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Colo. S Corp. Division Not Unitary Business, Calif. OTA Says
The beverage division of a Colorado-based S corporation did not operate as a unitary business with the S corporation's other divisions, the California Office of Tax Appeals said Tuesday, reversing the finding of the state tax agency.
DC Circ. Affirms Injunction Against IRS-ICE Data Sharing
The D.C. Circuit affirmed a lower court's preliminary injunction Tuesday barring the IRS from sharing taxpayer data with immigration authorities, finding that the coalition challenging the deal has standing and that the arrangement likely violates the law.
EU Figure Defends Tax Data Guards Amid Exchange Concerns
Amid criticism that taxpayer privacy is not sufficiently protected, a European Union tax official said Tuesday that the bloc has strong measures in place to address data-protection breaches and protect taxpayers, such as the suspension of information sharing between member states.
Federal More
The IRS is misusing a regulatory example that is unrelated to its argument that Eaton cannot pay foreign affiliates for support that a lender would assume exists in the agency's bid to reduce related-party int... (more story)
Jonathan Westreich joined Simpson Thacher & Bartlett LLP as a tax partner in its Los Angeles office, the firm announced Tuesday, deepening the firm's sports, media and entertainment bench.
Canadian Prime Minister Mark Carney defended Canada's retaliatory tariffs against the U.S. as they went into effect Tuesday, saying they are needed to protect Canadian workers and industries from President Don... (more story)
A Virginia federal magistrate judge ordered the Trump administration Friday to move quickly in turning over documents connected to its proposed "Anti-Weaponization Fund," including the names of those who struc... (more story)
Reality television stars Todd and Julie Chrisley asked a Georgia federal judge on Friday to reject an attempt by their former attorneys to dismiss a legal malpractice lawsuit that claims a critical pretrial mi... (more story)
The Fourth Circuit affirmed a $2.9 million fine Friday against a Hong Kong-based U.S. businessman, holding that he should have known there was a "grave risk" of inaccurate tax filings when he failed to disclos... (more story)
The Internal Revenue Service was wrong to disallow two conservation easement deductions worth a combined $78 million based on potential mining activity without adequately explaining why, an Alabama real estate... (more story)
State & Local More
Colo. County Repeating Illegal Valuation, Airport Lessee Says
Tax valuations of improvements to property at a Colorado airport possessed through a leasehold interest were wrongly imposed despite substantial legal precedent, the leaseholder told a state court, urging it t... (more story)
Ohio Bill Would Bar Property Tax Breaks For Data Centers
Ohio would prohibit new property tax breaks for data centers, including facilities used for mining cryptocurrency, under legislation introduced in the state House.
Credit Where It Is Due: SALT In Review
From the Texas comptroller's plan to reform his state's tax system to the reduction of an income tax credit in New York City, RSM's David Brunori offers his thoughts on noteworthy state and local tax news.
Neb. Justices Urged To Allow $16M Gains Exclusion For Trust
A trust set up by a former Union Pacific executive should receive a $16 million capital gains exclusion despite the shares at issue being indirectly transferred to the trust as part of a corporation, the Nebra... (more story)
NJ Urges Justices To Resolve Kalshi Sports Betting Split
New Jersey regulators on Wednesday asked the U.S. Supreme Court to address the newly emerged circuit split around prediction market regulation, filing a long-awaited petition that challenged a Third Circuit de... (more story)
Fla. Defends Airline Tax Method Targeted By JetBlue
A Florida state court was right to reject JetBlue's challenges to the state's method for apportionment of airline income, including receipts from flights over offshore areas, the state Department of Revenue to... (more story)
Biz Groups Ask Texas Justices To Bar Tax On Stored Oil
If the Texas Supreme Court rules that counties can levy personal property tax on oil slated for export, the decision could be damaging to the state's economy and a boon for other states, the U.S. Chamber of Co... (more story)
Tax valuations of improvements to property at a Colorado airport possessed through a leasehold interest were wrongly imposed despite substantial legal precedent, the leaseholder told a state court, urging it t... (more story)
Ohio would prohibit new property tax breaks for data centers, including facilities used for mining cryptocurrency, under legislation introduced in the state House.
