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Why Trump's 2nd Global Tariff May Fare Better On Appeal
President Donald Trump's administration on Friday appealed the U.S. Court of International Trade's ruling deeming his temporary global tariff unlawful to the Federal Circuit, where judges may view the executive action with more deference than the measures it immediately replaced.
NY Internet Activity Rule Not Barred By Fed. Law, Panel Says
A New York rule that outlines when out-of-state businesses' online activities exceed federal protections against state income taxes isn't preempted by federal law, a state appeals court ruled Thursday, saying the federal statute's goal of shielding certain interstate businesses from tax isn't impeded by the regulation.
Why Trump's 2nd Global Tariff May Fare Better On Appeal
President Donald Trump's administration on Friday appealed the U.S. Court of International Trade's ruling deeming his temporary global tariff unlawful to the Federal Circuit, where judges may view the executive action with more deference than the measures it immediately replaced.
Securities Co. Asks NY Court To Source Receipts To Investors
A securities company asked a New York state appeals court to reverse a tribunal decision that said its receipts must be sourced to the locations of institutional intermediaries, such as investment advisers, rather than where underlying investors were located.
NY Internet Activity Rule Not Barred By Fed. Law, Panel Says
A New York rule that outlines when out-of-state businesses' online activities exceed federal protections against state income taxes isn't preempted by federal law, a state appeals court ruled Thursday, saying the federal statute's goal of shielding certain interstate businesses from tax isn't impeded by the regulation.
Federal More
Scrutinizing businesses with potential employment tax fraud issues related to undocumented immigrants will remain among the Internal Revenue Service Criminal Investigation division's top priorities, a senior d... (more story)
The Internal Revenue Service has resumed issuing letter rulings on significant issues in tax-free spinoffs, and an IRS attorney on Saturday encouraged companies to use the program, as it provides the agency wi... (more story)
The administrative costs for a company or individual triggering a taxable presence, or permanent establishment, in a jurisdiction shouldn't exceed the profit allocable to the entity, transfer pricing specialists said Friday.
The use of artificial intelligence in transfer pricing is expected to ease compliance and reduce costs for clients, but multiple questions remain about the technology's potential and how it should be applied, ... (more story)
A Florida federal judge on Friday ruled Pro Energy LLC can recover $1.85 million in refunds from fuel excise taxes it paid despite being registered as an ultimate vendor, which should have allowed it to make t... (more story)
A disbarred English attorney who assisted the heirs of an American businessman in evading taxation on their inheritance cannot use an "extraordinary" post-conviction remedy to overturn part of the verdict and ... (more story)
A group of Nike customers on Friday joined the growing number of proposed class actions looking to secure legal rights to refunds of costs tied to President Donald Trump's now-invalidated global tariff regime,... (more story)
State & Local More
Taxation With Representation: Corrs, Kirkland, Linklaters
In this week's Taxation With Representation, gold companies Regis Resources and Vault Minerals combine, Long Lake Management acquires American Express Global Business Travel and Vodafone buys out CK Hutchison ... (more story)
Hochul Says Budget Deal Will Include NYC 2nd-Home Tax
New York Gov. Kathy Hochul said Thursday that she reached a budget compromise with lawmakers that includes a tax on high-value second homes in New York City and a tax break for tip income, but the state Assemb... (more story)
Stinson Real Estate Finance Atty Joins Reed Smith In DC
Reed Smith LLP has hired a Stinson LLP lawyer who focuses her practice on real estate finance matters, renewable energy tax credit and new market tax credit issues, the firm has announced.
Speed Jigsaw Puzzling Makes Me A Better Lawyer
My passion for speed puzzling — I can complete a 500-piece jigsaw puzzle in under 50 minutes — has sharpened my legal skills in more ways than one, with both disciplines requiring patience, precision and the a... (more story)
JetBlue Asks Appeals Court To Find Fla. Tax Unconstitutional
JetBlue asked a Florida state appeals court to rule that the state's method of taxing airline income unconstitutionally counts miles flown outside Florida's borders, arguing that a trial court misapplied a tes... (more story)
Texas Worker Can't Be Taxed As Unitary Biz, Calif. Panel Rules
A Texas-based radiologist who worked remotely as an independent contractor for a California company was a sole proprietor engaged in a single business activity and cannot be taxed as a unitary business, a stat... (more story)
Wis. Village Urges 7th Circ. To Void Oneida Tribal Trust Order
A Wisconsin village is asking the Seventh Circuit to undo a U.S. Department of the Interior decision to place 500 acres of properties into trust for the Oneida Nation, arguing that a district court ignored evi... (more story)
In this week's Taxation With Representation, gold companies Regis Resources and Vault Minerals combine, Long Lake Management acquires American Express Global Business Travel and Vodafone buys out CK Hutchison ... (more story)
New York Gov. Kathy Hochul said Thursday that she reached a budget compromise with lawmakers that includes a tax on high-value second homes in New York City and a tax break for tip income, but the state Assemb... (more story)
Reed Smith LLP has hired a Stinson LLP lawyer who focuses her practice on real estate finance matters, renewable energy tax credit and new market tax credit issues, the firm has announced.
