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11th Circ. Affirms Quarry Valuation Sank $23M Easement Perk
A 103-acre tract's best alternative use is not an aggregate quarry, the 11th Circuit ruled Thursday, rejecting the valuation that supported a partnership's $23 million deduction claim for donating the Georgia property as a conservation easement.
Meta Says Altera Ruling Doesn't Control In Stock Option Fight
The Ninth Circuit's 2019 ruling against Altera, which upheld an IRS regulation requiring companies to share the cost of stock options in joint ventures with foreign affiliates, has no bearing on Meta Platforms' dispute over the same issue, the social media company told the U.S. Tax Court.
NY Panel Rejects Hotel Co. Fight Over $15M Tax Assessments
A hotel refurbishing business failed to prove that New York's tax agency lacked a rational basis for imposing about $15 million in corporate tax assessments stemming from denied deductions, a state appeals court ruled Thursday, saying the company didn't provide sufficient records to support its case.
11th Circ. Affirms Quarry Valuation Sank $23M Easement Perk
A 103-acre tract's best alternative use is not an aggregate quarry, the 11th Circuit ruled Thursday, rejecting the valuation that supported a partnership's $23 million deduction claim for donating the Georgia property as a conservation easement.
Meta Says Altera Ruling Doesn't Control In Stock Option Fight
The Ninth Circuit's 2019 ruling against Altera, which upheld an IRS regulation requiring companies to share the cost of stock options in joint ventures with foreign affiliates, has no bearing on Meta Platforms' dispute over the same issue, the social media company told the U.S. Tax Court.
NY Panel Rejects Hotel Co. Fight Over $15M Tax Assessments
A hotel refurbishing business failed to prove that New York's tax agency lacked a rational basis for imposing about $15 million in corporate tax assessments stemming from denied deductions, a state appeals court ruled Thursday, saying the company didn't provide sufficient records to support its case.
Federal More
Online tax return filers who alleged Google's tracking tool effectively eavesdropped on their confidential tax information asked a California federal judge to certify several classes in their suit against the search giant.
Congress needs to take steps to create a tax structure for the digital asset market, two of President Donald Trump's picks to serve in U.S. Treasury Department posts told the Senate Finance Committee during a ... (more story)
Senate Democrats on Thursday once again reintroduced a cannabis legalization bill that would remove the drug entirely from the ambit of the Controlled Substances Act and impose a tax-and-regulate scheme akin t... (more story)
Ashurst Perkins Coie announced Thursday that it has bolstered its tax practice with a Los Angeles-based partner who came aboard from Stradling Yocca Carlson & Rauth PC.
A 25% tariff on Brazilian goods will begin next week with an expanded exemption list following public comments on the action, U.S. Trade Representative Jamieson Greer announced.
The skills I've developed as a lifelong magician have translated directly into tangible benefits in the courtroom because performing magic and trying cases both live at the intersection of psychology, storytel... (more story)
The IRS' argument in support of its income allocations to Eaton Corp. from an Irish affiliate effectively inverts the arm's-length standard underlying U.S. transfer pricing law, seeking to price transactions b... (more story)
State & Local More
Skill Games, Grinch Bots: A Midyear Pa. Legislation Review
Two major rulings from the Pennsylvania Supreme Court have left it up to the Legislature to address "skill games" and second-degree murder sentences, while other pending bills would tackle a long-standing chal... (more story)
Title Co. Can't Keep Tax Refund, Wash. Panel Rules 2nd Time
A Washington appeals panel handed a win again to the state Department of Revenue, reversing a lower court order that the department owed an $11 million tax refund to a title insurance and settlement services company.
Minn. Tax Court Right On $108M Building Value, Justices Told
The Minnesota Tax Court operated within its discretion to give 80% weight to Hennepin County's appraisal of a Minneapolis office building and 20% to the owner's, the county told the state Supreme Court, urging... (more story)
Wash. Chief Justice Draws 3 Challengers In Bid For 4th Term
A former public defender, a naval officer-turned-tax attorney and a family law practitioner are each vying this election season to unseat a veteran Washington State Supreme Court justice who's penned some of t... (more story)
House Backs Bill To End Penny Minting, Round Cash Sales
The phaseout of the penny would become law and retailers would be able to round cash transactions up or down to the nearest 5-cent amount under a bill that the U.S. House passed Tuesday, sending it to the Senate.
