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6th Circ. Wrestles with TCJA In FedEx's $89M Tax Refund Case
A Sixth Circuit panel grappled Thursday with how to interpret interactions between the 2017 federal tax overhaul and the Internal Revenue Code's long-standing regime for offshore income as the judges weighed FedEx's bid for a tax refund of over $89 million.
MTC Draft Tackles State Partnership Tax Rules Vacuum
The Multistate Tax Commission has spent the past five years building an expansive framework for partnership taxation precisely because state law in this area is fragmented, underdeveloped and no match for the complexity of modern pass‑through structures, state tax professionals said Thursday.
EU Electricity Tax Proposal Lacks Legal Basis, Germany Says
A European Union proposal to put an electricity tax change to a majority vote — rather than seeking member states' unanimous approval — is likely illegal and should therefore be dropped, according to a letter written by a German government official and seen Thursday by Law360.
6th Circ. Wrestles with TCJA In FedEx's $89M Tax Refund Case
A Sixth Circuit panel grappled Thursday with how to interpret interactions between the 2017 federal tax overhaul and the Internal Revenue Code's long-standing regime for offshore income as the judges weighed FedEx's bid for a tax refund of over $89 million.
MTC Draft Tackles State Partnership Tax Rules Vacuum
The Multistate Tax Commission has spent the past five years building an expansive framework for partnership taxation precisely because state law in this area is fragmented, underdeveloped and no match for the complexity of modern pass‑through structures, state tax professionals said Thursday.
EU Electricity Tax Proposal Lacks Legal Basis, Germany Says
A European Union proposal to put an electricity tax change to a majority vote — rather than seeking member states' unanimous approval — is likely illegal and should therefore be dropped, according to a letter written by a German government official and seen Thursday by Law360.
Federal More
The Senate Finance Committee approved a wide-ranging bipartisan package Thursday that would implement a slew of changes intended to improve taxpayer service, including a mandate that the agency digitize more t... (more story)
As of July 1, Florida business owners can create protected series LLCs to shield assets from liability while avoiding increased costs and wasted time, but burdensome recordkeeping obligations are crucial to ma... (more story)
With Sens. John Cornyn, R-Texas, and Thom Tillis, R-N.C., still on the fence about acting Attorney General Todd Blanche's confirmation to be attorney general, President Donald Trump said Thursday he might reno... (more story)
New York prosecutors told a state appellate court that President Donald Trump's 34-count felony conviction for falsifying business records is "unaffected" by the U.S. Supreme Court's watershed presidential imm... (more story)
A New York trial judge erred in rejecting a retirement-fund garnishment deal that would have protected Martin Shkreli's convicted former lawyer from tax penalties, the Second Circuit ruled Wednesday.
The U.S. Supreme Court’s recent decision in Pung v. Isabella County, Michigan, that taxpayers are not entitled to fair market value of real property seized to satisfy a tax debt shifts attention to the fairnes... (more story)
Democrats in the Senate Finance Committee introduced legislation Wednesday that they said would officially sink the portion of President Donald Trump's settlement of his suit against the IRS that grants him im... (more story)
State & Local More
MTC On Track To Approve Updated Airline Tax Rule, Atty Says
The Multistate Tax Commission appears to have approved updating a sourcing regulation for airlines to account for income generated from Wi-Fi access and other modern activities, an MTC attorney told Law360 on ... (more story)
Kalshi Sports Offerings Appear On Shaky Ground At 6th Circ.
A Sixth Circuit panel looked askance at Kalshi's push to have its sports event contracts shielded from state gambling regulators Thursday, pointedly questioning the prediction market giant about the difference... (more story)
Property's $108M Valuation Unfounded, Minn. Justices Told
The Minnesota Tax Court's $108 million valuation of a Minneapolis office building is not backed by the evidence, the building owner told the Minnesota Supreme Court, asserting that the local assessor's apprais... (more story)
Bressler Grows In Northeast, Southeast With Atty Trio Hire
Bressler Amery & Ross PC announced Wednesday that the firm has added three attorneys in Alabama, Florida and New Jersey to bolster its capabilities in commercial litigation, insurance defense, tax, trusts and estates.