From the Texas comptroller's plan to reform his state's tax system to the reduction of an income tax credit in New York City, RSM's David Brunori offers his thoughts on noteworthy state and local tax news.
A trust set up by a former Union Pacific executive should receive a $16 million capital gains exclusion despite the shares at issue being indirectly transferred to the trust as part of a corporation, the Nebra... (more story)
New Jersey regulators on Wednesday asked the U.S. Supreme Court to address the newly emerged circuit split around prediction market regulation, filing a long-awaited petition that challenged a Third Circuit de... (more story)
A Florida state court was right to reject JetBlue's challenges to the state's method for apportionment of airline income, including receipts from flights over offshore areas, the state Department of Revenue to... (more story)
If the Texas Supreme Court rules that counties can levy personal property tax on oil slated for export, the decision could be damaging to the state's economy and a boon for other states, the U.S. Chamber of Co... (more story)
International More
Aussie Tax Office Issues Royalty Guidance After Pepsi Ruling
The Australian Taxation Office published guidance covering situations when intercompany payments under software arrangements constitute taxable royalties, including definitions that incorporate a 2025 decision... (more story)
Biotech Company Pays £7.4M To Settle Russia Export Breach
The U.K. arm of an international genome sequencing company has paid a record £7.4 million ($10 million) for breaching export controls after it admitted to supplying sanctioned goods to Russia, HM Revenue & Cus... (more story)
Healey Won't Rule Out Tax Hikes Despite Business Demands
Chancellor John Healey declined on Monday to rule out tax hikes in the autumn Budget statement despite demands from industry groups to reduce the fiscal pressure on businesses.
EU Nations Fear Digital Tax Backlash Ahead of Budget Crunch
A number of European Union countries oppose the inclusion of a bloc-wide digital services tax in the EU's long-term budget because of its potential to aggravate geopolitical tensions, according to a Council of... (more story)
Spain Calls For EU Energy Firm Tax To Fund Climate Action
Spain called on the European Union to consider a levy on the profits of oil and gas companies to fund the region's response to the climate crisis, according to a letter and policy paper seen Friday by Law360.
EU Countries Bristle At Tax Avoidance Rule Proposal
European Union member states are concerned that proposed changes to anti-tax avoidance rules, such as those that relate to how much interest companies can deduct from taxable profits, may result in revenue los... (more story)
Canadian Group Can't Blend Insurance Businesses' Income
A fraternal benefit society cannot blend its life insurance and accident insurance businesses for tax purposes, Canada's Federal Court of Appeal said, setting aside a lower court's decision.
The Australian Taxation Office published guidance covering situations when intercompany payments under software arrangements constitute taxable royalties, including definitions that incorporate a 2025 decision... (more story)
The U.K. arm of an international genome sequencing company has paid a record £7.4 million ($10 million) for breaching export controls after it admitted to supplying sanctioned goods to Russia, HM Revenue & Cus... (more story)
Chancellor John Healey declined on Monday to rule out tax hikes in the autumn Budget statement despite demands from industry groups to reduce the fiscal pressure on businesses.
A number of European Union countries oppose the inclusion of a bloc-wide digital services tax in the EU's long-term budget because of its potential to aggravate geopolitical tensions, according to a Council of... (more story)
Spain called on the European Union to consider a levy on the profits of oil and gas companies to fund the region's response to the climate crisis, according to a letter and policy paper seen Friday by Law360.
European Union member states are concerned that proposed changes to anti-tax avoidance rules, such as those that relate to how much interest companies can deduct from taxable profits, may result in revenue los... (more story)
A fraternal benefit society cannot blend its life insurance and accident insurance businesses for tax purposes, Canada's Federal Court of Appeal said, setting aside a lower court's decision.