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.
UK Gov't To Temporarily Raise Bank Surcharge To 6%
The U.K.'s Labour government will temporarily raise the bank surcharge to 6% to help generate more revenue to cover its expanded spending plans, Chancellor John Healey said in his autumn Budget on Wednesday.
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.
UK Gov't To Temporarily Raise Bank Surcharge To 6%
The U.K.'s Labour government will temporarily raise the bank surcharge to 6% to help generate more revenue to cover its expanded spending plans, Chancellor John Healey said in his autumn Budget on Wednesday.
Federal More
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)
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)
An Alabama tax preparation business owner and several of her employees participated in a scheme to submit false tax returns to the IRS seeking more than $177 million in fraudulent federal tax refunds, federal ... (more story)
A Washington Court of Appeals panel has reinstated a real estate company's challenge to a string of Seattle landlord-tenant laws, finding the firm has adequately detailed how the contested ordinances stunted i... (more story)
A Seattle restaurant owner was sentenced to 13 months in prison and three years of supervised release for willfully failing to pay more than $1.4 million in unemployment, Social Security and Medicare taxes, so... (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)
State & Local More
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.
Ex-Pa. Senator Wrongly Convicted Over Tax, 3rd Circ. Told
The U.S. Tax Court erred when it found a former Pennsylvania state senator responsible for losses to the state's Senate, he told the Third Circuit, arguing that the lower court incorrectly determined that exce... (more story)
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.
The U.S. Tax Court erred when it found a former Pennsylvania state senator responsible for losses to the state's Senate, he told the Third Circuit, arguing that the lower court incorrectly determined that exce... (more story)
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)
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)
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)
Pillar 2 Minimum Tax Funds Could Finance EU Budget
A coming draft of the European Union's next long-term budget could propose using Pillar Two funds as a revenue source to finance the bloc's spending priorities, three EU officials told Law360 on Wednesday.
Healey Looks To Simplify But Not Abolish Shareholder Taxes
Chancellor John Healey told MPs on Wednesday that the government would retain stamp duty on share trading but pledged to modernize the tax, drawing criticism of a "missed opportunity" to revive interest in the... (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)
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)
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)
A coming draft of the European Union's next long-term budget could propose using Pillar Two funds as a revenue source to finance the bloc's spending priorities, three EU officials told Law360 on Wednesday.
Chancellor John Healey told MPs on Wednesday that the government would retain stamp duty on share trading but pledged to modernize the tax, drawing criticism of a "missed opportunity" to revive interest in the... (more story)