4th Circ. Rejects Couple's $5.1M Easement Deduction
IBM Taps Jones Day To Take NY Royalty Tax Fight To Justices
Top State & Local Tax Cases To Watch In 2024's 2nd Half
4th Circ. Rejects Couple's $5.1M Easement Deduction
The Fourth Circuit rejected Monday a married couple's bid to revive a claimed $5.1 million conservation easement deduction, saying it represented a "remarkable" attempt to inflate the value of a 41-acre property that was worth just $652,000 the year before they donated it.
IBM Taps Jones Day To Take NY Royalty Tax Fight To Justices
IBM asked the U.S. Supreme Court for more time to submit a petition for review of a New York high court decision that upheld tax on royalties received from foreign affiliates, saying it recently retained Jones Day to handle the case.
Top State & Local Tax Cases To Watch In 2024's 2nd Half
From a potential U.S. Supreme Court weigh-in on a Philadelphia resident's wage tax claim to cases addressing the scope of taxable information services and whether unapportioned use tax is constitutional, the second half of 2024 promises to pore over state and local tax law. Here, Law360 examines cases to watch in the rest of the year.
Federal More
The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the j... (more story)
A logger's widow agreed to pull about $1.7 million from her Swiss bank account to pay down penalties that her late husband's estate owes the IRS for his failure to report offshore accounts, according to a fili... (more story)
Akerman LLP announced Monday that it picked up a pair of new partners for its tax practice group in Atlanta who were previously with Chamberlain Hrdlicka White Williams & Aughtry.
Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by th... (more story)
A Tennessee company asked the Sixth Circuit to shield it from more than $500 million in excise tax liabilities, saying a lower court correctly found that its refurbished trucks qualify for the safe harbor from... (more story)
Dominic Foulkes of Davis Polk & Wardwell LLP has advised companies on several multibillion-dollar transactions, including a technology-maker's $4.9 billion initial public offering, the largest in the United St... (more story)
Emily Au of Quinn Emanuel Urquhart & Sullivan LLP has been the lead attorney on several high-profile cases, including a key case across the U.K. construction industry in terms of HMRC's Value-Added Tax policy,... (more story)
State & Local More
Tax, Biz Groups Ask MTC To Toss Draft Truck Sourcing Rule
The Multistate State Tax Commission should scrap or pause its attempt to create an alternative to the current mileage-based sourcing rule for trucking receipts, a tax group and others said during a meeting of ... (more story)
Law360 Names 2024's Top Attorneys Under 40
Law360 is pleased to announce the Rising Stars of 2024, our list of 158 attorneys under 40 whose legal accomplishments belie their age.
Conn. Justices Say Town Can Tax Hospital's Property
Personal property of a Connecticut hospital owned by Hartford HealthCare is taxable, the state Supreme Court said Friday, reversing a trial court opinion and ruling that Hartford's acquisition of the hospital ... (more story)
Mo. Says IRS 'Stonewalling' On Worker Credit Freeze Records
The Internal Revenue Service violated public records law in failing to release documents related to its decision to stop processing new employee retention credit claims, the state of Missouri said Friday in a ... (more story)
DC To Offer 15-Year Tax Freeze For Office Conversion Projects
Washington, D.C., plans to offer a 15-year property tax freeze for projects that aim to reposition an office building for a different commercial use, building on the city's larger effort to enliven its downtow... (more story)
Another Crack In The Shield: SALT In Review
From the latest assault on a federal shield against taxing out-of-state businesses to an update on beer taxes, RSM's David Brunori offers his thoughts on noteworthy state and local tax news.
Taxation With Representation: Ropes & Gray, Cravath, Latham
In this Week's Taxation with Representation, Paramount Global merges with Skydance Media, Devon Energy acquires Grayson Mill Energy's Williston Basin oil and gas business, Ryan acquires Altus Group Ltd.'s prop... (more story)
Fire Fee Reversal Risks 'Chaos' For Cities, Detroit Says
The city of Detroit urged Michigan Supreme Court justices to leave in place a decision that said its fire inspection fees are not a disguised unlawful tax because reversing it could send municipalities into "c... (more story)
Accounting Firm Contests Blame For Client's $2M Tax Bill
An accounting firm maintains it had no duty to inform an online flower bulb retailer about a major change in tax law stemming from the U.S. Supreme Court's 2018 Wayfair decision, telling the North Carolina Bus... (more story)
The Multistate State Tax Commission should scrap or pause its attempt to create an alternative to the current mileage-based sourcing rule for trucking receipts, a tax group and others said during a meeting of ... (more story)
Law360 is pleased to announce the Rising Stars of 2024, our list of 158 attorneys under 40 whose legal accomplishments belie their age.
