Calif. LLC Must Report Allocated Income, OTA Says
A California owner of a limited liability company that held an ownership interest in a partnership is required to recognize all the income allocated to it even though the distributions it received are lower than the allocation, the state Office of Tax Appeals said.
Buy.com Founder On Hook For $16M Tax Bill, 10th Circ. Says
The founder of Buy.com waited too long to challenge a nearly $16 million tax bill tied to his former partnership's investments, the Tenth Circuit ruled Monday, holding that the window had closed by the time the IRS assessed partner-level liabilities.
UK Probes Boston Consulting's Partner Pay After Court Ruling
HM Revenue & Customs is investigating how Boston Consulting Group's U.K. arm treats partners for income tax purposes, the company disclosed after a U.K. Supreme Court ruling allowing a hedge fund's managers to be taxed as employees.
Calif. LLC Must Report Allocated Income, OTA Says
A California owner of a limited liability company that held an ownership interest in a partnership is required to recognize all the income allocated to it even though the distributions it received are lower than the allocation, the state Office of Tax Appeals said.
Buy.com Founder On Hook For $16M Tax Bill, 10th Circ. Says
The founder of Buy.com waited too long to challenge a nearly $16 million tax bill tied to his former partnership's investments, the Tenth Circuit ruled Monday, holding that the window had closed by the time the IRS assessed partner-level liabilities.
UK Probes Boston Consulting's Partner Pay After Court Ruling
HM Revenue & Customs is investigating how Boston Consulting Group's U.K. arm treats partners for income tax purposes, the company disclosed after a U.K. Supreme Court ruling allowing a hedge fund's managers to be taxed as employees.
Federal More
The U.S. Tax Court properly dismissed a partnership's bid to challenge the IRS' denial of a $27 million tax deduction for a Georgia conservation easement donation, the agency told the Eleventh Circuit, saying ... (more story)
Peter Schuur, chair of Debevoise & Plimpton LLP's global tax practice, steered the tax strategy for Warner Bros. Discovery's $110 billion sale to Paramount Skydance, earning him a spot as one of the 2026 Law360 Tax MVPs.
Latham & Watkins LLP has hired a former Morgan Lewis & Bockius LLP partner who spent 16 years with his previous firm working on tax and employee benefits issues.
A Washington federal judge said Monday that an Xbox buyer must arbitrate his claims that Microsoft unjustly pocketed refunds meant for consumers after the U.S. Supreme Court struck down the Trump administratio... (more story)
The skilled manufacturing that took place at Eaton's plants in Puerto Rico and the Dominican Republic from 2011 through 2013 was the critical factor in the success of the company's electrical breaker products ... (more story)
The IRS' nonprofit donor disclosure rule violates organizations' and donors' First Amendment rights, a privacy group told a D.C. federal court, saying the rule is subject to a heightened level of judicial scru... (more story)
Michael Cannon, a partner in Gibson Dunn & Crutcher LLP's Dallas office, co-led the tax team advising SpaceX on its pivotal transactions that wrapped up this year, including the largest initial public offering... (more story)
State & Local More
Law360 MVP Awards Go To Top Attorneys From 89 Firms
The lawyers chosen as Law360's 2026 MVPs stand out from their peers by notching significant achievements in high-stakes litigation, complex global matters and record-setting transactions.
Colo. Justices Keep Graduated Income Tax Measure On Ballot
The Colorado Supreme Court Friday affirmed the dismissal of a man's complaint seeking to have an initiative to raise taxes on the state's wealthiest residents removed from the ballot due to some petition entit... (more story)
Hedge Fund Exec Fights $40M In IRS Foreign Reporting Fines
A hedge fund manager is seeking to recover nearly $40 million in foreign account reporting penalties, telling the U.S. Court of Federal Claims that the IRS violated his due process rights and administrative ru... (more story)
Mo. Court Rejects Challenge To Property Tax Increase Caps
A challenge to voter-approved local caps on residential property tax hikes in Missouri was struck down by a state circuit court, which found the taxpayers and taxing authorities involved did not have standing ... (more story)
How AI Could Help Judges Spot Their Own Biases
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 Adds Tax Pro In Dallas From Jackson Walker
Buchalter PC's rapid growth in Texas continues with the addition of a Dallas-based tax partner who came aboard from Jackson Walker LLP.