NY Gov. Signs Data Center Moratorium Executive Order
New York Gov. Kathy Hochul has signed an executive order that blocks any new hyperscale data center projects from being built in her state by temporarily pausing environmental permits for those types of projec... (more story)
NJ Aims To Protect Ratepayers With Nuclear Power Guidelines
New Jersey Gov. Mikie Sherrill on Monday signed into law a bill intended to ensure consumers don't bear the costs of nuclear power projects needed to help address the growing demand for electricity driven prim... (more story)
Two major rulings from the Pennsylvania Supreme Court have left it up to the Legislature to address "skill games" and second-degree murder sentences, while other pending bills would tackle a long-standing chal... (more story)
A Washington appeals panel handed a win again to the state Department of Revenue, reversing a lower court order that the department owed an $11 million tax refund to a title insurance and settlement services company.
The Minnesota Tax Court operated within its discretion to give 80% weight to Hennepin County's appraisal of a Minneapolis office building and 20% to the owner's, the county told the state Supreme Court, urging... (more story)
A former public defender, a naval officer-turned-tax attorney and a family law practitioner are each vying this election season to unseat a veteran Washington State Supreme Court justice who's penned some of t... (more story)
The phaseout of the penny would become law and retailers would be able to round cash transactions up or down to the nearest 5-cent amount under a bill that the U.S. House passed Tuesday, sending it to the Senate.
New York Gov. Kathy Hochul has signed an executive order that blocks any new hyperscale data center projects from being built in her state by temporarily pausing environmental permits for those types of projec... (more story)
New Jersey Gov. Mikie Sherrill on Monday signed into law a bill intended to ensure consumers don't bear the costs of nuclear power projects needed to help address the growing demand for electricity driven prim... (more story)
International More
EU Launches Electricity Tax Plan To Spur Clean Fuel Shift
The European Union has unveiled an initiative that will require member states to tax electricity at a lower rate than natural gas to support the bloc's climate goals.
UK Litigation Roundup: Here's What You Missed In London
The past week in London has seen Snapchat and Dolby press on with a fresh infringement claim in their ongoing patent battle, The Telegraph face an intellectual property claim by a photo archive, a group of int... (more story)
EU Countries Split On Pillar 2 Multinationals' Reporting Breaks
European Union countries are deeply divided on proposals from the European Commission to exempt Pillar 2 companies from certain rules that aim to prevent tax abuse, EU officials told Law360.
German Court Convicts Former Banker In €320M Cum-Ex Case
A former banker at an Australian firm was convicted Thursday by a German court of attempting €320 million ($366 million) in tax evasion as part of a cum-ex dividend scandal, a court spokesperson told Law360.
Belgian Energy Revenue Cap Is Lawful, EU Court Adviser Says
An adviser to the European Union's top court backed Belgium's application of a bloc-wide mechanism for capping revenue collected by certain energy companies, concluding Thursday that the levy didn't deviate fr... (more story)
HMRC Resists Port Co.'s Claim To Broader Tax Allowances
HM Revenue & Customs pushed back Thursday against Liverpool's port operator over its claims that the construction costs of a quay wall qualify for capital allowances, arguing before the Upper Tribunal that the... (more story)
Frozen Thresholds Drag 10M UK Pensioners Into Paying Tax
The number of U.K. pensioners paying income tax has risen by three million in the five years since earning thresholds were frozen, government figures have revealed.
The European Union has unveiled an initiative that will require member states to tax electricity at a lower rate than natural gas to support the bloc's climate goals.
The past week in London has seen Snapchat and Dolby press on with a fresh infringement claim in their ongoing patent battle, The Telegraph face an intellectual property claim by a photo archive, a group of int... (more story)
European Union countries are deeply divided on proposals from the European Commission to exempt Pillar 2 companies from certain rules that aim to prevent tax abuse, EU officials told Law360.
A former banker at an Australian firm was convicted Thursday by a German court of attempting €320 million ($366 million) in tax evasion as part of a cum-ex dividend scandal, a court spokesperson told Law360.
An adviser to the European Union's top court backed Belgium's application of a bloc-wide mechanism for capping revenue collected by certain energy companies, concluding Thursday that the levy didn't deviate fr... (more story)
HM Revenue & Customs pushed back Thursday against Liverpool's port operator over its claims that the construction costs of a quay wall qualify for capital allowances, arguing before the Upper Tribunal that the... (more story)
The number of U.K. pensioners paying income tax has risen by three million in the five years since earning thresholds were frozen, government figures have revealed.