Personal property of a Connecticut hospital owned by Hartford HealthCare is taxable, the state Supreme Court said Friday, reversing a trial court opinion and ruling that Hartford's acquisition of the hospital ... (more story)
The Internal Revenue Service violated public records law in failing to release documents related to its decision to stop processing new employee retention credit claims, the state of Missouri said Friday in a ... (more story)
Washington, D.C., plans to offer a 15-year property tax freeze for projects that aim to reposition an office building for a different commercial use, building on the city's larger effort to enliven its downtow... (more story)
From the latest assault on a federal shield against taxing out-of-state businesses to an update on beer taxes, RSM's David Brunori offers his thoughts on noteworthy state and local tax news.
In this Week's Taxation with Representation, Paramount Global merges with Skydance Media, Devon Energy acquires Grayson Mill Energy's Williston Basin oil and gas business, Ryan acquires Altus Group Ltd.'s prop... (more story)
The city of Detroit urged Michigan Supreme Court justices to leave in place a decision that said its fire inspection fees are not a disguised unlawful tax because reversing it could send municipalities into "c... (more story)
An accounting firm maintains it had no duty to inform an online flower bulb retailer about a major change in tax law stemming from the U.S. Supreme Court's 2018 Wayfair decision, telling the North Carolina Bus... (more story)
International More
Chevron's End Doesn't Bear On 3M's Case, IRS Tells 8th Circ.
The U.S. Supreme Court's recent overturning of Chevron deference doesn't warrant a reversal of a U.S. Tax Court ruling in 3M Co.'s transfer pricing case, the Internal Revenue Service told the Eighth Circuit on Friday.
Alvarez & Marsal Appoints Managing Director Of Tax Group
Alvarez & Marsal Tax LLC appointed an experienced negotiator of tax incentives as managing director to the firm's corporate transformation tax group, the firm announced.
States Should Loosen Law Firm Ownership Restrictions
Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices... (more story)
IRS Proposes 'Basket Contracts' As Listed Transactions
The Internal Revenue Service proposed rules Thursday that would flag so-called basket option contracts as potentially abusive listed transactions, imposing additional reporting requirements under the threat of... (more story)
IRS, OECD Officials Detail Expansion Of AI In Tax Work
The Internal Revenue Service and Organization for Economic Cooperation and Development are making great progress in adopting artificial intelligence in tax administration, representatives of both organizations said Thursday.
Biz Officials Call For Simpler Tax Rules In Light Of Pillar 2
Business representatives said Thursday that tax compliance rules need to be simplified as new minimum tax rules, known as Pillar Two, are added to the existing regime.
Engineer Who Faced Export Charges Cops To Tax Counts
A Chinese-born engineer has pled guilty to two counts of filing a false tax return related to allegations that he and his wife omitted gross income from their tax returns between 2015 and 2019, after Texas fed... (more story)
The U.S. Supreme Court's recent overturning of Chevron deference doesn't warrant a reversal of a U.S. Tax Court ruling in 3M Co.'s transfer pricing case, the Internal Revenue Service told the Eighth Circuit on Friday.
Alvarez & Marsal Tax LLC appointed an experienced negotiator of tax incentives as managing director to the firm's corporate transformation tax group, the firm announced.
Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices... (more story)
The Internal Revenue Service proposed rules Thursday that would flag so-called basket option contracts as potentially abusive listed transactions, imposing additional reporting requirements under the threat of... (more story)
The Internal Revenue Service and Organization for Economic Cooperation and Development are making great progress in adopting artificial intelligence in tax administration, representatives of both organizations said Thursday.
Business representatives said Thursday that tax compliance rules need to be simplified as new minimum tax rules, known as Pillar Two, are added to the existing regime.
A Chinese-born engineer has pled guilty to two counts of filing a false tax return related to allegations that he and his wife omitted gross income from their tax returns between 2015 and 2019, after Texas fed... (more story)