Multinationals Grapple With Tariff-Induced Pricing Issues
President Donald Trump's flurry of tariff actions since taking office has created new questions for multinationals and their transfer pricing tax planners, including how to properly account for cost increases associated with new duties in related party transactions.
Uber Needed To Collect Tax Pre-Wayfair, Ga. Panel Affirms
Uber was required to collect and remit millions in sales taxes on behalf of drivers and customers who used its app before the Wayfair decision, a Georgia appellate panel held Thursday, ruling against the ride-hailing company and upholding a trial court decision.
Colo. Fees Don't Violate TABOR, Appeals Panel Says
The enterprise fees in Colorado's state transportation package passed in 2021 do not violate the state's Taxpayer Bill of Rights, a state appeals court said Thursday, upholding a district court ruling and rejecting a challenge from a conservative group.
Multinationals Grapple With Tariff-Induced Pricing Issues
President Donald Trump's flurry of tariff actions since taking office has created new questions for multinationals and their transfer pricing tax planners, including how to properly account for cost increases associated with new duties in related party transactions.
Uber Needed To Collect Tax Pre-Wayfair, Ga. Panel Affirms
Uber was required to collect and remit millions in sales taxes on behalf of drivers and customers who used its app before the Wayfair decision, a Georgia appellate panel held Thursday, ruling against the ride-hailing company and upholding a trial court decision.
Colo. Fees Don't Violate TABOR, Appeals Panel Says
The enterprise fees in Colorado's state transportation package passed in 2021 do not violate the state's Taxpayer Bill of Rights, a state appeals court said Thursday, upholding a district court ruling and rejecting a challenge from a conservative group.
Federal More
President Donald Trump has tapped a former Internal Revenue Service chief counsel to return to the role, and if he is confirmed, it will represent the second time in his career that the veteran tax controversy... (more story)
Tax crimes are historically difficult to prosecute, but the Internal Revenue Services’ recent agreement with U.S. Immigration and Customs Enforcement to share taxpayer records of non-U.S. citizens could be use... (more story)
The estate of a man whose offshore businesses were raided by the IRS, giving rise to a nearly $18 million tax judgment, criticized the agency's effort to rebuff the estate's claims to the D.C. Circuit that the... (more story)
A former FBI informant won't be released while he appeals his six-year prison sentence for tax evasion and falsely telling federal agents that a Ukrainian energy company paid off President Joe Biden and his so... (more story)
Hunter Biden dropped his suit against the federal government alleging the unauthorized disclosure of his tax return information by special agents and their attorneys who talked publicly about an investigation ... (more story)
Nelson Mullins Riley & Scarborough LLP announced Thursday that it has fortified its tax controversy and litigation team with a partner in Houston who came aboard from Porter Hedges LLP.
Crypto exchange Coinbase on Wednesday urged the U.S. Supreme Court to firm up privacy rights around digital information stored with third parties, backing a petition by a Coinbase user who's challenging the In... (more story)
State & Local More
PepsiCo Owes $2.1M In Tax Penalties, Illinois Panel Affirms
PepsiCo was correctly assessed $2.1 million in penalties for categorizing Frito-Lay expatriates' compensation as foreign payroll that would allow the company's profits to be excluded from state income tax calc... (more story)
Ore. Tax Court Retains Nix Of Microsoft Foreign Income Relief
The Oregon Tax Court is adhering to its finding on the treatment of Microsoft's repatriated foreign income when calculating its state income, making only minor changes to an earlier order and rejecting the com... (more story)
Sheppard Mullin Brings On Kirkland Tax Ace In Houston
Sheppard Mullin Richter & Hampton LLP announced Wednesday that it expanded its tax, employee benefits and trusts and estates practice with a new partner most recently with Kirkland & Ellis LLP.
Fried Frank Taps Sidley's UK Tax Head
The former head of Sidley Austin LLP's U.K. tax practice has joined Fried Frank Harris Shriver & Jacobson LLP's London office, where he will advise on U.K. and international tax structuring, the firm announced.
