Eaton's Position On Parental Support Conflicting, Judge Says
Eaton is telling "different stories at different times" about the ability of its foreign parent company to step in and pay the U.S. company's debt obligations to third parties, Tax Court Judge Albert Lauber said in questioning one of the company's experts Friday.
Mass. Co.'s Software Receipts Sourced To Wis., Agency Rules
A Massachusetts company's receipts for licensing its database software to a Wisconsin-based business are sourced to Wisconsin for tax purposes instead of the locations of customers who bought sublicenses from the business, the Wisconsin Tax Appeals Commission affirmed.
Treasury To Float Guidance For Budget Bill's Int'l Provisions
The U.S. Treasury Department announced plans Thursday to issue regulations for international tax provisions that were modified under the federal budget bill in July, including guidance to help corporations calculate foreign tax credits on certain types of overseas income.
Eaton's Position On Parental Support Conflicting, Judge Says
Eaton is telling "different stories at different times" about the ability of its foreign parent company to step in and pay the U.S. company's debt obligations to third parties, Tax Court Judge Albert Lauber said in questioning one of the company's experts Friday.
Mass. Co.'s Software Receipts Sourced To Wis., Agency Rules
A Massachusetts company's receipts for licensing its database software to a Wisconsin-based business are sourced to Wisconsin for tax purposes instead of the locations of customers who bought sublicenses from the business, the Wisconsin Tax Appeals Commission affirmed.
Treasury To Float Guidance For Budget Bill's Int'l Provisions
The U.S. Treasury Department announced plans Thursday to issue regulations for international tax provisions that were modified under the federal budget bill in July, including guidance to help corporations calculate foreign tax credits on certain types of overseas income.
Federal More
A D.C. federal court's order pausing the Internal Revenue Service's ability to share confidential taxpayer addresses with immigration enforcement officials should not impact a separate D.C. Circuit proceeding ... (more story)
Multinational chemical manufacturer Huntsman is challenging the IRS over a $28.6 million tax bill that resulted from the agency reducing its carried-forward loss from selling a spun-off pigments business, acco... (more story)
Though agentic artificial intelligence has demonstrated significant promise for optimizing legal work, it presents numerous risks, so specific ethical obligations should be built into the knowledge base of eve... (more story)
A U.S. Tax Court judge closely questioned Thursday an expert for Eaton who said potential investors would not have counted on financial support from the company's parent in the event it couldn't meet its oblig... (more story)
Partners who are active participants in a partnership's business despite their status as limited partners under state law are not exempt from the self-employment tax, New York University's tax law center told ... (more story)
The commissioner of the IRS' Large Business and International Division, who was placed on leave, told a D.C. federal court that she cannot find a new job due to the agency's alleged unlawful leak of informatio... (more story)
The Sixth Circuit declined to reexamine an August decision that allowed some leeway in extending the U.S. Tax Court's 90-day deadline to file a petition, according to an order dismissing a federal government b... (more story)
State & Local More
NH Supreme Court Asked To Affirm Tax Loss Offset Ruling
New Hampshire's justices should affirm a lower court's finding that a capital loss carryback can be used to offset capital gains in a combined group, even if the loss and gain are generated by different group ... (more story)
Colo. Justices Urged To Scrap Ballot Plan To Expand TABOR
A proposed ballot measure to require voter approval for a broader range of fees under Colorado's Taxpayer's Bill of Rights unlawfully contains more than a single subject and should be rejected, an opponent of ... (more story)
Food For Thought On Taxes, By The Bagful: SALT In Review
From a welcome annual ranking of the states' tax climates to the Virginia capital city's new tax on plastic bags, RSM's David Brunori offers his thoughts on noteworthy state and local tax news.
NY Tax Talk: New ALJs, New Rules, Apportionment, Bundling
Attorneys at Eversheds review the top New York tax law developments from last quarter, including appointments to the New York City Tax Appeals Tribunal and the city's proposed rules to clarify income taxation ... (more story)
Mineral Rights At Former Mo. Gas Station Ruled Worthless
A convenience store company's interest in mineral rights it retained when it sold a gas station property are correctly valued at $0 and not taxable, the Missouri Court of Appeals ruled, upholding decisions of ... (more story)
Wisconsin Village Loses Bid to Block Oneida Land Trust
A federal court judge affirmed an Interior Department decision to place 500 acres of properties into a trust for the Oneida Nation, rejecting claims by a Wisconsin village that the transfers were based on a bi... (more story)
Mass. Justices Question Limits Of Estate Tax Penalties
A fine and interest assessment levied by Massachusetts' tax agency against an estate that filed its return seven years late is excessive and unconstitutional, the estate told the state's high court Wednesday, ... (more story)
State, Federal Incentives Heat Up Geothermal Projects
Geothermal energy can now benefit from dramatically accelerated permitting for development on federal land as well as state-level renewable energy portfolio standards — but operating in the complex legal frame... (more story)
Boston Celeb Chef Facing Default In City's $1.7M Tax Case
Celebrity chef Barbara Lynch failed to line up new counsel or respond to an amended complaint the city of Boston brought against her in state court over an unpaid $1.7 million tax bill for her now-shuttered re... (more story)
New Hampshire's justices should affirm a lower court's finding that a capital loss carryback can be used to offset capital gains in a combined group, even if the loss and gain are generated by different group ... (more story)
A proposed ballot measure to require voter approval for a broader range of fees under Colorado's Taxpayer's Bill of Rights unlawfully contains more than a single subject and should be rejected, an opponent of ... (more story)
From a welcome annual ranking of the states' tax climates to the Virginia capital city's new tax on plastic bags, RSM's David Brunori offers his thoughts on noteworthy state and local tax news.
