House Sends ACA Credit Expansion Extension To Senate
The House of Representatives on Thursday approved legislation to reinstate the Affordable Care Act's expired enhanced premium tax credit for three more years, with 17 Republicans voting with Democrats to send the proposal to the Senate.
OECD, Gov't Officials Praise 'Side-By-Side' Tax Deal
Officials from Germany, the U.S. and the OECD on Thursday hailed a recently finalized agreement among roughly 150 countries as a balanced solution to the U.S.' desire for a global minimum tax regime that operates "side by side" with its own rules.
NBC Penalties Upheld By Ore. Tax Court In Nexus Row
NBC Universal's tax positions in a nexus dispute with the Oregon Department of Revenue were not supported by substantial authority or a reasonable basis, the state tax court said, declining to reduce penalties for underreporting state income.
House Sends ACA Credit Expansion Extension To Senate
The House of Representatives on Thursday approved legislation to reinstate the Affordable Care Act's expired enhanced premium tax credit for three more years, with 17 Republicans voting with Democrats to send the proposal to the Senate.
OECD, Gov't Officials Praise 'Side-By-Side' Tax Deal
Officials from Germany, the U.S. and the OECD on Thursday hailed a recently finalized agreement among roughly 150 countries as a balanced solution to the U.S.' desire for a global minimum tax regime that operates "side by side" with its own rules.
NBC Penalties Upheld By Ore. Tax Court In Nexus Row
NBC Universal's tax positions in a nexus dispute with the Oregon Department of Revenue were not supported by substantial authority or a reasonable basis, the state tax court said, declining to reduce penalties for underreporting state income.
Federal More
Appellate courts have mostly upheld federal agencies' interpretation of ambiguous statutes, including tax disputes, even after the U.S. Supreme Court's 2024 landmark decision that limited agency deference, a U... (more story)
A former IRS deputy commissioner criticized the U.S. Department of Justice for indicting a former software executive who was ultimately convicted of failing to pay employment taxes, calling the choice "entirel... (more story)
The Sixth Circuit should vacate a judgment that allowed FedEx an $89 million refund by discarding a regulation preventing companies from claiming foreign tax credits on earnings offset by losses, which aren't ... (more story)
A potentially sweeping overhaul simplifying the U.S. Securities and Exchange Commission's disclosure regime for public company executive compensation will be top of mind for executive pay practitioners as they... (more story)
IRS attorneys provide legal guidance during audits on whether a transaction lacks economic substance, but examiners make the ultimate determination, an agency associate chief counsel said Thursday while explai... (more story)
The Internal Revenue Service floated changes Thursday to withholding rules for organizations such as PayPal and Venmo that make payments to settle third-party network transactions, saying the move would align ... (more story)
Recent changes to the commentary on when a home office gives rise to a permanent establishment in the OECD model tax treaty reflect delegates' unhappiness with previous language on the availability of an offic... (more story)
State & Local More
Kraft Heinz Fights For Apportionment Of NJ Litter Fee
Kraft Heinz asked the New Jersey Tax Court to rule that the state's litter control fee unconstitutionally taxed the company's out-of-state activities by not allowing it to apportion the levy based on where its... (more story)
NC Wins Appeal To Use Smithfield Funds For Enviro Grants
The North Carolina Attorney General's Office can continue putting money from a decades-old hog waste agreement toward environmental grants, a state appeals court panel ruled, overturning a lower court order ea... (more story)
Mich. Again Falls Short In Bid To Ax Challenge To 24% Pot Tax
A Michigan federal judge is standing firm in her decision to allow industry members to proceed with a portion of their challenge to the state's excise tax on wholesale marijuana sales, finding that the state h... (more story)
Treasury Eyes Final Easements Settlements, Official Says
The U.S. Department of the Treasury plans to issue a summary of the IRS' successes in conservation easement cases as it works on a final settlement initiative for hundreds of remaining disputes, a department o... (more story)
Ore. Gov. Seeks Repeal Of Transportation Funding Package
Oregon's governor said Wednesday that lawmakers should repeal a transportation package with tax and fee increases passed last year that is now slated for a voter referendum in November.
