PwC, Deloitte, KPMG Back Coke In $2.7B Dispute In 11th Circ.
Three major accounting firms have asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming the IRS' change to Coca-Cola's intercompany pricing, which led to a $2.7 billion tax bill, arguing the agency's conduct was unsupported and unjustified.
Technical, Policy Questions Still Swirl Around Amount B
U.S. multinational corporations have welcomed the option of a simplified transfer pricing approach under an international tax framework known as Amount B, but uncertainties linger about how the rules will ultimately shake out on a technical level both domestically and globally.
Tax On Services In Proposed Minn. Budget Hits Opposition
Minnesota business groups criticized on Wednesday a provision in the governor's budget proposal to expand the state sales tax to certain accounting, banking and legal services, telling a state Senate committee that it would hurt heavily taxed residents even more.
PwC, Deloitte, KPMG Back Coke In $2.7B Dispute In 11th Circ.
Three major accounting firms have asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming the IRS' change to Coca-Cola's intercompany pricing, which led to a $2.7 billion tax bill, arguing the agency's conduct was unsupported and unjustified.
Technical, Policy Questions Still Swirl Around Amount B
U.S. multinational corporations have welcomed the option of a simplified transfer pricing approach under an international tax framework known as Amount B, but uncertainties linger about how the rules will ultimately shake out on a technical level both domestically and globally.
Tax On Services In Proposed Minn. Budget Hits Opposition
Minnesota business groups criticized on Wednesday a provision in the governor's budget proposal to expand the state sales tax to certain accounting, banking and legal services, telling a state Senate committee that it would hurt heavily taxed residents even more.
Federal More
Rachel Cohen at Skadden discusses why she is helping to organize a movement of BigLaw associates urging their firms to stand up for the rule of law after the Trump administration’s moves against Covington, Per... (more story)
Frost Brown Todd LLP announced that it has hired an attorney from the ranks of Houston's city government to strengthen its public finance group, adding his expertise in state and local government operations, t... (more story)
The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent ... (more story)
A Texas law firm asked the U.S. Tax Court to find that the IRS improperly denied it a $621,000 deduction for payments it made to a captive insurance company, saying the agency wrongly accused the firm of parti... (more story)
Two sisters overseeing their brother's $13.7 million estate told a Rhode Island district court that they shouldn't have to pay hundreds of thousands of dollars in tax penalties for missing the deadline to file... (more story)
An Internal Revenue Service special agent who accused the U.S. Department of Justice of mishandling an investigation into former President Joe Biden's son has been named deputy chief in the IRS Criminal Invest... (more story)
Three industry groups asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming that the Internal Revenue Service could raise Coca-Cola's taxes by $2.7 billion, saying in friend-of-the-court br... (more story)
State & Local More
Jurisdictional Uncertainty Helps Preserve Ill. Tax Bias Suit
Cook County property owners who mistakenly brought discriminatory assessment accusations in state court before taking their allegations to federal court can continue pursuing those claims, an Illinois judge sa... (more story)
Mich. House Approves 6-Fold Rate Hike To Old Biz Tax Regime
Michigan would impose a roughly six-fold increase to the tax rate that applies to businesses that elect to continue filing under a former corporate tax system, under legislation the state House approved as par... (more story)
La. Top Court Tosses Lawsuit Seeking To Block Tax Overhaul
The Louisiana Supreme Court dismissed a lawsuit from a group of state residents to halt a referendum that, if approved, would allow for a state constitutional change to carry out an overhaul of the state's tax regime.
Comerica Awarded Interest On $11M Mich. Tax Credit Win
Comerica is entitled to interest on a nearly $11 million business tax refund it received following the Michigan Supreme Court's upholding of transfers of tax credits that occurred during a merger, the state Ta... (more story)
Mo. Auditor Faults State For Lack Of Cannabis Tax Probes
Missouri's state auditor faulted the state Department of Revenue for not auditing any cannabis tax returns since sales of medical cannabis began in 2020, saying the tax agency failed to establish a robust comp... (more story)
Law360 Announces The Members Of Its 2025 Editorial Boards
Law360 is pleased to announce the formation of its 2025 Editorial Advisory Boards.
Miss. Senate Passes Income Tax Cut With Revenue Triggers
Mississippi's latest tax reform package seeks to tie income tax rate decreases to future revenue surpluses under an amended bill passed by the state Senate, countering the state House of Representative's origi... (more story)
Mich. House OKs Permanent Automatic Income Tax Rate Cut
Michigan would lower its income tax rate back down to where it was in 2023 and make the tax cut permanent, unless the Legislature voted to change it, under a bill the state House of Representatives passed Tuesday.
