Treasury Asked To Narrow Crackdown On Fund Strategies
The U.S. Treasury Department should develop targeted rules distinguishing abusive transactions from long-standing investment management practices in new enforcement that scrutinizes novel strategies exploiting the tax benefits of certain investment vehicles and financial products, firms and organizations told the department.
Texas Instruments Asks Court To Reject IRS Stance On FDII
The IRS' reduction of Texas Instruments' deduction for foreign-derived intangible income contradicted a long-standing interpretation by courts, which have required a connection between expenses and gross income for which a deduction is allowed, the company told the U.S. Tax Court.
MTC Partnership Tax Group Eyes Sales Of Interests, Assets
As the Multistate Tax Commission group working on uniform rules for the state taxation of partnerships finalizes its draft combined model act, it will turn next to researching ways for states to tax sales of partnership interests or assets, tax professionals said Wednesday.
Treasury Asked To Narrow Crackdown On Fund Strategies
The U.S. Treasury Department should develop targeted rules distinguishing abusive transactions from long-standing investment management practices in new enforcement that scrutinizes novel strategies exploiting the tax benefits of certain investment vehicles and financial products, firms and organizations told the department.
Texas Instruments Asks Court To Reject IRS Stance On FDII
The IRS' reduction of Texas Instruments' deduction for foreign-derived intangible income contradicted a long-standing interpretation by courts, which have required a connection between expenses and gross income for which a deduction is allowed, the company told the U.S. Tax Court.
MTC Partnership Tax Group Eyes Sales Of Interests, Assets
As the Multistate Tax Commission group working on uniform rules for the state taxation of partnerships finalizes its draft combined model act, it will turn next to researching ways for states to tax sales of partnership interests or assets, tax professionals said Wednesday.
Federal More
The U.K. government issued its first budget under a new prime minister in October and is looking to the banking industry to boost revenue, while in the U.S., a dispute over a Minnesota medical device company's... (more story)
In close cases where there’s room for discretion, artificial intelligence could challenge judges’ implicit biases by running counterfactual tests at scale — but any judicial use of such tools would need guardr... (more story)
Buchalter PC's rapid growth in Texas continues with the addition of a Dallas-based tax partner who came aboard from Jackson Walker LLP.
In this week's Taxation with Representation, Blackstone, Bank of America, Citi and Morgan Stanley announce a financing structure to buy Broadcom artificial intelligence chips and network components for Anthrop... (more story)
The Internal Revenue Service violated federal law by terminating its collective bargaining agreement with a union representing the agency's employees in light of a 2025 executive order from President Donald Tr... (more story)
A German manufacturer challenging a $1.2 million tax bill stemming from late information filings with the IRS told the U.S. Tax Court it should be able to claim deductions and credits despite missing the statu... (more story)
The IRS never published data showing that microcaptive transactions pose a potential for tax avoidance to justify a rule making companies and advisers report them as "transactions of interest," a tax consultan... (more story)
State & Local More
Wishing A Rate Would Stay The Same: SALT In Review
From a proposed move toward graduated income tax rates in Pennsylvania to a Missouri amendment intended to eliminate all taxes there, RSM's David Brunori offers his thoughts on noteworthy state and local tax news.
Missouri, Louisiana Sued By Prediction Market Giants
Missouri and Louisiana are the latest states to become embroiled in litigation with event contract platforms, after Kalshi and Polymarket sued them, respectively, to prevent pending enforcement action.
Electronics Maker Says $48.5M Tax Suit Wrongly Tossed
Electronics manufacturer Flex Ltd. urged the Delaware Supreme Court on Wednesday to revive its bid for a $48.5 million tax distribution from its Nextracker Inc. spinoff, arguing the companies' agreements entit... (more story)
Microsoft Seeks $115M NJ Refund Over GILTI Apportionment
New Jersey unconstitutionally apportioned Microsoft's global intangible low-taxed income by failing to account for the activities of foreign entities that generated those earnings, the company argued in asking... (more story)
Idaho Co. Owed Corp. Tax Refund, High Court Affirms
An Idaho district court correctly found that a company was owed a corporate tax refund because the Legislature intended the effective date for the state's new lower tax rate to have a retroactive effect, the s... (more story)
3 Strategies To Reduce AI Sycophancy In Legal Work
The tendency of generative artificial intelligence models to tell users what they want to hear can reinforce attorneys’ confirmation bias when testing the strength of arguments, and it can’t simply be prompted... (more story)
Ariz. Court OKs Local Sales Tax Passed By Simple Majority
An Arizona appeals court rejected a challenge to a local sales tax enacted via ballot measure in 2024, disagreeing with taxpayers who claimed the ballot proposal was a referendum that required 60% approval.