NJ Panel Declines To Revive Tobacco Co.'s Tax Refund Claim
A tobacco company cannot revive its claim for a tax refund, a New Jersey appeals court found, agreeing with the state's tax court that 2020 amendments to a regulation limiting a royalty add-back deduction must... (more story)
Adapting To Private Practice: From DOJ Enviro To Mid-Law
Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares the... (more story)
Bipartisan House Members Pitch Expanded Paid Family Leave
A bipartisan group of House lawmakers unveiled legislation Wednesday that they said would expand access to paid family leave by incentivizing states to establish their own programs and facilitating the exchang... (more story)
MTC Digital Work Group Backs Tax Pact's Bundling Rules
The Streamlined Sales Tax Governing Board's model for how to tax products sold in a bundle generally works well and more states should consider it, a Multistate Tax Commission work group studying how to harmon... (more story)
NY Court Upholds PL 86-272 Regulations, Bars Retroactivity
A New York rule allowing state taxation of nonsolicitation business activities over the internet isn't barred by a federal law providing limited protections against state income tax, but the rule cannot apply ... (more story)
PepsiCo was correctly assessed $2.1 million in penalties for categorizing Frito-Lay expatriates' compensation as foreign payroll that would allow the company's profits to be excluded from state income tax calc... (more story)
The Oregon Tax Court is adhering to its finding on the treatment of Microsoft's repatriated foreign income when calculating its state income, making only minor changes to an earlier order and rejecting the com... (more story)
Sheppard Mullin Richter & Hampton LLP announced Wednesday that it expanded its tax, employee benefits and trusts and estates practice with a new partner most recently with Kirkland & Ellis LLP.
The former head of Sidley Austin LLP's U.K. tax practice has joined Fried Frank Harris Shriver & Jacobson LLP's London office, where he will advise on U.K. and international tax structuring, the firm announced.
A tobacco company cannot revive its claim for a tax refund, a New Jersey appeals court found, agreeing with the state's tax court that 2020 amendments to a regulation limiting a royalty add-back deduction must... (more story)
Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares the... (more story)
A bipartisan group of House lawmakers unveiled legislation Wednesday that they said would expand access to paid family leave by incentivizing states to establish their own programs and facilitating the exchang... (more story)
The Streamlined Sales Tax Governing Board's model for how to tax products sold in a bundle generally works well and more states should consider it, a Multistate Tax Commission work group studying how to harmon... (more story)
A New York rule allowing state taxation of nonsolicitation business activities over the internet isn't barred by a federal law providing limited protections against state income tax, but the rule cannot apply ... (more story)
International More
ECB Says Consumers Ready To Avoid US Goods Over Tariffs
European consumers are prepared to avoid American goods for the long term, following the impact of tariffs imposed by the U.S. administration, according to a survey by the European Central Bank.
BNY Can't Escape A&O Shearman's £93M Negligence Claim
Bank of New York Mellon lost its fight Thursday to escape a claim from Allen Overy Shearman Sterling alleging that the lender caused Nationwide Building Society to face a £93 million ($109 million) tax bill by... (more story)
Morgan Lewis Expands Tax Practice With Milbank Hire
Morgan Lewis & Bockius LLP added a former Milbank special counsel as a tax partner based in the firm's London office.
Dentist Fights HMRC Over Alleged Tax Avoidance
A dentist's firm urged an appeals court on Wednesday to find that it had not engaged in tax avoidance by making loan payments to its owner through a trust, saying the payments had no connection to its owner's ... (more story)
Ex-Treasury Official Joins Baker McKenzie's Tax Practice
Baker McKenzie has hired a former deputy assistant secretary at the Treasury Department to work on international tax matters as a partner in the firm's office in Washington, D.C.
HMRC Should Use AI To Boost Services, Report Says
HM Revenue & Customs is still not doing enough to improve its services and should prepare to use artificial intelligence to enhance customer service for U.K. taxpayers and increase its productivity, acco... (more story)
Immigration Ruling No Help To Liberty Global, 10th Circ. Told
Liberty Global cannot use a U.S. Supreme Court ruling on interpreting ambiguous law in an immigration case to support the company's interpretation of law in its $248 million foreign tax credit claim, the feder... (more story)
European consumers are prepared to avoid American goods for the long term, following the impact of tariffs imposed by the U.S. administration, according to a survey by the European Central Bank.
Bank of New York Mellon lost its fight Thursday to escape a claim from Allen Overy Shearman Sterling alleging that the lender caused Nationwide Building Society to face a £93 million ($109 million) tax bill by... (more story)
Morgan Lewis & Bockius LLP added a former Milbank special counsel as a tax partner based in the firm's London office.
A dentist's firm urged an appeals court on Wednesday to find that it had not engaged in tax avoidance by making loan payments to its owner through a trust, saying the payments had no connection to its owner's ... (more story)
Baker McKenzie has hired a former deputy assistant secretary at the Treasury Department to work on international tax matters as a partner in the firm's office in Washington, D.C.
HM Revenue & Customs is still not doing enough to improve its services and should prepare to use artificial intelligence to enhance customer service for U.K. taxpayers and increase its productivity, acco... (more story)
Liberty Global cannot use a U.S. Supreme Court ruling on interpreting ambiguous law in an immigration case to support the company's interpretation of law in its $248 million foreign tax credit claim, the feder... (more story)