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Falls Church, VA
Joined January 2012
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
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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
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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
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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
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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
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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
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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
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"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…
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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
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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
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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.
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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
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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
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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
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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
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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
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