3 Ways Burgeoning AI Use Can Trip Up Benefits Providers
As the use of artificial intelligence in the employee benefits space grows, experts warn that companies need to be vigilant to guard against mishaps caused by the emerging technology. Here, Law360 looks at thr... (more story)
The lawyers chosen as Law360's 2026 MVPs stand out from their peers by notching significant achievements in high-stakes litigation, complex global matters and record-setting transactions.
The Colorado Supreme Court Friday affirmed the dismissal of a man's complaint seeking to have an initiative to raise taxes on the state's wealthiest residents removed from the ballot due to some petition entit... (more story)
A hedge fund manager is seeking to recover nearly $40 million in foreign account reporting penalties, telling the U.S. Court of Federal Claims that the IRS violated his due process rights and administrative ru... (more story)
A challenge to voter-approved local caps on residential property tax hikes in Missouri was struck down by a state circuit court, which found the taxpayers and taxing authorities involved did not have standing ... (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.
As the use of artificial intelligence in the employee benefits space grows, experts warn that companies need to be vigilant to guard against mishaps caused by the emerging technology. Here, Law360 looks at thr... (more story)
International More
EU Tax Reporting Break Would Send 'Worst Signal,' Panel Told
Multinational companies shouldn't get a free pass on reporting potentially harmful cross-border tax arrangements to European Union countries because they're within the scope of the 15% global minimum tax, an E... (more story)
£3M In Taxes Axed In Fight Over 'Gaming Machine' Definition
A London appeals court struck down HM Revenue & Customs' nearly £3.3 million ($4.4 million) in tax assessments against arcade and bingo hall operators, holding the companies had justifiable grounds for misunde... (more story)
EU Official Defends US Exclusion From Reporting Carveout
Member states currently negotiating the European Union's tax simplification proposals should not allow U.S.-headquartered companies operating under the side-by-side agreement of the global minimum tax framewor... (more story)
Former Ecclestone Family Lawyer Denies Tax Fraud Charge
A former solicitor and adviser to Bernie Ecclestone, the ex-chief executive of Formula One, pleaded not guilty to tax fraud in London on Tuesday over allegations that he lied to HM Revenue and Customs about hi... (more story)
EU Draft Says Pillar 2 Reporting Carveout Could End In 2033
A draft bill on tax information exchange in the European Union proposes that a previously suggested reporting carveout for large multinationals should last only until January 2033 unless an extension is justif... (more story)
Brookfield Fights $4.3M Tax Bill Over Lehman Losses
Asset management giant Brookfield is challenging a $4.3 million tax bill tied to its acquisition of a defunct Lehman Brothers unit, telling the U.S. Tax Court that the IRS incorrectly denied a deduction stemmi... (more story)
EU, Canada Seal Digital Trade Deal Amid Closer Partnership
EU and Canadian officials signed a document Friday concluding negotiations on a digital trade agreement between the two economies following a summit in Montreal where Canadian and European leaders shared new d... (more story)
Multinational companies shouldn't get a free pass on reporting potentially harmful cross-border tax arrangements to European Union countries because they're within the scope of the 15% global minimum tax, an E... (more story)
A London appeals court struck down HM Revenue & Customs' nearly £3.3 million ($4.4 million) in tax assessments against arcade and bingo hall operators, holding the companies had justifiable grounds for misunde... (more story)
Member states currently negotiating the European Union's tax simplification proposals should not allow U.S.-headquartered companies operating under the side-by-side agreement of the global minimum tax framewor... (more story)
A former solicitor and adviser to Bernie Ecclestone, the ex-chief executive of Formula One, pleaded not guilty to tax fraud in London on Tuesday over allegations that he lied to HM Revenue and Customs about hi... (more story)
A draft bill on tax information exchange in the European Union proposes that a previously suggested reporting carveout for large multinationals should last only until January 2033 unless an extension is justif... (more story)
Asset management giant Brookfield is challenging a $4.3 million tax bill tied to its acquisition of a defunct Lehman Brothers unit, telling the U.S. Tax Court that the IRS incorrectly denied a deduction stemmi... (more story)
EU and Canadian officials signed a document Friday concluding negotiations on a digital trade agreement between the two economies following a summit in Montreal where Canadian and European leaders shared new d... (more story)