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…

The House Ways and Means Committee released additional information regarding their proposed tax bill, named “The One, Big, Beautiful Bill”, which includes needed modifications to the requirement that research and experimental (“R&E”) expenditures be capitalized. While domestic R&E expenditures were provided relief, no favorable adjustments were provided to foreign R&E. The House bill provides domestic R&E can be fully deductible for expenditures paid or incurred in taxable year beginning after December, 31, 2024. However, the ability to immediately expense R&E capitalized assets for taxable years beginning after December 31, 2021 and before January 1, 2024 is not provided . In…

The Child Tax Credit (CTC) delivers substantial benefits to families with children—but the credit’s design means that 17 million children (about 1 in 4) live in families who miss out on the full CTC benefit because the parents—most of whom work—do not earn enough. At the end of this year, along with a host of other Tax Cuts and Jobs Act of 2017 (TCJA) individual income tax changes scheduled to expire, the maximum credit will fall from $2,000 per child to $1,000 per child under age 17. Congress could extend the $2,000 benefit and other aspects of the current CTC…

To read this article with full citations, please visit taxnotes.com President Trump’s musings about Harvard University possibly losing its tax-exempt status for failing to adhere to public policy crystallized May 2 into what appears to be an actual plan to revoke the school’s exemption. The move highlights a long-standing problem that the IRS and Congress should have remedied long ago. For more than five decades the IRS has effectively dangled the threat of revocation over the heads of tax-exempt entities like the proverbial sword of Damocles, claiming extremely broad authority to revoke their status. The IRS has apparently never disclaimed…

According to a new Tax Policy Center analysis, the House Republicans’ March 9 draft of a major 2025 revenue bill would cut taxes on average by about $2,800 in 2026, compared to what households would pay if the individual and some business provisions of the Tax Cuts and Jobs Act (TCJA) expire or become less generous as scheduled at the end of this year. TPC analyzed a preliminary, incomplete draft of the tax portion of what will become the year’s major budget bill. It found that, on average, all income groups would benefit from the tax proposals. However, more than…

The U.S. and China have reached an agreement to stave off their unusually high import tariffs on each other’s countries. Stock markets have positively responded to the news. While the reduction in tariffs likely diminishes the direct impacts on companies, the greatest positive effect leading to the stock market rise may be on the lower uncertainty that these companies now face as they head into the next phase of this ongoing trade war. On May 11, 2025, President Donald Trump announced on X via The White House account that a trade deal with China had been reached. While the details…

Artificial intelligence tools such as ChatGPT and Grok are becoming household fixtures with Americans increasingly turning to them. These tools are being used to find answers on everything from cooking recipes to complicated tax questions. How reliable is AI for taxpayers seeking tax advice, particularly on U.S. international tax issues? While AI has laudable capabilities and provides great speed in its responses, the reality is that currently in the U.S. international tax area (indeed, in the tax area generally), AI often delivers inaccurate or incomplete information. Since U.S. international taxation is such a highly specialized field, AI can leave users…

When I was younger, I spent an entire summer with my great-grandmother (who famously–and presciently–told me that I sounded just like a Philadelphia lawyer). Her house was in Greenville, S.C., a town my 12-year-old self would have described as a bit sleepy. What a difference a few decades make. This year, that Greenville made Forbes’ list of Best Places To Retire alongside 24 other cities like Athens, Georgia, and Apache Junction, Arizona. To assemble the list, Forbes compared more than 950 locales in America with populations above 10,000 on everything from housing costs to healthcare, air quality, crime and climate…

Once again, the most popular names for babies born in the United States are Liam and Olivia—2024 marks the sixth consecutive year both names topped the lists. The second most popular names, Emma and Noah, also didn’t budge. The rankings are measured by the Social Security Administration (SSA) data based on applications for Social Security cards. According to agency data, Social Security numbers were recorded for 3,612,777 new babies, with male births (1,845,330) edging out female births (1,767,447) in 2024. That reflects an increase over 2023, which recorded 3,595,309 new babies. It reverses—just slightly—a trend of fewer births in the…

It is reported that Trump seeks to pay for his proposed tax cuts by increasing the top tax rate on individuals from 37% to 39.6%. This article provides an overview of his proposal as well as 3 important considerations for this 2.6% tax rate increase on the top income individuals. Overview The current top tax rate for individuals is 37%. In 2025, this tax rate applies to single individuals with income over $626,350 and married individuals with income over $751,600. While cutting taxes has been a long-standing part of Trump’s platform, his recent social media post on Truth Social suggests…

Recent academic research explores a United Kingdom reform mandating large companies to disclose reports on tax strategy. The study finds that while the mandate leads to more disclosure, it does not increase overall tax transparency. It concludes that the enhanced tax disclosure requirements may not positively affect tax disclosures as intended. Beginning in 2025, Accounting Standards Update (ASU) 2023-09, titled Income Taxes Improvements to Income Tax Disclosures, will radically change the information public companies must publicly disclose in their financial statements. The main provisions in this standard update require affected companies to provide more detailed income tax rate reconciliations, disclose…