From a proposed move toward graduated income tax rates in Pennsylvania to a Missouri amendment intended to eliminate all taxes there, RSM's David Brunori offers his thoughts on noteworthy state and local tax news.
Missouri and Louisiana are the latest states to become embroiled in litigation with event contract platforms, after Kalshi and Polymarket sued them, respectively, to prevent pending enforcement action.
Electronics manufacturer Flex Ltd. urged the Delaware Supreme Court on Wednesday to revive its bid for a $48.5 million tax distribution from its Nextracker Inc. spinoff, arguing the companies' agreements entit... (more story)
New Jersey unconstitutionally apportioned Microsoft's global intangible low-taxed income by failing to account for the activities of foreign entities that generated those earnings, the company argued in asking... (more story)
An Idaho district court correctly found that a company was owed a corporate tax refund because the Legislature intended the effective date for the state's new lower tax rate to have a retroactive effect, the s... (more story)
The tendency of generative artificial intelligence models to tell users what they want to hear can reinforce attorneys’ confirmation bias when testing the strength of arguments, and it can’t simply be prompted... (more story)
An Arizona appeals court rejected a challenge to a local sales tax enacted via ballot measure in 2024, disagreeing with taxpayers who claimed the ballot proposal was a referendum that required 60% approval.
International More
Frasers Unit Loses £5.6M VAT Dispute Over Marketing Photos
A Frasers Group unit lost its bid to overturn assessments that it owed value-added tax of £5.6 million ($7.4 million) when a London court ruled that the company's marketing photos were linked to taxable retail... (more story)
Wyo. Court Flags AI Use In Defamation Case Against Tax Atty
A Wyoming federal judge threatened sanctions against an exiled U.K. financial services provider who is suing a tax attorney for defamation, noting the businessman's filings indicate the use of artificial intel... (more story)
FCA Urged To Probe Possible Leak Of Bank-Tax Budget Plans
The parliamentary Treasury Committee asked HM Treasury and the Financial Conduct Authority on Thursday to investigate whether confidential details of the government's planned bank tax increase were improperly ... (more story)
Pitney Bowes Denied Interest In Repatriation Tax Fight
The IRS doesn't owe interest to Pitney Bowes for overpaid 2017 federal income taxes, the U.S. Court of Federal Claims held, finding the agency was allowed to apply a chunk of the overpayment to the global ship... (more story)
Judge Sides With Feds In Pair's $1.6M Tax Penalty Dispute
A formerly married couple are not entitled to claim a refund of roughly $1.6 million for tax penalties related to a foreign trust, a Pennsylvania federal magistrate judge ruled, finding the court lacks jurisdi... (more story)
CBP Clears Nearly 16M Imports In 3rd Tariff Refund Phase
In just over two weeks, U.S. Customs and Border Protection has cleared nearly 16 million more imports as part of the third phase of its tariff refund system, according to a declaration filed by a CBP official ... (more story)
Nigerian Man Extradited For $100 Million IRS Refund Scheme
A Nigerian man facing charges that he obtained more than $100 million in tax refunds fraudulently by posing as tax professionals and taxpayers was arraigned after being extradited from Benin, the U.S. Departme... (more story)
A Frasers Group unit lost its bid to overturn assessments that it owed value-added tax of £5.6 million ($7.4 million) when a London court ruled that the company's marketing photos were linked to taxable retail... (more story)
A Wyoming federal judge threatened sanctions against an exiled U.K. financial services provider who is suing a tax attorney for defamation, noting the businessman's filings indicate the use of artificial intel... (more story)
The parliamentary Treasury Committee asked HM Treasury and the Financial Conduct Authority on Thursday to investigate whether confidential details of the government's planned bank tax increase were improperly ... (more story)
The IRS doesn't owe interest to Pitney Bowes for overpaid 2017 federal income taxes, the U.S. Court of Federal Claims held, finding the agency was allowed to apply a chunk of the overpayment to the global ship... (more story)
A formerly married couple are not entitled to claim a refund of roughly $1.6 million for tax penalties related to a foreign trust, a Pennsylvania federal magistrate judge ruled, finding the court lacks jurisdi... (more story)
In just over two weeks, U.S. Customs and Border Protection has cleared nearly 16 million more imports as part of the third phase of its tariff refund system, according to a declaration filed by a CBP official ... (more story)
A Nigerian man facing charges that he obtained more than $100 million in tax refunds fraudulently by posing as tax professionals and taxpayers was arraigned after being extradited from Benin, the U.S. Departme... (more story)