Trade Bloc Asks 10th Circ. To Nix Liberty Global's $109M Loss
To preserve the stability of federal tax law, the Tenth Circuit should reverse a lower court's finding that it needn't determine the economic substance doctrine is relevant before disallowing a transaction's tax benefits, the National Foreign Trade Council said Monday, supporting telecommunications firm Liberty Global.
IRS Urged To Drop Investment Advisers From Donor Rules
The IRS should change regulations on donor-advised funds so that personal investment advisers wouldn't be considered donor-advisers, stakeholders told the agency at a hearing Monday, saying failure to do so could chill charitable giving and would exceed regulatory authority.
Man's FBAR Filing Makes Challenge Moot, 7th Circ. Says
The Seventh Circuit upheld Monday the dismissal of a man's challenge to the constitutionality of filing reports of foreign accounts because after filing the suit, the man reported his bank account, making the case moot.
Federal More
The Eighth Circuit declined Monday to revive an engineering company's bid for research tax credits for its work on several building projects, finding the credits are limited to endeavors where funding is conti... (more story)
A Missouri certified public accountant accused of operating a charitable trust scheme that cost the government $8 million in tax was permanently barred from marketing tax arrangements involving charitable rema... (more story)
Accounting and advisory firm Marcum LLP acquired Detroit-based Croskey Lanni PC, adding six partners and more than 50 associates, Marcum announced Monday.
Clifford Chance continued its recent aggressive expansion by growing its Houston and New York offices with two attorneys specializing in energy, taxation and mergers and acquisitions, bringing the firm's later... (more story)
Trump Media and Technology Group Corp. has hired a new auditor, replacing its predecessor firm, which was permanently suspended by securities regulators Friday for alleged "massive fraud" regarding its work wi... (more story)
The IRS is seeking more information on fine-tuning a test in proposed rules on the stock buyback tax meant to assess whether the principal purpose of a U.S. subsidiary's funding purchase of its foreign parent'... (more story)
Gannett Co. can't escape a defamation case accusing it of writing misleading articles saying Ryan LLC, a tax services and technology firm, engaged in shady business practices, a Texas appeals court ruled, find... (more story)
State & Local More
Unclaimed Property Class Action Against Pa. Treasurer Axed
A Pennsylvania federal judge has tossed a potential class action challenging the constitutionality of the state's unclaimed property law, finding that the state treasurer doesn't have to pay interest on proper... (more story)
NJ Justices Erase Gov't Workplace Probe Confidentiality Rule
The New Jersey Supreme Court on Monday struck down part of a state statute that directs investigators to request, but not require, confidentiality in discrimination or harassment investigations involving state... (more story)
NY Tax Talk: Primary Function Is Key Analysis For Sales Tax
Two sales tax cases recently decided by New York's Appellate Division illustrate why both taxpayers and the state's Department of Revenue subscribe to the primary function test, a logical way to determine whet... (more story)
Wash. Woman Fights NJ Tax Bill Tied To Fed. Filing Status
A woman who lived in Washington state while married to a New Jersey resident challenged the latter state's assessment of income tax against her, arguing that the couple could file separately in the state even ... (more story)
Minn. House OKs Tax Bill With Corp. Disclosure Rule
Minnesota would demand disclosure of certain corporate franchise tax information and examine the prospect of worldwide combined reporting under parts of an omnibus tax package passed by the state House of Representatives.
Ohio Justices Urged To Uphold Tax On Goods Held In State
Ohio's imposition of its gross receipts tax on a Kansas-based soap company's goods that were temporarily held in Ohio distribution centers before being shipped elsewhere passes constitutional muster, the state... (more story)
Time To Fix NYC's Broken Property Assessment System
A New York appellate court's decision to revive Tax Equity Now New York v. City of New York may force the city to revamp its outdated and unfair real estate tax assessment system, which could be fixed with a c... (more story)
IRS Expects Updates To Hydrogen Credit Emissions Model
The Internal Revenue Service expects the U.S. Department of Energy to update a model used to determine eligibility for the new clean hydrogen production tax credit under recently proposed rules, an IRS attorney said Friday.
Hawaii Legislature OKs Adjusting Tax Brackets For Inflation
Hawaii would adjust its income tax brackets and increase its standard deduction to account for inflation under a bill sent to the governor for approval.