Verizon Seeks $24.7M Refund In Challenge To Fla. Tax Rules
A Florida regulation that determines the tax treatment for certain receipts from telecommunications companies unconstitutionally burdens interstate commerce and taxes activity that occurs in other states, Veri... (more story)
Cook County property owners who mistakenly brought discriminatory assessment accusations in state court before taking their allegations to federal court can continue pursuing those claims, an Illinois judge sa... (more story)
Michigan would impose a roughly six-fold increase to the tax rate that applies to businesses that elect to continue filing under a former corporate tax system, under legislation the state House approved as par... (more story)
The Louisiana Supreme Court dismissed a lawsuit from a group of state residents to halt a referendum that, if approved, would allow for a state constitutional change to carry out an overhaul of the state's tax regime.
Comerica is entitled to interest on a nearly $11 million business tax refund it received following the Michigan Supreme Court's upholding of transfers of tax credits that occurred during a merger, the state Ta... (more story)
Missouri's state auditor faulted the state Department of Revenue for not auditing any cannabis tax returns since sales of medical cannabis began in 2020, saying the tax agency failed to establish a robust comp... (more story)
Law360 is pleased to announce the formation of its 2025 Editorial Advisory Boards.
Mississippi's latest tax reform package seeks to tie income tax rate decreases to future revenue surpluses under an amended bill passed by the state Senate, countering the state House of Representative's origi... (more story)
Michigan would lower its income tax rate back down to where it was in 2023 and make the tax cut permanent, unless the Legislature voted to change it, under a bill the state House of Representatives passed Tuesday.
A Florida regulation that determines the tax treatment for certain receipts from telecommunications companies unconstitutionally burdens interstate commerce and taxes activity that occurs in other states, Veri... (more story)
International More
Prudential's £9.3M Fees To Silverfleet Taxable, HMRC Argues
Prudential's payments of £9.3 million ($12 million) to an investment firm are taxable even though the fees were for services the firm carried out when the two companies were part of the same group, the tax aut... (more story)
DC Judge Won't Preemptively Stop IRS Data Sharing With DHS
A D.C. federal judge on Wednesday said two immigrant rights groups had not shown that the IRS is poised to unlawfully share noncitizen taxpayer records with immigration enforcement authorities, rejecting their... (more story)
Group Status Prohibits VAT, Prudential Tells UK Top Court
Prudential disputed a value-added tax claim on £9.3 million ($12.1 million) in performance fees at the U.K. Supreme Court on Wednesday on the grounds that the business providing the services was a part of the ... (more story)
Ex-Glencore Exec Fights £150M Tax On Offshore Shares
Glencore's former head of oil urged an appeals court Wednesday to overturn a finding he was liable for income tax on nearly £150 million ($194 million) in share distributions from the Jersey company, in a case... (more story)
Disclosure Woes Sink £13M Fraud Trial Against Film Execs
Prosecutors have abandoned a decade-long fraud case in which four former managers at a film production company were accused of cheating taxpayers out of £13 million ($17 million) because of insurmountable disc... (more story)
Danish Wind Farm Co. Wins UK Tax Relief For Study Costs
A Danish wind farm company can claim expenditures on studies and designs associated with constructing wind farms for tax relief purposes, a London appeals court ruled.
Trump Hasn't Asked IRS For Immigrants' Tax Info, Gov't Says
The IRS hasn't received any requests from President Donald Trump for immigrants' tax return information and hasn't released any such information to the U.S. Department of Homeland Security, the government told... (more story)
Prudential's payments of £9.3 million ($12 million) to an investment firm are taxable even though the fees were for services the firm carried out when the two companies were part of the same group, the tax aut... (more story)
A D.C. federal judge on Wednesday said two immigrant rights groups had not shown that the IRS is poised to unlawfully share noncitizen taxpayer records with immigration enforcement authorities, rejecting their... (more story)
Prudential disputed a value-added tax claim on £9.3 million ($12.1 million) in performance fees at the U.K. Supreme Court on Wednesday on the grounds that the business providing the services was a part of the ... (more story)
Glencore's former head of oil urged an appeals court Wednesday to overturn a finding he was liable for income tax on nearly £150 million ($194 million) in share distributions from the Jersey company, in a case... (more story)
Prosecutors have abandoned a decade-long fraud case in which four former managers at a film production company were accused of cheating taxpayers out of £13 million ($17 million) because of insurmountable disc... (more story)
A Danish wind farm company can claim expenditures on studies and designs associated with constructing wind farms for tax relief purposes, a London appeals court ruled.
The IRS hasn't received any requests from President Donald Trump for immigrants' tax return information and hasn't released any such information to the U.S. Department of Homeland Security, the government told... (more story)