• March 22, 2018

    OECD Adds Guidance On Transfer-Pricing Taxation

    The Organization for Economic Cooperation and Development issued guidelines Thursday that draw on public input as to how multinational companies should attribute profits to permanent establishments, focusing on warehousing, procurement and certain outsourcing contracts as part of its effort to prevent tax avoidance.

  • March 22, 2018

    Port Authority, Jersey City Settle $400M Tax Dispute

    The Port Authority of New York and New Jersey said on Thursday its board of commissioners voted to authorize a host of agreements that settle a long-standing dispute with Jersey City, New Jersey, over property tax payments worth $400 million, with the understanding that the city will not contest the tax-exempt status of Port Authority properties located within the city for 25 years.

  • March 22, 2018

    Union Pacific Urges Justices To Preserve Win On Stocks

    The Union Pacific Railroad Co. urged the U.S. Supreme Court on Thursday not to overturn its victory in the Eighth Circuit that deemed its stock options for employees nontaxable, even if the high court rules against railroad companies in a similar and separate case before it.

  • March 22, 2018

    Ireland Urges EU To Hit The Brakes On Digital Tax Rules

    The European Commission should wait for international consensus before moving forward with the “rushed” proposal of a revenue-based digital services tax, the Irish government said Wednesday, arguing that the measure likely would disadvantage smaller member states.

  • March 22, 2018

    Pennsylvania Withdraws Objection To Refinery Bankruptcy

    Pennsylvania tax officials on Wednesday withdrew their objection to Philadelphia Energy Solutions LLC's fast-track prepack Chapter 11 plan, saying the oil refinery agreed to amend the plan to preserve the state’s right to collect on a $3.8 billion tax claim.

  • March 22, 2018

    Pa. Justices To Weigh Broadness Of Business Privilege Tax

    The Pennsylvania Supreme Court agreed Wednesday to review whether a business privilege tax provision in a city ordinance was properly interpreted to prevent a freight broker from claiming a tax deduction based on customer payments it passed through to freight carriers.

  • March 22, 2018

    5th Circ. Rejects IRS Bid To Pause Anti-Inversion Appeal

    The Fifth Circuit refused to pause the U.S. government’s appeal of a Texas federal court’s decision to invalidate a rule that sank a planned $160 billion merger between Pfizer Inc. and Irish counterpart Allergan PLC, according to an order issued Wednesday.

  • March 22, 2018

    Rakoff Spares 3 Swiss Tax-Evasion Cooperators Prison Time

    Three Swiss men who helped Americans dodge tax obligations avoided prison Thursday after Manhattan U.S. District Judge Jed S. Rakoff credited their extensive cooperation and expressed dismay over backlash two of them experienced in their native country.

  • March 22, 2018

    Expedia, Others Join Bid To Toss Overcharging Suit

    Hotel booking websites Expedia Inc., LP and Travelscape LLC on Thursday urged a South Carolina court to throw out a proposed class action alleging they overcharged state residents for taxes and fees, saying the court has no jurisdiction over the matter.

  • March 22, 2018

    Congress' Last Chance For Action On Remote Sellers Dies

    The last chance for Congress to beat the U.S. Supreme Court to action on remote sellers’ tax obligations appears to have evaporated when congressional leaders unveiled an omnibus spending bill that did not include online taxation regulations.

  • March 22, 2018

    IRS Overhaul Bill Coming In April, Brady Says

    House Ways and Means Chairman Kevin Brady, R-Texas, said Thursday that his committee will advance an Internal Revenue Service overhaul bill next month as part of the next phase of tax overhaul that he and President Donald Trump have advocated.

  • March 22, 2018

    Local Coke Units Made Key Strategic Decisions, Exec Says

    A Coca-Cola business unit executive made key business decisions autonomously from corporate headquarters, including lobbying the Egyptian government for a tax cut on company products and adjusting worldwide advertising campaigns for local markets, the executive testified at a U.S. Tax Court trial Thursday.

  • March 22, 2018

    House Passes $1.3T Spending Bill With ‘Grain Glitch’ Fix

    The U.S. House of Representatives on Thursday approved a $1.3 trillion omnibus spending bill that in addition to funding the government would fix a provision in the recent tax overhaul law that was having unintended effects on the agricultural industry and make other changes to the tax code.

  • March 22, 2018

    Anadarko Playing Victim In $26M Tax Refund Row, IRS Argues

    The IRS told a Texas federal court Wednesday to reject a quick-win request from Anadarko Petroleum Corp., saying the oil company is playing the victim, while Anadarko said the government is just restating the same arguments.

  • March 21, 2018

    Condo Association Can't Represent Unit Owners In Tax Case

    While Florida condominium owners can file a joint petition through their condominium association to challenge property tax assessments, language in state tax law prevents them from forming a similar defense class if the county property appraiser files suit to appeal an adverse ruling, a state appeals court ruled Wednesday.

  • March 21, 2018

    High Court Criminal Tax Ruling Leaves Some Leeway For Feds

    A commanding majority on the U.S. Supreme Court bench refused to grant federal prosecutors a wider berth in trying allegedly criminal tax behavior, but the court’s interpretation of a tax felony statute may still be vague enough to lead to convictions for lesser violations.

