Spinoff Landscape Unclear In Wake Of Tossed IRS Guidance
The Internal Revenue Service has scrapped controversial guidance that limited the types of spinoff transactions that revenue officials would approve as tax-free ahead of time, but the path to seeking the agency's blessing for certain intercompany reorganizations remains hazy.
Mo. Airport Marriott Merits Lower Value, State Justices Affirm
A Missouri airport Marriott built on land owned by the city is subject to a reduced property value despite the assessor's protests that the reduced value is unconstitutional, the state Supreme Court affirmed.
Liberty Global Loses $2.4B Tax Substance Fight In 10th Circ.
Telecommunications giant Liberty Global is not entitled to a $2.4 billion deduction tied to transactions with its foreign affiliates, the Tenth Circuit majority ruled in a long-awaited opinion, siding with the U.S. government in finding the arrangement is a tax shelter lacking economic substance.
Spinoff Landscape Unclear In Wake Of Tossed IRS Guidance
The Internal Revenue Service has scrapped controversial guidance that limited the types of spinoff transactions that revenue officials would approve as tax-free ahead of time, but the path to seeking the agency's blessing for certain intercompany reorganizations remains hazy.
Mo. Airport Marriott Merits Lower Value, State Justices Affirm
A Missouri airport Marriott built on land owned by the city is subject to a reduced property value despite the assessor's protests that the reduced value is unconstitutional, the state Supreme Court affirmed.
Liberty Global Loses $2.4B Tax Substance Fight In 10th Circ.
Telecommunications giant Liberty Global is not entitled to a $2.4 billion deduction tied to transactions with its foreign affiliates, the Tenth Circuit majority ruled in a long-awaited opinion, siding with the U.S. government in finding the arrangement is a tax shelter lacking economic substance.
Federal More
The House Appropriations Committee passed legislation Wednesday that would cut the Internal Revenue Service's funding by $1 billion for the 2027 fiscal year.
The U.S. Tax Court relied on an incomplete analysis when it sided with the IRS and held that nearly $300 million in revenue from Hyatt Hotels' loyalty rewards program fund should be treated as taxable income, ... (more story)
The First Circuit on Wednesday affirmed the convictions of a Quincy, Massachusetts, temp agency owner who prosecutors said evaded more than $800,000 in payroll taxes by paying employees under the table.
An Ohio brewery owner has standing to challenge the constitutionality of the federal tax code's ban on distilling whiskey at home, but the ban is necessary for the government to collect taxes on distilled spir... (more story)
Video game giant Nintendo stands to make "windfall profits" through refunds of President Donald Trump's now-invalidated global tariff regime since those costs were actually passed on to consumers, a proposed c... (more story)
Treasury Secretary Scott Bessent told Senate lawmakers Wednesday that a $1.4 billion cut in the Internal Revenue Service's budget next year would still allow the agency to modernize its technology and provide ... (more story)
U.S. Trade Representative Jamieson Greer told a U.S. House of Representatives panel Wednesday that efforts to eliminate digital service taxes implemented by jurisdictions across the world continue to be priori... (more story)
State & Local More
Mitigating Multistate Risks As California Expands Tax Reach
Though California's new sourcing rules and extension of the pass-through entity election have created uncertainty, practitioners should file protective returns to respect the law's ambiguity and take certain o... (more story)
MTC Nearing Completion Of Yearslong Digital Tax Project
As a white paper from a Multistate Tax Commission work group studying how to harmonize state rules for taxing digital products nears completion, the group has chosen several key areas that states could focus o... (more story)
Ariz. House OKs Making Tax Dept. Report New Stances
Arizona would require its tax department to notify state lawmakers before adopting interpretations of tax statutes that would "adversely affect" taxpayers under legislation approved by the state House on Tuesday.
E-Discovery Quarterly: Recent Rulings On ESI Control
Several recent federal court decisions have perpetuated a split over what constitutes “control” of electronically stored information — with judges divided on whether the standard should turn on a party's legal... (more story)
COVID Not A 'Natural Disaster,' Wash. Panel Rules In Tax Case
A Washington state appeals court declined to revive a hotel trade group's class action seeking tax relief over the governor's COVID-19 emergency declaration in 2020, ruling Monday that the pandemic doesn't qua... (more story)
Anticipating The Justices' Potential Ruling On Tax Takings
Recent oral arguments in the U.S. Supreme Court case Pung v. Isabella focused on rules for valuation, timing and administrability of tax auction proceeds and whichever method the court adopts for determining j... (more story)
Tenn. Senate OKs Tax On International Money Transfers
Tennessee would impose a tax on money transferred from the state to anywhere outside the country and U.S. territories under a bill passed by the state Senate.
