State & Local Tax Takeaways From September
Action in the state and local tax world in September was centered in courthouses in Massachusetts, Texas, California and elsewhere. Here, Law360 looks at highlights from the past month.
Int'l Tax In September: Facebook Ruling, BEAT Bill And More
September kicked off with the announcement of tariffs on semiconductors and ended with the U.S. Tax Court's long-awaited ruling on a computational dispute involving Facebook, with Siemens USA's trial and a bill that would change the U.S. base erosion and anti-abuse tax in the middle. Here, Law360 looks at some of the biggest international tax developments of the past month.
2nd Circ. Forges Own Path In Limited Partner Tax Ruling
The Second Circuit's decision limiting a self-employment tax break for limited partners with significant managerial roles reached a conclusion similar to that of a recent Fifth Circuit ruling, but practitioners said notable differences between them create a split requiring resolution by the IRS, the U.S. Supreme Court or Congress.
State & Local Tax Takeaways From September
Action in the state and local tax world in September was centered in courthouses in Massachusetts, Texas, California and elsewhere. Here, Law360 looks at highlights from the past month.
Int'l Tax In September: Facebook Ruling, BEAT Bill And More
September kicked off with the announcement of tariffs on semiconductors and ended with the U.S. Tax Court's long-awaited ruling on a computational dispute involving Facebook, with Siemens USA's trial and a bill that would change the U.S. base erosion and anti-abuse tax in the middle. Here, Law360 looks at some of the biggest international tax developments of the past month.
2nd Circ. Forges Own Path In Limited Partner Tax Ruling
The Second Circuit's decision limiting a self-employment tax break for limited partners with significant managerial roles reached a conclusion similar to that of a recent Fifth Circuit ruling, but practitioners said notable differences between them create a split requiring resolution by the IRS, the U.S. Supreme Court or Congress.
Federal More
The Department of Justice lacked the authority to reverse the IRS' abatement of a man's penalty of nearly $2.4 million for promoting abusive tax shelters after the agency realized a supervisor hadn't signed of... (more story)
A group of Democratic senators urged the U.S. Department of the Treasury to scrap proposed rules that would cut off refundable tax credits to certain immigrants living in the U.S. legally, arguing that the gui... (more story)
A Florida federal judge on Friday sentenced ex-Florida Rep. David Rivera to 10 years in prison for failing to register as a foreign agent and laundering the proceeds of a $50 million contract with a unit of Ve... (more story)
In this week's Taxation With Representation, semiconductor company Advanced Micro Devices buys AI model developer and research lab World Labs, Brixmor Property Group, and private investment management firm Eve... (more story)
A Maryland cancer research laboratory that said it had no income in 2021 is contesting IRS tax assessments totaling $4.5 million, telling the U.S. Tax Court that the government's imputing of an underpayment vi... (more story)
The Financial Crimes Enforcement Network's recently rolled-out broad exemption for U.S. companies from Corporate Transparency Act reporting may face administrative law and statutory challenges, so businesses s... (more story)
A New York federal magistrate judge gave an initial green light to a $1.05 million class settlement to resolve claims brought by tax preparers who accused a New York tax preparation company of overtime and wag... (more story)
State & Local More
NJ Tax Court Axes Challenge To Internet Activity Tax Rules
The New Jersey Tax Court tossed a trade group's challenge to the state's regulations that outline when an out-of-state company's internet activities exceed a federal law's protections against state income taxe... (more story)
Signatures For Colo. Graduated Tax Plan Valid, Court Told
Signature gatherers for a Colorado ballot measure for graduated income tax rates followed all state laws aimed at preventing fraud, election officials and the measure's backers told a state court, urging it to... (more story)
The Courts Are There For A Reason: SALT In Review
From a challenge to Illinois' taxing of digital advertising and social media to the Montana governor's call for a flat income tax, RSM's David Brunori offers his thoughts on noteworthy state and local tax news.
Kilpatrick Adds Ex-Barnes & Thornburg Tax Partner
Kilpatrick has hired a former Barnes & Thornburg LLP attorney who is experienced in transactional law as a partner on its employee benefits and tax team and co-chair of its federal tax practice.