  • March 21, 2018

    NY Agency OKs Power Tariffs On Upstate Cryptocurrency Biz

    The New York State Public Service Commission has ruled that upstate municipal power authorities can impose a tariff on cryptocurrency companies that require large amounts of electricity to conduct business.

  • March 21, 2018

    Omnibus Spending Bill Would Fix Tax Law’s ‘Grain Glitch’

    Congressional leaders on Wednesday unveiled an omnibus spending bill that would alter a provision of the recent tax overhaul legislation that lawmakers said was having adverse effects on the U.S. agriculture industry.

  • March 21, 2018

    Feds Wrong To Underpay Utah County, Claims Court Finds

    The U.S. Department of the Interior must pay what it promises to pay even when Congress appropriates less funding, the U.S. Court of Federal Claims ruled Tuesday in siding with a Utah county government for payments in lieu of taxes.

  • March 21, 2018

    GILTI Calculation Has 'Potential Traps,' Practitioner Says

    A provision in the new U.S. tax law can lead to “potential traps” because of how it calculates taxes for a new category of profit — global intangible low-taxed income, or GILTI — a practitioner said during a webcast on Wednesday.

Expert Analysis

  • Expats Beware: OVDP Is Over In September

    Glen Frost

    U.S. taxpayers with undisclosed foreign accounts need to act soon as the IRS is ending its offshore voluntary disclosure program in six months, says Glen Frost of American Citizens Abroad.

  • Tax Reform Is Hurting Foreign Investors In The US

    Michele Alexander

    The Tax Cuts and Jobs Act has codified a previous revenue ruling in a fairly controversial area of partnership tax law, in a potential disappointment to non-U.S. investors in domestic partnerships and practitioners who questioned the authority for issuing the ruling in the first place, say Michele Alexander and Ryan Davis of Bracewell LLP.

  • How FERC Is Acting On Income Tax Allowances And The TCJA

    Linda Walsh

    The Federal Energy Regulatory Commission acted swiftly to respond to the recent United Airlines v. FERC decision regarding income tax allowances, as well as to implement changes stemming from the Tax Cuts and Jobs Act. FERC's actions are meant to ensure that ratepayers see the benefits of lower corporate tax rates, say attorneys with Husch Blackwell LLP.

  • Opinion

    Companies Should Avoid The BigLaw Bonus Structure

    Michael Moradzadeh

    Since passage of the Trump tax plan last year, companies have been touting bonuses they’ve handed down to rank-and-file employees. This highlights the trend of employers favoring bonuses over pay raises in the belief that variable, short-term rewards are less risky to the business than permanent increases in labor costs. But law firms have been using this strategy for years — and there are dangers, says Michael Moradzadeh of Rimon PC.

  • Post Tax Reform: What Corporate Structure Is Right For You?

    David Boatwright

    Given a range of changes made to the Internal Revenue Code by the Tax Cuts and Jobs Act, many CEOs and in-house counsel are wondering whether it is more advantageous to conduct their businesses as pass-through entities or, alternatively, as C corporations. Attorneys with Procopio Cory Hargreaves & Savitch LLP discuss the options.

  • Calif. Seeks Input On Clean Energy Equipment Tax Exemption

    Carley Roberts

    Next month, the California Department of Tax and Fee Administration will hold an interested parties meeting regarding a partial sales and use tax exemption for electric generation and distribution equipment. Attorneys from Eversheds Sutherland LLP explain how the exemption has changed this year and why stakeholders may want to weigh in.

  • Chief Innovation Officer — The New Star On Legal Teams

    Mark Williamson

    Over the past few years, forward-thinking law firms have expanded their talent pools to include a chief innovation officer, whose responsibilities include spearheading the implementation of technology. It is a smart move, says ​​​​​​​Mark Williamson, co-founder and chief technology officer at Hanzo Archives Ltd.

  • An Expansion Of Tax On US Owners Of Foreign Equity

    David Dreier

    Tax reform's expansion of the controlled foreign corporation rules — which have affected many foreign corporations not previously categorized as CFCs — have prompted U.S. persons who directly or indirectly own interests in these corporations to question whether they are subject to further annual income inclusions. David Dreier and Grayson Weeks of White & Case LLP deconstruct the new tax regime.

  • The Impact Of Tax Reform On Leveraged Lending Transactions

    Frederick Fisher

    Attorneys from Mayer Brown International LLP discuss the impact of the tax overhaul on leveraged lending transactions focusing on Section 956, the limitation on interest deduction and pass-through entities.

  • Opinion

    National Lawyers Need National Licensing For National Courts

    EJ Hurst II

    Just last month, a number of legal groups asked the Northern District of California to strike its rule requiring that, before seeking federal court admission, attorneys first be licensed by the state of California. It is irrational to exclude seasoned federal practitioners from general admission due to state bar approval while allowing raw state lawyers who have never been inside a federal courtroom, says attorney EJ Hurst.