My passion for speed puzzling — I can complete a 500-piece jigsaw puzzle in under 50 minutes — has sharpened my legal skills in more ways than one, with both disciplines requiring patience, precision and the a... (more story)
JetBlue asked a Florida state appeals court to rule that the state's method of taxing airline income unconstitutionally counts miles flown outside Florida's borders, arguing that a trial court misapplied a tes... (more story)
A Texas-based radiologist who worked remotely as an independent contractor for a California company was a sole proprietor engaged in a single business activity and cannot be taxed as a unitary business, a stat... (more story)
A Wisconsin village is asking the Seventh Circuit to undo a U.S. Department of the Interior decision to place 500 acres of properties into trust for the Oneida Nation, arguing that a district court ignored evi... (more story)
International More
Clarity Sought On Energy Tax Credits And Foreign Debt
The IRS should issue more guidance on what kind of debt arrangements can limit a development project's access to clean energy tax credits under new prohibited foreign entity requirements as uncertainty over fi... (more story)
US, Romania Have Wrapped Up Tax Treaty Talks, Official Says
The U.S. and Romania recently completed negotiations on their double-tax treaty and are conducting reviews of the changes, an official with the U.S. Department of the Treasury said Friday.
Liberty Global Easy Case For 10th Circ., IRS Atty Says
The Internal Revenue Service's recent win against telecommunications giant Liberty Global, whose complex transactions were held to be a tax shelter lacking economic substance, was an "easy affirmance" for the ... (more story)
Wyden Probes Wall Street Firms For Tariff Refund Stakes' Info
The top Democratic lawmakers on the Senate Finance Committee sent letters to major Wall Street firms Thursday about their activity in buying the rights to importers' tariff refund interests at a discount follo... (more story)
Italian Man Arrested Amid Probe Into Large-Scale VAT Fraud
Italian authorities have arrested a businessman suspected of laundering the proceeds of a multimillion-euro value-added tax fraud, the European Public Prosecutor's Office said.
Documenting Business Purpose After IRS' 10th Circ. Win
Following the Tenth Circuit’s recent Liberty Global v. U.S. decision, which held the economic substance doctrine does not require a threshold relevancy determination, taxpayers can prepare for potential audit... (more story)
IRS Gets Protest Of Wedding Gift Penalties Narrowed
A Chinese citizen seeking a refund of penalties imposed by the IRS over a failure to report wedding gifts she received from abroad cannot argue the agency must collect the penalties through a civil action, a C... (more story)
The IRS should issue more guidance on what kind of debt arrangements can limit a development project's access to clean energy tax credits under new prohibited foreign entity requirements as uncertainty over fi... (more story)
The U.S. and Romania recently completed negotiations on their double-tax treaty and are conducting reviews of the changes, an official with the U.S. Department of the Treasury said Friday.
The Internal Revenue Service's recent win against telecommunications giant Liberty Global, whose complex transactions were held to be a tax shelter lacking economic substance, was an "easy affirmance" for the ... (more story)
The top Democratic lawmakers on the Senate Finance Committee sent letters to major Wall Street firms Thursday about their activity in buying the rights to importers' tariff refund interests at a discount follo... (more story)
Italian authorities have arrested a businessman suspected of laundering the proceeds of a multimillion-euro value-added tax fraud, the European Public Prosecutor's Office said.
Following the Tenth Circuit’s recent Liberty Global v. U.S. decision, which held the economic substance doctrine does not require a threshold relevancy determination, taxpayers can prepare for potential audit... (more story)
A Chinese citizen seeking a refund of penalties imposed by the IRS over a failure to report wedding gifts she received from abroad cannot argue the agency must collect the penalties through a civil action, a C... (more story)