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 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 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
A Hungarian anti-corruption investigation into claims that the former prime minister used taxpayer funds to support the Conservative Political Action Conference could include potential cross-border political a... (more story)
The Internal Revenue Service properly disallowed a partnership's nearly $26 million charitable deduction for a donated easement on a 110-acre pasture, the agency told the Eleventh Circuit, urging it to affirm ... (more story)
The U.S. Department of Justice published a final order Thursday loosening federal restrictions on medical marijuana products that fall within the ambit of state-regulated programs or have approval from the U.S... (more story)
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)
State & Local More
Minn. Business Groups Denounce Sales Tax Expansion
Minnesota Gov. Tim Walz's proposal to expand the state's sales tax base to include more services and a social media tax plan would increase costs in the state, several business groups said during a hearing Thursday.
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)
Minnesota Gov. Tim Walz's proposal to expand the state's sales tax base to include more services and a social media tax plan would increase costs in the state, several business groups said during a hearing Thursday.
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)
International More
Belgian Lawmakers Push Gov't For 3% Digital Services Tax
Belgian lawmakers have introduced a bill to create a 3% digital services tax on revenue that large multinational corporations derive from the country, pushing the governing coalition to follow through on a ple... (more story)
HMRC Defends Court's Power To Resolve Exit Tax Dispute
A U.K. tribunal didn't overstep its authority by interpreting legislation to allow taxpayers to pay an exit tax in deferred payment plans to comply with the European Union's rights to free establishment, HM Re... (more story)
EU's Ability To Simplify Pillar 2 Limited, Official Says
The ability of the European Union to simplify Pillar Two and support businesses with compliance is currently limited because of the decision not to change the related EU law, a European Commission official said Thursday.
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)
USTR Seeking 'Outcomes' On DSTs, Stronger USMCA Rules
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)
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)
Belgian lawmakers have introduced a bill to create a 3% digital services tax on revenue that large multinational corporations derive from the country, pushing the governing coalition to follow through on a ple... (more story)
A U.K. tribunal didn't overstep its authority by interpreting legislation to allow taxpayers to pay an exit tax in deferred payment plans to comply with the European Union's rights to free establishment, HM Re... (more story)
The ability of the European Union to simplify Pillar Two and support businesses with compliance is currently limited because of the decision not to change the related EU law, a European Commission official said Thursday.
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)
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)
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)