There are almost infinite circumstances…

Tucked among the trillions of tax cuts in the House’s just-passed “big, beautiful bill” is the repeal of the tax on indoor tanning services. But before you rush to book a tanning bed appointment, remember that the Senate still has to act on this bill and that dermatologists are no fans of tanning. About The Tax The tanning tax, a 10% excise tax on indoor tanning services, dates back to 2010. It was part of the Patient Protection and Affordable Care Act—better known as Obamacare. When Congress wants to find money to pay for things that matter to them—like healthcare…

The U.S. House of Representatives just passed H.R. 1, the “One Big Beautiful Bill Act” by a narrow margin, with the vote being 215 to 214. Foreign persons (including foreign governments) considering inbound investments should pay close watch as this develops. The OBBBA has many tax provisions, but one (Section 112029 of the OBBBA) would create a powerful new retaliatory tax by adding a new Section 899 to the Internal Revenue Code. Section 899 as proposed in H.R. 1, titled “Enforcement of Remedies Against Unfair Foreign Taxes” is aimed at foreign jurisdictions that impose certain discriminatory or extraterritorial taxes on…

House Republicans passed their “One Big Beautiful Bill Act” early Thursday morning in defiance of several warnings that it would have big negative consequences for the United States. The “biggest” thing about the bill (beyond its 1,118-page length) is the more than $3 trillion that the Committee for a Responsible Federal Budget estimates it would add to budget deficits over the next decade. That figure would swell to more than $5 trillion if the nominally temporary policies within it are made permanent, as leading Republicans have made clear they intend. No matter which measurement is used, this bill would be…

It turns out that all of those “no” votes in committee didn’t amount to much once the tax bill hit the House floor on Thursday morning. House Republicans passed the “big, beautiful tax bill” with a 215-214 vote. Only two Republicans, Warren Davidson (Ohio) and Thomas Massie (Ky.) voted “no” on the grounds that the bill would add significantly to federal deficits—two others, Andrew Garbarino (N.Y. and David Schweikert (Ariz.) didn’t vote, while Andy Harris (Md.) voted “present.” The tax portion of the bill before any changes were made, would cost $3.7 trillion over the next decade, according to the…

By the thinnest of margins (215 to 214), the House of Representatives has voted to pass Trump’s domestic policy bill. According to Forbes, the ‘Big Beautiful Bill’ act has trillions of dollars of impact on US taxpayers, including renewing the tax cuts from the Tax Cuts and Jobs Act of 2017, a deduction for income earned from tips, and increased deductions for state and local income taxation, and much more. However, the bill proposes to pay for these tax cuts by limiting the benefits from social services programs like Medicaid, food stamps, and student loan payment plans. In this article,…

In a surprise move, the Senate passed the No Tax on Tips Act. The vote was unanimous. The bill was originally introduced by Sen. Ted Cruz (R-Texas) to little fanfare. However, on May 20, Sen. Jacky Rosen (D-Nev.), one of seven cosponsors of the bipartisan bill, brought it to the Senate floor, where it passed by unanimous consent. Unanimous consent is a procedural tool that is exactly what it sounds like—it requires the unanimous agreement of all Senators. You don’t typically see it used in tax bills, as it’s generally used for noncontroversial resolutions and simple requests, neither of which…

The frustration on Senator Ron Wyden’s (D-Ore.) face was clear. The Ranking Member of the U.S. Senate Committee on Finance expressed his concerns about the nomination of Billy Long, a former Republican congressman, to be IRS Commissioner. At the hearing on May 20, Wyden pulled no punches about Long, saying, “Congressman Long’s experience with tax issues came after he left Congress, when he dove headlong into the tax scam industry.” Long does not have any formal training in tax, law, or accounting, does not have a college degree, and never served in Congress on a tax writing committee. He dropped…