4 Firms Steer Grant Thornton's $5B Agreement To Buy CBIZ
New Mountain Capital-backed Grant Thornton Advisors said Wednesday it has agreed to acquire CBIZ Inc. in a deal worth $5 billion, including debt, that would create a top-five U.S. provider of professional, tax... (more story)
States' Patchwork Digital Taxes Spur MTC Guide Plan
States are trying so many ways to tax digital media and online products that the Multistate Tax Commission will plan to create a briefing book explaining what the taxes are, how states have implemented them an... (more story)
MTC Group Nears Model Act On State Partnership Taxes
The Multistate Tax Commission group working on uniform rules for the state taxation of partnerships said Tuesday that it is preparing a combined draft model act that focuses on investment partnerships, guarant... (more story)
The Multistate Tax Commission appears to have approved updating a sourcing regulation for airlines to account for income generated from Wi-Fi access and other modern activities, an MTC attorney told Law360 on ... (more story)
A Sixth Circuit panel looked askance at Kalshi's push to have its sports event contracts shielded from state gambling regulators Thursday, pointedly questioning the prediction market giant about the difference... (more story)
The Minnesota Tax Court's $108 million valuation of a Minneapolis office building is not backed by the evidence, the building owner told the Minnesota Supreme Court, asserting that the local assessor's apprais... (more story)
Bressler Amery & Ross PC announced Wednesday that the firm has added three attorneys in Alabama, Florida and New Jersey to bolster its capabilities in commercial litigation, insurance defense, tax, trusts and estates.
New Mountain Capital-backed Grant Thornton Advisors said Wednesday it has agreed to acquire CBIZ Inc. in a deal worth $5 billion, including debt, that would create a top-five U.S. provider of professional, tax... (more story)
States are trying so many ways to tax digital media and online products that the Multistate Tax Commission will plan to create a briefing book explaining what the taxes are, how states have implemented them an... (more story)
The Multistate Tax Commission group working on uniform rules for the state taxation of partnerships said Tuesday that it is preparing a combined draft model act that focuses on investment partnerships, guarant... (more story)
International More
Perenco Beats HMRC's Challenge Of £39M In Tax Allowances
British oil company Perenco is entitled to tax allowances of £39 million ($52.5 million) on the purchase of BP oilfields even though it agreed to sell part of the sites to Premier Oil days later, a London trib... (more story)
Airbus Pays HMRC £6.4M Over Export Control Breaches
Aerospace giant Airbus reached an agreement with the U.K. tax authority to pay £6.4 million ($8.6 million) to settle claims that the company breached export control rules, the agency announced Thursday.
CORRECTED: Tipster's Info Didn't Aid IRS Audit Of Co., DC Circ. Told
The Internal Revenue Service appropriately denied a whistleblower award to an individual alleging that a company underpaid taxes by not following transfer pricing regulations, the U.S. government told the D.C.... (more story)
Burnham Not Ruling Out Tax Hikes For Social Care Plan
U.K. Prime Minister Andy Burnham declined Wednesday to rule out tax hikes to recoup the costs of a new national care service to address problems related to social care in Britain.
Trade Unions Urge Burnham Toward Higher Taxes On Banks
U.K. Prime Minister Andy Burnham should back higher taxes on banks following Barclays Group's financial results, a group of trade unions urged Tuesday.
Tax Court Ruling Doesn't Help Liberty Global, 10th Circ. Told
A recent U.S. Tax Court decision that tossed IRS regulations doesn't help Liberty Global's bid for a $2.4 billion deduction under the same statute, the federal government told the Tenth Circuit, arguing that t... (more story)
Crypto Hedge Fund Manager Gets 3 Years For Tax Evasion
A crypto hedge fund manager who renounced his U.S. citizenship and moved to the Cayman Islands was sentenced to over three years in prison for tax evasion, the U.S. Attorney's Office for the Western District o... (more story)
British oil company Perenco is entitled to tax allowances of £39 million ($52.5 million) on the purchase of BP oilfields even though it agreed to sell part of the sites to Premier Oil days later, a London trib... (more story)
Aerospace giant Airbus reached an agreement with the U.K. tax authority to pay £6.4 million ($8.6 million) to settle claims that the company breached export control rules, the agency announced Thursday.
The Internal Revenue Service appropriately denied a whistleblower award to an individual alleging that a company underpaid taxes by not following transfer pricing regulations, the U.S. government told the D.C.... (more story)
U.K. Prime Minister Andy Burnham declined Wednesday to rule out tax hikes to recoup the costs of a new national care service to address problems related to social care in Britain.
U.K. Prime Minister Andy Burnham should back higher taxes on banks following Barclays Group's financial results, a group of trade unions urged Tuesday.
A recent U.S. Tax Court decision that tossed IRS regulations doesn't help Liberty Global's bid for a $2.4 billion deduction under the same statute, the federal government told the Tenth Circuit, arguing that t... (more story)
A crypto hedge fund manager who renounced his U.S. citizenship and moved to the Cayman Islands was sentenced to over three years in prison for tax evasion, the U.S. Attorney's Office for the Western District o... (more story)