A Pennsylvania federal judge has tossed a potential class action challenging the constitutionality of the state's unclaimed property law, finding that the state treasurer doesn't have to pay interest on proper... (more story)
The New Jersey Supreme Court on Monday struck down part of a state statute that directs investigators to request, but not require, confidentiality in discrimination or harassment investigations involving state... (more story)
Two sales tax cases recently decided by New York's Appellate Division illustrate why both taxpayers and the state's Department of Revenue subscribe to the primary function test, a logical way to determine whet... (more story)
A woman who lived in Washington state while married to a New Jersey resident challenged the latter state's assessment of income tax against her, arguing that the couple could file separately in the state even ... (more story)
Minnesota would demand disclosure of certain corporate franchise tax information and examine the prospect of worldwide combined reporting under parts of an omnibus tax package passed by the state House of Representatives.
Ohio's imposition of its gross receipts tax on a Kansas-based soap company's goods that were temporarily held in Ohio distribution centers before being shipped elsewhere passes constitutional muster, the state... (more story)
A New York appellate court's decision to revive Tax Equity Now New York v. City of New York may force the city to revamp its outdated and unfair real estate tax assessment system, which could be fixed with a c... (more story)
The Internal Revenue Service expects the U.S. Department of Energy to update a model used to determine eligibility for the new clean hydrogen production tax credit under recently proposed rules, an IRS attorney said Friday.
Hawaii would adjust its income tax brackets and increase its standard deduction to account for inflation under a bill sent to the governor for approval.
International More
Japan Floats Top Seat For Small Islands At UN Tax Convention
The United Nations committee responsible for negotiating a framework convention on tax should have a co-chair for small island states in a subgroup that leads drafting of proposals, Japan's government said Monday.
US Resisting More Scoping On Amount B, Economist Says
In negotiations over the streamlined transfer pricing approach for baseline marketing and distribution functions known as Amount B, the U.S. has resisted calls for additional scoping criteria that would exclud... (more story)
HMRC Director Rejoins KPMG To Boost Tax Dispute Offering
A former deputy director at HM Revenue & Customs has returned to KPMG as director of KPMG Law's tax disputes teams, the firm has announced.
Africa Seeks Early UN Reform On Transfer Pricing, Exchanges
Legally binding protocols that reform transfer pricing and exchange of information to the benefit of all countries where multinational corporations operate should be developed simultaneously with the U.N. fram... (more story)
Finland's Stance On Swiss Treaty Recalls Ended Portugal Deal
Finland's plan to renegotiate its tax treaty with Switzerland in response to concerns about pension tax avoidance has some observers worried that the country will cancel that accord as it did a treaty with Por... (more story)
Taxation With Representation: Skadden, Wachtell, Davis Polk
In this week's Taxation With Representation, L'Occitane International said its executive director and chair is leading an offer to buy the company's shares he doesn't already own, UMB Financial agreed to purch... (more story)
IRS Can Assess Foreign Info Disclosure Penalty, DC Circ. Says
The D.C. Circuit on Friday overturned a major U.S. Tax Court ruling that had struck down the Internal Revenue Service's authority to assess and administratively collect penalties from taxpayers for failing to ... (more story)
The United Nations committee responsible for negotiating a framework convention on tax should have a co-chair for small island states in a subgroup that leads drafting of proposals, Japan's government said Monday.
In negotiations over the streamlined transfer pricing approach for baseline marketing and distribution functions known as Amount B, the U.S. has resisted calls for additional scoping criteria that would exclud... (more story)
A former deputy director at HM Revenue & Customs has returned to KPMG as director of KPMG Law's tax disputes teams, the firm has announced.
Legally binding protocols that reform transfer pricing and exchange of information to the benefit of all countries where multinational corporations operate should be developed simultaneously with the U.N. fram... (more story)
Finland's plan to renegotiate its tax treaty with Switzerland in response to concerns about pension tax avoidance has some observers worried that the country will cancel that accord as it did a treaty with Por... (more story)
In this week's Taxation With Representation, L'Occitane International said its executive director and chair is leading an offer to buy the company's shares he doesn't already own, UMB Financial agreed to purch... (more story)
The D.C. Circuit on Friday overturned a major U.S. Tax Court ruling that had struck down the Internal Revenue Service's authority to assess and administratively collect penalties from taxpayers for failing to ... (more story)