A representative from the IRS said Friday that the intervening period between a reviewed year, which is the year examined during an audit, and an adjustment year, which is when an audit is finalized, does not matter under the new centralized partnership audit regime.
The U.S. Department of Justice’s associate attorney general who was tasked with overseeing numerous divisions, including antitrust, civil, civil rights, environment and natural resources, and tax, will leave the department for Walmart after nine months on the job, the DOJ and the retail giant announced Friday.
The city and county of San Francisco hit the state of California with a lawsuit Thursday, challenging a recently enacted law that allows ride-hailing services like Lyft and Uber to operate in cities without obtaining local licenses, causing the city to lose millions in associated taxes.
Attorneys general from Texas and Nevada on Friday filed an amicus brief in a lawsuit in Arizona federal court, offering their support for a law that bars state-funded contractors from boycotting Israel.
Energy tax credit extenders included in the two-year budget deal signed by President Donald Trump on Friday provide potential boosts for renewable energy development and potential lifelines for nuclear and carbon capture and storage projects.
Documents withheld by Facebook Inc. in its transfer pricing dispute with the Internal Revenue Service are not protected by privilege because they pertain to business development and not trial preparation, U.S. Department of Justice attorneys said Thursday in California federal court ahead of a March 29 hearing on whether the company should produce the documents.
India’s tax authority has announced that last month it inked seven advance pricing agreements, which provide preemptive approval of multinational corporations' tax treatment of transactions with foreign subsidiaries, including the country’s first such deal with the U.S.
In this week’s Taxation With Representation, NuStar Holdings merged with a subsidiary to create a $7.9 billion partnership, Kroger made a $2.15 billion convenience store sale to EG Group, Enduring Resources bought WPX Energy’s San Juan Basin oil holdings for $700 million, and Tronc sold the Los Angeles Times and other newspapers to Nant Capital for $500 million.
An oil company sued the Internal Revenue Service in a Texas federal court Thursday, asking for a $222 million reduction in its income over the classification of alternative fuel credits.
President Donald Trump signed legislation Friday for a two-year budget deal and temporary spending measure, ending a brief government shutdown after Congress failed to pass the bill before midnight.
After several lean years in which no states created an earned income tax credit and North Carolina became the first state in 30 years to scrap its credit, the state EITC — designed to boost the impact of the federal earned income credit for low- and moderate-income working families — is thriving again.
Long-standing royalty agreements between Coca-Cola and six foreign subsidiaries will be the company's main focus at trial in its $3.3 billion transfer pricing dispute with the Internal Revenue Service, Coca-Cola said in a 161-page trial brief filed Wednesday at the U.S. Tax Court.
The Australian Taxation Office released a guidance draft Wednesday covering the steps multinational businesses can take if they suspect their arrangements with foreign affiliates might trigger the country’s controversial diverted profits tax, which is designed to prevent companies from shifting profits offshore.
The U.S. Department of the Treasury has identified a number of areas where it says guidance will be prioritized over the coming months in the wake of the recently enacted Republican tax cut legislation, according to a document released Wednesday.
A New Jersey appellate court on Thursday affirmed that a whistleblower’s $1.2 million payout from his False Claims Act lawsuit over unlawful Medicare billing is subject to state income tax, clarifying in a published opinion that the award falls within the legal damages that constitute taxable income under state law.
Skadden Arps Slate Meagher & Flom LLP's global tax practice has provided advice on transactions to big-name companies such as NXP Semiconductors N.V. in its proposed $47 billion acquisition by San Diego-based Qualcomm Inc. and Hewlett Packard Enterprise in its $8.8 billion spin-off and merger of its software business with a foreign company, earning the firm a spot among Law360's 2017 Tax Practice Groups of the Year for the third year in a row.
Congress has passed a budget agreement that, along with keeping the government funded, would revive a set of expired targeted tax benefits for businesses and individuals, known as tax extenders.
The European Union’s top court on Thursday upheld a challenge to a Greek law that lets gas stations near bordering non-EU countries sell tax-exempt fuel, ruling that the excise duty applies even if the drivers are heading directly out of Europe.
Charles Rettig, a seasoned California litigator with Hochman Salkin Rettig Toscher & Perez PC, has been nominated to head the Internal Revenue Service for five years, the White House announced on Thursday.
European Union lawmakers voted Thursday to form a new inquiry committee to tackle money laundering and tax evasion practices exposed in the Paradise Paper leaks, taking up the mantle from three previous parliamentary investigations.
Though allowing the transfer of unused development rights carries some disadvantages, it has encouraged developers to utilize air rights and improve upon some of America's largest cities, say attorneys with Nixon Peabody LLP and Katherine Soule of the Northeastern University School of Law.
Until recently, if a partnership were audited and the IRS determined that the partnership had underreported its income, the IRS would collect the unpaid income tax from the individual partners. As of Jan. 1, 2018, those rules have changed, says Helen Rogers of Holland & Hart LLP.
While a client’s visual impairment can create challenges for an attorney, it also can open up an opportunity for both attorney and client to learn from each other. By taking steps to better assist clients who are blind or visually impaired, attorneys can become more perceptive and effective advisers overall, say Julia Satti Cosentino and Nicholas Stabile of Nutter McClennen & Fish LLP.
A new memo from the U.S. Department of Justice prohibiting DOJ litigators from treating any agency guidance document as binding offers needed relief to regulated parties, giving them a greater opportunity to push back against enforcement theories that rely on “clear” guidance regarding an underlying ambiguous or silent statute, say Ronald Tenpas and Gregory Etzel of Morgan Lewis & Bockius LLP.
As President Donald Trump emphasized in his recent State of the Union speech, the U.S. economy appears to be strong. Unfortunately, as the Democratic response confirmed, the state of affairs on Capitol Hill is anything but. Jeffrey Turner and David Schnittger of Squire Patton Boggs LLP outline what Congress must do in the next month or so.
Three unrelated developments make it more likely that employees will question their pay with greater frequency than in the past. Employers should prepare to answer paycheck questions, understanding that these conversations could give rise to Fair Labor Standards Act and state wage and hour retaliation claims, says Mark Stanisz of Duane Morris LLP.
On Jan. 19, the U.S. Department of the Treasury and the IRS issued Notice 2018-13, elaborating on previous guidance about the Tax Cuts and Jobs Act’s new deemed repatriation provision. The notice also describes the agencies' intent to issue updated Form 5471 instructions, which will introduce an important — and much needed — limitation to filing requirements following the repeal of Section 958(b)(4), say attorneys at Morgan Lewis & Bockius LLP.
Because courts have not modernized as quickly as companies like Amazon, Tesla and Apple, Americans are becoming increasingly dissatisfied, but technological innovations may be able to help Americans access their due process, says Stephen Kane of FairClaims.
Counsel representing victims of Ponzi schemes should note that the Tax Cuts and Jobs Act eliminates the theft tax loss provisions of the Internal Revenue Code for tax years after 2017. The time to act is now, before this important tax benefit goes away, says Kevin Diamond of Rico Murphy & Diamond LLP.
The Tax Cuts and Jobs Act purports to lower taxes and simplify the Internal Revenue Code, but the new limitation on the deductibility of business interest seems contrary to this objective. This change will certainly cause many businesses to pause and consider whether debt financing is the best option for them, says Jennifer Tolsky of Gould & Ratner LLP.