DC Says Rail Fee Doesn't Favor Local Carriers Over Others
The Office of Attorney General for the District of Columbia has urged a federal judge to uphold its annual per-car fee on railroads against a challenge from the freight industry, arguing the charge is valid un... (more story)
What's Next For Prediction Markets If States Win At High Court
While the Supreme Court hasn't taken up a prediction market case yet, a high court win for the states in their quest to regulate the exchanges would likely mean a wave of state legislature bills and regulatory... (more story)
AI Meeting Recaps Pose New Discovery And Privilege Risks
The New York City Bar Association’s recent ethics opinion, cautioning attorneys not to record nonclient conversations with artificial intelligence tools, reflects an emerging view that AI meeting recaps are no... (more story)
The New Jersey Tax Court tossed a trade group's challenge to the state's regulations that outline when an out-of-state company's internet activities exceed a federal law's protections against state income taxe... (more story)
Signature gatherers for a Colorado ballot measure for graduated income tax rates followed all state laws aimed at preventing fraud, election officials and the measure's backers told a state court, urging it to... (more story)
From a challenge to Illinois' taxing of digital advertising and social media to the Montana governor's call for a flat income tax, RSM's David Brunori offers his thoughts on noteworthy state and local tax news.
Kilpatrick has hired a former Barnes & Thornburg LLP attorney who is experienced in transactional law as a partner on its employee benefits and tax team and co-chair of its federal tax practice.
The Office of Attorney General for the District of Columbia has urged a federal judge to uphold its annual per-car fee on railroads against a challenge from the freight industry, arguing the charge is valid un... (more story)
While the Supreme Court hasn't taken up a prediction market case yet, a high court win for the states in their quest to regulate the exchanges would likely mean a wave of state legislature bills and regulatory... (more story)
The New York City Bar Association’s recent ethics opinion, cautioning attorneys not to record nonclient conversations with artificial intelligence tools, reflects an emerging view that AI meeting recaps are no... (more story)
International More
Tax Burden Costing Hospitality Jobs, Investment, Groups Say
Hospitality and retail face the highest effective tax rate of any sector in the U.K., resulting in lower investment, fewer jobs and higher prices for customers, according to a report by a retail industry group.
MPs Ask HMRC To Review Tax Implications Of Man City Case
An influential cross-party group of MPs Monday called on HM Revenue & Customs to consider any tax implications from the bombshell findings that Manchester City used "sham" contracts to boost its income by arou... (more story)
Greece Urges Looser EU Spending Limit Amid Energy VAT Lift
Greece called on the European Union to loosen its spending rules for member states, particularly given a boost in value-added tax revenue, to help countries that wish to enact energy affordability support, acc... (more story)
EU Nations Push For OECD Alignment On Platform Tax Rules
Several European Union countries said during a working group meeting that the bloc's revisions to tax data-sharing legislation for digital platforms must remain aligned with rules developed at the Organization... (more story)
UK Vape Excise Tax Comes Into Effect
The U.K. government's new tax on vapes went into effect Thursday in a bid to raise the cost of such products and reduce vaping among young people and nonsmokers, according to HM Revenue & Customs.
DOJ Outlines New Corporate Fraud Enforcement Priorities
Federal prosecutors "must place great weight" on a new list of factors when considering potential charges in corporate fraud cases, including whether the matters involve government programs, threats to nationa... (more story)
Laytons Shifts Blame In £2.6M Row Over Disputed Tax Advice
Law firm Laytons LLP has denied a claim that it cost a letting agency more than £2.6 million ($3.4 million) in tax liabilities, arguing it was never actually instructed to review offshore tax advice allegedly ... (more story)
Hospitality and retail face the highest effective tax rate of any sector in the U.K., resulting in lower investment, fewer jobs and higher prices for customers, according to a report by a retail industry group.
An influential cross-party group of MPs Monday called on HM Revenue & Customs to consider any tax implications from the bombshell findings that Manchester City used "sham" contracts to boost its income by arou... (more story)
Greece called on the European Union to loosen its spending rules for member states, particularly given a boost in value-added tax revenue, to help countries that wish to enact energy affordability support, acc... (more story)
Several European Union countries said during a working group meeting that the bloc's revisions to tax data-sharing legislation for digital platforms must remain aligned with rules developed at the Organization... (more story)
The U.K. government's new tax on vapes went into effect Thursday in a bid to raise the cost of such products and reduce vaping among young people and nonsmokers, according to HM Revenue & Customs.
Federal prosecutors "must place great weight" on a new list of factors when considering potential charges in corporate fraud cases, including whether the matters involve government programs, threats to nationa... (more story)
Law firm Laytons LLP has denied a claim that it cost a letting agency more than £2.6 million ($3.4 million) in tax liabilities, arguing it was never actually instructed to review offshore tax advice allegedly ... (more story)