Attorneys at Eversheds review the top New York tax law developments from last quarter, including appointments to the New York City Tax Appeals Tribunal and the city's proposed rules to clarify income taxation ... (more story)
A convenience store company's interest in mineral rights it retained when it sold a gas station property are correctly valued at $0 and not taxable, the Missouri Court of Appeals ruled, upholding decisions of ... (more story)
A federal court judge affirmed an Interior Department decision to place 500 acres of properties into a trust for the Oneida Nation, rejecting claims by a Wisconsin village that the transfers were based on a bi... (more story)
A fine and interest assessment levied by Massachusetts' tax agency against an estate that filed its return seven years late is excessive and unconstitutional, the estate told the state's high court Wednesday, ... (more story)
Geothermal energy can now benefit from dramatically accelerated permitting for development on federal land as well as state-level renewable energy portfolio standards — but operating in the complex legal frame... (more story)
Celebrity chef Barbara Lynch failed to line up new counsel or respond to an amended complaint the city of Boston brought against her in state court over an unpaid $1.7 million tax bill for her now-shuttered re... (more story)
International More
Belgian Court Refers FATCA Data Case To EU's Top Court
A Brussels court referred a case to the Court of Justice of the European Union concerning whether transfers of U.S. taxpayer data breach EU privacy law, according to a court document released Thursday.
Over 2 Dozen Countries Commit To Property Tax Transparency
A group of 26 jurisdictions committed Thursday to adopting a framework developed by the Organization for Economic Cooperation and Development to facilitate the exchange of real estate information among tax authorities.
HMRC OK To Fire Union Rep Who Promoted Strike Via Teams
HM Revenue & Customs did not act unfairly by sacking a long-standing trade union rep for gross misconduct after he sent 67 Microsoft Teams messages to staff who declined to join a strike in 2023, a tribunal has ruled.
UK Importer Must Pay Tax On PPE, Court Affirms
A logistics company must pay £1.4 million ($1.8 million) in customs duties and value-added tax for personal protective equipment imported from China to the U.K. during the COVID-19 pandemic in 2020, a London c... (more story)
Thai Cabinet Backs Carbon Tax, Border Tax, Emissions Trading
Thailand would institute a carbon tax, emissions trading system and carbon-border adjustment mechanism under the country's first comprehensive climate bill, approved Tuesday by the country's cabinet.
Most Countries Compliant With Data Exchanges, OECD Says
Many countries are on track with implementing a data-swapping network under global guidelines to exchange financial and tax information, but more could be done to enforce reporting requirements for banks, the ... (more story)
Trump Tariff Refund Rights Should Be Preserved, Costco Says
The federal government should have to refund President Donald Trump's emergency tariffs paid by Costco Wholesale Corp., the company told the U.S. Court of International Trade.
A Brussels court referred a case to the Court of Justice of the European Union concerning whether transfers of U.S. taxpayer data breach EU privacy law, according to a court document released Thursday.
A group of 26 jurisdictions committed Thursday to adopting a framework developed by the Organization for Economic Cooperation and Development to facilitate the exchange of real estate information among tax authorities.
HM Revenue & Customs did not act unfairly by sacking a long-standing trade union rep for gross misconduct after he sent 67 Microsoft Teams messages to staff who declined to join a strike in 2023, a tribunal has ruled.
A logistics company must pay £1.4 million ($1.8 million) in customs duties and value-added tax for personal protective equipment imported from China to the U.K. during the COVID-19 pandemic in 2020, a London c... (more story)
Thailand would institute a carbon tax, emissions trading system and carbon-border adjustment mechanism under the country's first comprehensive climate bill, approved Tuesday by the country's cabinet.
Many countries are on track with implementing a data-swapping network under global guidelines to exchange financial and tax information, but more could be done to enforce reporting requirements for banks, the ... (more story)
The federal government should have to refund President Donald Trump's emergency tariffs paid by Costco Wholesale Corp., the company told the U.S. Court of International Trade.