Texas Instruments Asks Court To Reject IRS Stance On FDII
The IRS' reduction of Texas Instruments' deduction for foreign-derived intangible income contradicted a long-standing interpretation by courts, which have required a connection between expenses and gross income for which a deduction is allowed, the company told the U.S. Tax Court.
MTC Partnership Tax Group Eyes Sales Of Interests, Assets
As the Multistate Tax Commission group working on uniform rules for the state taxation of partnerships finalizes its draft combined model act, it will turn next to researching ways for states to tax sales of partnership interests or assets, tax professionals said Wednesday.
UK Gov't To Temporarily Raise Bank Surcharge To 6%
The Labour government will temporarily raise the bank surcharge to 6% to help generate more revenue to cover its expanded spending plans, Chancellor John Healey said in his autumn Budget on Wednesday.
Texas Instruments Asks Court To Reject IRS Stance On FDII
The IRS' reduction of Texas Instruments' deduction for foreign-derived intangible income contradicted a long-standing interpretation by courts, which have required a connection between expenses and gross income for which a deduction is allowed, the company told the U.S. Tax Court.
MTC Partnership Tax Group Eyes Sales Of Interests, Assets
As the Multistate Tax Commission group working on uniform rules for the state taxation of partnerships finalizes its draft combined model act, it will turn next to researching ways for states to tax sales of partnership interests or assets, tax professionals said Wednesday.
UK Gov't To Temporarily Raise Bank Surcharge To 6%
The Labour government will temporarily raise the bank surcharge to 6% to help generate more revenue to cover its expanded spending plans, Chancellor John Healey said in his autumn Budget on Wednesday.
Federal More
A Seattle restaurant owner was sentenced to 13 months in prison and three years of supervised release for willfully failing to pay more than $1.4 million in unemployment, Social Security and Medicare taxes, so... (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)
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)
A Manhattan federal judge on Wednesday sentenced a charity founder to eight years in prison for embezzling over $2.5 million of charitable funds to live a luxury lifestyle, after his bid to withdraw a guilty p... (more story)
A formerly married couple are not entitled to claim a refund of roughly $1.6 million for tax penalties related to a foreign trust, a Pennsylvania federal magistrate judge ruled, finding the court lacks jurisdi... (more story)
In just over two weeks, U.S. Customs and Border Protection has cleared nearly 16 million more imports as part of the third phase of its tariff refund system, according to a declaration filed by a CBP official ... (more story)
A Nigerian man facing charges that he obtained more than $100 million in tax refunds fraudulently by posing as tax professionals and taxpayers was arraigned after being extradited from Benin, the U.S. Departme... (more story)
State & Local More
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)
Ariz. Court OKs Local Sales Tax Passed By Simple Majority
An Arizona appeals court rejected a challenge to a local sales tax enacted via ballot measure in 2024, disagreeing with taxpayers who claimed the ballot proposal was a referendum that required 60% approval.
Ex-Pa. Senator Wrongly Convicted Over Tax, 3rd Circ. Told
The U.S. Tax Court erred when it found a former Pennsylvania state senator responsible for losses to the state's Senate, he told the Third Circuit, arguing that the lower court incorrectly determined that exce... (more story)
NC Top Court Will Weigh State Bar's Reach Over Ex-Judges
The North Carolina Supreme Court agreed to take up a former state court judge's appeal challenging the state bar's authority to discipline him for alleged misconduct on the bench, which he said the Tar Heel st... (more story)
Colo. Justices Asked To Hear Challenge To Amendment 87
The man challenging the validity of signatures for a Colorado ballot initiative to raise taxes on the state's wealthiest residents appealed the dismissal of his lawsuit to the state's high court Thursday.
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)
An Arizona appeals court rejected a challenge to a local sales tax enacted via ballot measure in 2024, disagreeing with taxpayers who claimed the ballot proposal was a referendum that required 60% approval.
The U.S. Tax Court erred when it found a former Pennsylvania state senator responsible for losses to the state's Senate, he told the Third Circuit, arguing that the lower court incorrectly determined that exce... (more story)
The North Carolina Supreme Court agreed to take up a former state court judge's appeal challenging the state bar's authority to discipline him for alleged misconduct on the bench, which he said the Tar Heel st... (more story)
The man challenging the validity of signatures for a Colorado ballot initiative to raise taxes on the state's wealthiest residents appealed the dismissal of his lawsuit to the state's high court Thursday.
International More
Pillar 2 Minimum Tax Funds Could Finance EU Budget
A coming draft of the European Union's next long-term budget could propose using Pillar Two funds as a revenue source to finance the bloc's spending priorities, three EU officials told Law360 on Wednesday.
Healey Looks To Simplify But Not Abolish Shareholder Taxes
Chancellor John Healey told MPs on Wednesday that the government would retain stamp duty on share trading but pledged to modernize the tax, drawing criticism of a "missed opportunity" to revive interest in the... (more story)
Gov't Tweaks UK Tax Allowance To Protect Pensioners
The government announced plans on Wednesday to protect pensioners from paying income tax on the state pension, which is set to rise above the basic income tax threshold.
IRS Asks 1st Circ. To Toss Shuttered Bank Owner's Claims
The IRS asked the First Circuit to dismiss unlawful property seizure and due process claims against former IRS Criminal Investigation officers in a dispute related to a shuttered online bank suspected of facil... (more story)
Medtronic, IRS Unable To Settle Transfer Pricing Case
Medtronic and the IRS were unable to settle their dispute over how to price intangibles that the medical device maker licensed to a Puerto Rican affiliate, the parties told the U.S. Tax Court, potentially teei... (more story)
DOJ Directive Gives Contractors A Fraud Risk Road Map
For government contractors, the 10 factors described in the U.S. Department of Justice's recent corporate fraud enforcement directive function as a de facto scoring rubric for internal audits that mirrors what... (more story)
Former Company Director Can't Avert £283K Tax Bill On Loan
A former company director can't avoid nearly £283,000 ($377,000) in income tax on the unpaid balance of a loan despite it being written off, a London tribunal ruled, because the settlement with liquidators doe... (more story)
A coming draft of the European Union's next long-term budget could propose using Pillar Two funds as a revenue source to finance the bloc's spending priorities, three EU officials told Law360 on Wednesday.
Chancellor John Healey told MPs on Wednesday that the government would retain stamp duty on share trading but pledged to modernize the tax, drawing criticism of a "missed opportunity" to revive interest in the... (more story)
The government announced plans on Wednesday to protect pensioners from paying income tax on the state pension, which is set to rise above the basic income tax threshold.
The IRS asked the First Circuit to dismiss unlawful property seizure and due process claims against former IRS Criminal Investigation officers in a dispute related to a shuttered online bank suspected of facil... (more story)
Medtronic and the IRS were unable to settle their dispute over how to price intangibles that the medical device maker licensed to a Puerto Rican affiliate, the parties told the U.S. Tax Court, potentially teei... (more story)
For government contractors, the 10 factors described in the U.S. Department of Justice's recent corporate fraud enforcement directive function as a de facto scoring rubric for internal audits that mirrors what... (more story)
A former company director can't avoid nearly £283,000 ($377,000) in income tax on the unpaid balance of a loan despite it being written off, a London tribunal ruled, because the settlement with liquidators doe... (more story)