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Five years after its launch, the Multistate Tax Commission’s partnerships project is sending a draft model that combines its sourcing work to date to the Uniformity Committee for review. taxnotes.co/4kaeahF
The National Taxpayers Union (NTU) is arguing that it has standing to challenge California’s 2024 apportionment statute that excludes receipts and activities linked to deductible income. taxnotes.co/4ihbgp1
The 2022 EU solidarity contribution on energy companies was indeed fiscal in nature, but its nontax legal basis was lawful, an EU Court of Justice advocate general concluded. taxnotes.co/4BoO7JV
Proposed rules implementing a significant change to the way ownership of controlled foreign corporations is accounted for following a midyear ownership change are shaking up merger and acquisition deals, tax attorneys said. taxnotes.co/4z0XFcl
NEW: This week on the podcast, Tax Notes reporters @StephanieSoong and @PaezWrites break down the biggest international tax developments from the annual International Fiscal Association Congress in Melbourne, Australia.
Listen now: taxnotes.co/4zMMd45
Treasury and the have IRS rolled out a new IRA compliance system that allows for the correction of unintentional errors caused by service providers and provides a waiver of the 60-day rollover requirement. taxnotes.co/4z5FJ0n
The IRS is looking beyond the technical treatment of disregarded entity debt as it reconsiders two letter rulings amid worries that taxpayers are using the guidance in those rulings to avoid cancellation of debt (COD) income, an agency official said. taxnotes.co/4i3hyK2
Treasury and the IRS are still targeting February 2027 to release revised proposed regulations addressing the corporate alternative minimum tax, an official said. taxnotes.co/3UIovqQ
A new specialty group within the IRS that will focus on attacking abusive tax shelters and schemes will also examine sophisticated issues like those related to private placement life insurance, IRS Chief Tax Compliance Officer Jarod Koopman told Tax Notes. taxnotes.co/4jHG44F
"The English Premier League is more than just football," @RobertGoulder writes. "It might be Britain’s greatest cultural export since the works of William Shakespeare." forbes.com/sites/taxnotes/20…
Design and creation elements don’t necessarily reclassify a work of art from the supply of a good to the supply of a service for VAT purposes, an advocate general to the EU’s General Court concluded. taxnotes.co/4jBjFpA
Bitters sold by a wine and spirits business aren't subject to spirit taxes because the products are not beverages, according to a Washington tax review officer. taxnotes.co/4jAGE44
A U.S. food importer is challenging Trump administration tariffs on Canadian goods in federal court, arguing that the tariffs are just the latest effort by the administration to appropriate power assigned to Congress. taxnotes.co/4jvybPB
Tax Notes retweeted
I recently chatted with @cady_stanton about how taxing AI and data centers echoes international tax conversations we've been having since the early 2000s tech boom. And involves many of the same protagonists.
Like old wine in bottles, but now the wine is fortified.
From @cady_stanton: Any changes to the tax treatment of data centers likely won’t move until the next Congress, despite a spike in federal legislative proposals on taxing the industry. taxnotes.co/4hYhRpl
Several Democrats on the House Ways and Means Committee are urging Treasury to explain the delayed release of filing season statistics that would shed light on the new tax law. taxnotes.co/487tvbz
Chicago Mayor Brandon Johnson (D) is moving ahead with plans to revive a corporate head tax and increase the personal property lease tax on corporations to address an $882 million budget gap. taxnotes.co/4yCNuKd
To secure a political mandate to negotiate with the European Parliament on the proposed 28th regime at an October 23 meeting, the Irish EU Council presidency drafted a statement to reassure them on the tax provisions. taxnotes.co/4yw1hlD
The OECD inclusive framework on base erosion and profit shifting will soon return to discussions on the taxation of the digital economy, likely by revisiting previous work on the issue, an OECD official said. taxnotes.co/4dNcabq
The Fifth Circuit has agreed to toss a district court decision finding that the assessment of civil foreign bank account reporting penalties violated an individual’s Seventh Amendment rights and send the case back for reconsideration. taxnotes.co/3VZdZMg
The top Senate Democratic taxwriter is asking the Big Four accounting firms to provide details on any work advising multinational corporations to offshore profits to low-tax jurisdictions, including Malta. taxnotes.co/3U6CoyY


