Int'l Tax In October: UK Targets Banks, US Nixes Spinoff Rule
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 pricing with a Puerto Rican affiliate could require a third Tax Court trial after settlement talks failed. Here, Law360 looks at the top international tax developments from the past month.
Billionaire Tax Headlines Calif. Tax Ballot Measures
Of the many state and local tax measures voters will see on their ballots Tuesday, none is poised to have a greater impact than California's Proposition 40, which would levy the nation's first-ever tax on the wealth of billionaires.
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.
Int'l Tax In October: UK Targets Banks, US Nixes Spinoff Rule
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 pricing with a Puerto Rican affiliate could require a third Tax Court trial after settlement talks failed. Here, Law360 looks at the top international tax developments from the past month.
Billionaire Tax Headlines Calif. Tax Ballot Measures
Of the many state and local tax measures voters will see on their ballots Tuesday, none is poised to have a greater impact than California's Proposition 40, which would levy the nation's first-ever tax on the wealth of billionaires.
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.
Federal More
Tax software company Avalara did not illegally lure six workers away from a company acquired by rival Vertex, a Pennsylvania federal jury decided, clearing Avalara of trade secrets theft.
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)
An automobile racing mogul's estate asked the Tax Court to spike a $58.3 million estate tax deficiency, alleging that the IRS erred in revaluing its equity holdings.
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)
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)
State & Local More
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)
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)
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)
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)
International More
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)
German Co. Says $1.2M IRS Tax Bill Rests On Invalid Rule
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)
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)
Tax Consultancy Asks 5th Circ. To Kill Microcaptive Rule
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)
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)
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)
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)
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 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)
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)