Though California's new sourcing rules and extension of the pass-through entity election have created uncertainty, practitioners should file protective returns to respect the law's ambiguity and take certain o... (more story)
As a white paper from a Multistate Tax Commission work group studying how to harmonize state rules for taxing digital products nears completion, the group has chosen several key areas that states could focus o... (more story)
Arizona would require its tax department to notify state lawmakers before adopting interpretations of tax statutes that would "adversely affect" taxpayers under legislation approved by the state House on Tuesday.
Several recent federal court decisions have perpetuated a split over what constitutes “control” of electronically stored information — with judges divided on whether the standard should turn on a party's legal... (more story)
A Washington state appeals court declined to revive a hotel trade group's class action seeking tax relief over the governor's COVID-19 emergency declaration in 2020, ruling Monday that the pandemic doesn't qua... (more story)
Recent oral arguments in the U.S. Supreme Court case Pung v. Isabella focused on rules for valuation, timing and administrability of tax auction proceeds and whichever method the court adopts for determining j... (more story)
Tennessee would impose a tax on money transferred from the state to anywhere outside the country and U.S. territories under a bill passed by the state Senate.
International More
EU Advocate General Approves Of Denmark VAT Group Limit
The EU's value-added tax rules allow Denmark to combat tax avoidance by requiring a VAT-exempt company to solely own another company for them to register jointly for VAT, a European Court of Justice advocate g... (more story)
Real Estate Co. Fights Exit Tax On £142M Over Legal Certainty
A tribunal breached the principle of legal certainty in European Union law by ruling in favor of Britain's tax authority in a dispute over an exit tax on capital gains of £142 million ($192 million), a real es... (more story)
EU Pushes Back Against Calls For Bloc-Wide Windfall Tax
The European Union will not imminently implement an EU-wide windfall tax on energy companies that are profiting from the price surge linked to the U.S.-Iran war, the European Commission said Wednesday, despite... (more story)
House Panel Votes To Gut Corporate Transparency Act
A House finance committee advanced a bill Tuesday that would defang the Corporate Transparency Act by exempting all domestically owned companies from compliance, codifying a limitation already implemented by t... (more story)
UK Exit Tax Ruling Is Judicial Overreach, Court Told
A tribunal overstepped its authority by ruling in favor of Britain's tax authority to impose an exit tax on U.K. trusts leaving the country in breach of European Union law long before Brexit was enacted, a tru... (more story)
Payroll VAT Fraudsters Jailed For 22 Years
Four directors of a payroll company were sentenced to more than 22 years in prison for a two-year £8.8 million ($11.9 million) value-added tax fraud scheme, HM Revenue and Customs said Tuesday.
Buy.com Founder Says IRS Missed Deadline For $16M Bill
The founder of now-defunct Buy.com told the Tenth Circuit that the IRS cannot use "a patchwork of documents" to show it didn't miss the window to hit him with a nearly $16 million tax bill, pushing for reversa... (more story)
The EU's value-added tax rules allow Denmark to combat tax avoidance by requiring a VAT-exempt company to solely own another company for them to register jointly for VAT, a European Court of Justice advocate g... (more story)
A tribunal breached the principle of legal certainty in European Union law by ruling in favor of Britain's tax authority in a dispute over an exit tax on capital gains of £142 million ($192 million), a real es... (more story)
The European Union will not imminently implement an EU-wide windfall tax on energy companies that are profiting from the price surge linked to the U.S.-Iran war, the European Commission said Wednesday, despite... (more story)
A House finance committee advanced a bill Tuesday that would defang the Corporate Transparency Act by exempting all domestically owned companies from compliance, codifying a limitation already implemented by t... (more story)
A tribunal overstepped its authority by ruling in favor of Britain's tax authority to impose an exit tax on U.K. trusts leaving the country in breach of European Union law long before Brexit was enacted, a tru... (more story)
Four directors of a payroll company were sentenced to more than 22 years in prison for a two-year £8.8 million ($11.9 million) value-added tax fraud scheme, HM Revenue and Customs said Tuesday.
The founder of now-defunct Buy.com told the Tenth Circuit that the IRS cannot use "a patchwork of documents" to show it didn't miss the window to hit him with a nearly $16 million tax bill, pushing for reversa... (more story)