Ore. Tax Court Won't Limit Chevron Order To Enable Appeal
Chevron's tax and penalty refund requests from Oregon totaling $14.8 million were part of a single claim, the state Tax Court found, declining to limit its judgment against the company to an apportionment ques... (more story)
Paul Hastings Adds Ex-Cravath Tax Pro To Growing M&A Team
After adding 20 partners to its mergers and acquisitions platform over the past two years, Paul Hastings LLP announced on Tuesday that it has hired a former Cravath Swaine & Moore LLP partner who advises on th... (more story)
Kraft Heinz asked the New Jersey Tax Court to rule that the state's litter control fee unconstitutionally taxed the company's out-of-state activities by not allowing it to apportion the levy based on where its... (more story)
The North Carolina Attorney General's Office can continue putting money from a decades-old hog waste agreement toward environmental grants, a state appeals court panel ruled, overturning a lower court order ea... (more story)
A Michigan federal judge is standing firm in her decision to allow industry members to proceed with a portion of their challenge to the state's excise tax on wholesale marijuana sales, finding that the state h... (more story)
The U.S. Department of the Treasury plans to issue a summary of the IRS' successes in conservation easement cases as it works on a final settlement initiative for hundreds of remaining disputes, a department o... (more story)
Oregon's governor said Wednesday that lawmakers should repeal a transportation package with tax and fee increases passed last year that is now slated for a voter referendum in November.
Chevron's tax and penalty refund requests from Oregon totaling $14.8 million were part of a single claim, the state Tax Court found, declining to limit its judgment against the company to an apportionment ques... (more story)
After adding 20 partners to its mergers and acquisitions platform over the past two years, Paul Hastings LLP announced on Tuesday that it has hired a former Cravath Swaine & Moore LLP partner who advises on th... (more story)
International More
Data Supervisor Warns Against Exceptional VAT Info Searches
The European Union's plans to crack down on value-added tax fraud may blur the line between data cooperation and law enforcement, potentially undermining data protection, the EU's data supervisor warned Thursday.
HSBC To Pay €300M To Settle French Tax Fraud Probe
HSBC has agreed to pay French authorities more than €300 million ($350 million) in fines and unpaid taxes to settle a criminal probe into how the bank's Paris branch handled dividend arbitrage transactions bet... (more story)
OECD Project Seeks To Ease Access To Tax Dispute Process
A new project at the OECD will aim to ensure that double-tax cases are eligible to be resolved through bilateral government negotiations under treaties no matter how they're characterized by a country's tax au... (more story)
Reckless Conduct Can Be Willful FBAR Failure, 2nd Circ. Says
The standard for willful failure to report foreign bank accounts includes reckless conduct, and a 6% late payment penalty is mandatory for a couple who neglected fines for stashing millions in an undisclosed S... (more story)
Gov't Slow-Rolling Lower Fee For Expatriation, Court Told
The U.S. State Department has impermissibly slow-walked the rollout of a reduced fee for renouncing U.S. citizenship, a Paris-based group that represents Americans permanently residing abroad told a D.C. federal court.
IRS Appeals Pause Of ICE Info-Sharing Agreement
The Internal Revenue Service is appealing to the D.C. Circuit a federal court order temporarily stopping the agency from sharing confidential taxpayer addresses with immigration enforcement officials, accordin... (more story)
Tax Firm Says IRS Can't Justify Microcaptive Reporting Rules
A global tax services provider urged a Texas federal court to vacate tax reporting rules for microcaptive insurance companies, arguing that the Internal Revenue Service failed to provide evidence of tax evasio... (more story)
The European Union's plans to crack down on value-added tax fraud may blur the line between data cooperation and law enforcement, potentially undermining data protection, the EU's data supervisor warned Thursday.
HSBC has agreed to pay French authorities more than €300 million ($350 million) in fines and unpaid taxes to settle a criminal probe into how the bank's Paris branch handled dividend arbitrage transactions bet... (more story)
A new project at the OECD will aim to ensure that double-tax cases are eligible to be resolved through bilateral government negotiations under treaties no matter how they're characterized by a country's tax au... (more story)
The standard for willful failure to report foreign bank accounts includes reckless conduct, and a 6% late payment penalty is mandatory for a couple who neglected fines for stashing millions in an undisclosed S... (more story)
The U.S. State Department has impermissibly slow-walked the rollout of a reduced fee for renouncing U.S. citizenship, a Paris-based group that represents Americans permanently residing abroad told a D.C. federal court.
The Internal Revenue Service is appealing to the D.C. Circuit a federal court order temporarily stopping the agency from sharing confidential taxpayer addresses with immigration enforcement officials, accordin... (more story)
A global tax services provider urged a Texas federal court to vacate tax reporting rules for microcaptive insurance companies, arguing that the Internal Revenue Service failed to provide evidence of tax evasio... (more story)