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Sunday, January 20, 2019

Featured Stories

Atlantic City's Winning Streak Will Be Tough To Sustain No Photo Available

Atlantic City's fiscal recovery may be fueled by sports betting fever and trendy hotspots along the New Jersey boardwalk, but the reso... (more story)

Crunch Time For Wind Developers As Tax Credit Lapse Looms No Photo Available

Time is growing tight for wind developers to grab the remaining slice of the federal renewable energy production tax credit before it ... (more story)

Justices’ Cert Grant In Trust Case Could Broaden Tax Nexus Maria Koklanaris

The U.S. Supreme Court decision to hear a case about state taxation of trusts will likely have far-reaching implications, potentially ... (more story)

Federal More

CFCs Must Be Wary Of ‘Trap’ In Partnership Interest, Panelist Says

Saturday, January 19, 2019

A controlled foreign corporation must be aware of a potential "trap" when it holds and disposes of a partnership interest, or it could lose the ability to make certain tax adjustments, a tax attorney said at a meeting Friday.

Ex-Sadis & Goldberg Atty Gets 3 Years For Charity, Tax Scam

Friday, January 18, 2019

The former head of Sadis & Goldberg LLP’s tax and trusts and estates groups was sentenced to just over three years in prison Friday for cheating a dead client’s estate out of $3.7 million through a bogus c... (more story)

US Attys Can't Snub EU Tax Reporting Rules, Panelist Says

Friday, January 18, 2019

Although U.S. practitioners aren’t directly subject to the European Union’s tax disclosure rules, they’re not off the hook if a client says it won’t comply with a member state’s requirements, a panelist said F... (more story)

Orrick Adds Ex-Norton Rose Energy Tax Expert In NY

Friday, January 18, 2019

Orrick Herrington Sutcliffe LLP has announced that a former tax partner at Norton Rose Fulbright with a focus on renewable energy joined the firm in its New York office.

Fla. Couple Can't Escape $8M IRS Suit Over Alter Egos

Friday, January 18, 2019

A Florida federal judge Friday denied a couple’s bid for a quick win in an $8 million tax dispute with the Internal Revenue Service, ruling the government’s complaint did not warrant dismissal because it was c... (more story)

US Hybrid Rules Look To Fact Of Foreign Taxation, Not Rates

Friday, January 18, 2019

New U.S. rules designed to curb tax avoidance from differing treatment of interest income domestically and abroad are agnostic about the foreign country’s tax rate — as are the international guidelines on whic... (more story)

Some Owners Won’t Benefit From Opportunity Zones, Atty Says

Friday, January 18, 2019

The new opportunity zone program, designed to help low-income communities, could actually result in some original landowners in the communities being unable to use the program's tax benefits, a tax attorney said Friday.

State & Local More

North Dakota Bill Would Give Tribes More Oil Tax Revenue

Friday, January 18, 2019

A bill recently introduced in the North Dakota Senate would change the split of oil tax revenue between the state and a Native American nation, which bill sponsors said would ultimately result in increased rev... (more story)

Exxon's Foreign Dividends Wrongly Taxed, Mont. Justices Told

Friday, January 18, 2019

Exxon Mobil Corp. subsidiaries that hold limited amounts of property and payroll in the U.S. shouldn’t have dividend payments included in their parent company’s income apportionable to Montana, the oil giant t... (more story)

Miss. Justices Say City's Annexation Bid Not A 'Tax Grab'

Friday, January 18, 2019

The Mississippi Supreme Court has largely upheld a city’s attempt to annex surrounding land, finding the municipality's proposed expansion was not a “tax grab” because it wasn’t seeking more revenue to plug ho... (more story)

NYC Tax Tribunal Says Goldman Corp. Owes $4M In City Tax

Friday, January 18, 2019

The New York City Tax Appeals Tribunal recently ruled capital gains realized by a Goldman Sachs unit on the sale of its minority interest in a city-based business were subject to $4 million general corporation tax.

Minn. Rejects 'Dark Store' Theory In Lowe’s Property Row

Friday, January 18, 2019

The Minnesota Tax Court has said a Lowe’s store is entitled to a market value reduction, but the attorney for the county the store is located in lauded the decision as rejection of the “dark store” theory of p... (more story)

Weekly Column

Renewed Hope For Fighting Tax Incentive Wars: SALT In Review

Friday, January 18, 2019

From legislation that could curb tax incentive wars to one state that has been failing to meet the Streamlined Governing Board's standards, Quarles & Brady LLP's David Brunori offers his thoughts on recent not... (more story)

Tax Practice Group Of The Year: Skadden

Friday, January 18, 2019

Skadden Arps Slate Meagher & Flom participated in some of the most important and newsworthy tax transactions of 2018, from guiding Fox's sale of a $15 billion stake in Sky to Comcast Corp. to helping Starr... (more story)

International More

Proposed Hybrid Regs Require Proving Negative, Panelist Says

Friday, January 18, 2019

Proposed regulations for hybrid transactions will task U.S. companies with “proving a negative” by showing that any tax avoidance in a foreign structure can’t be linked with its American affiliate, a practitio... (more story)

Taxpayers Can No Longer 'Bunker' Info, Tax Adviser Says

Thursday, January 17, 2019

The advent of information-exchange arrangements both in the U.S. and globally means taxpayers can’t “bunker” information and think authorities won’t find it, a tax policy adviser said Thursday at the American ... (more story)

French Time Limit Doesn't Negate VAT Refund, Top EU Court Told

Thursday, January 17, 2019

A German cruise-services company shouldn’t have to forfeit its right to a refund of value-added tax from France because of a missed filing deadline, an adviser to the European Union’s highest court said in an ... (more story)

ABA Urges Treasury To Repeal Rule On Global Partnerships

Thursday, January 17, 2019

The American Bar Association Section of Taxation has criticized Treasury's "blended" approach to domestic partnerships that fall under the federal tax overhaul's global minimum tax, claiming it could lead to u... (more story)

States Lose $17B To Offshore Profit Shifting, Paper Says

Thursday, January 17, 2019

Adopting combined reporting and extending tax haven lists are two fixes aimed at cracking down on companies shifting profits offshore that could earn states more than $17 billion in annual corporate tax receip... (more story)

EU Order Doesn't Trump Bulgarian Laws In VAT Suit, ECJ Says

Thursday, January 17, 2019

The European Union mandate to prosecute tax fraud doesn't supersede national laws on the proper collection of evidence, the European Court of Justice ruled Thursday in a Bulgarian criminal value-added tax evasion case.

Nuts And Bolts Of The IRS' Proposed Anti-Hybrid Regulations

Thursday, January 17, 2019

In December, the IRS proposed regulations under two new sections of the Internal Revenue Code aimed at hybrid arrangements — transactions by multinational companies subject to corporate income tax in one natio... (more story)