Tax Notes

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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." https://t.co/gvOvhK3YrZ

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Perspective: Helena Thor explores the prerequisites for limited tax liability on carried interest in Germany. https://t.co/6bEj5NRWP8

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Perspective: Billy Hamilton examines Florida’s proposed constitutional amendment to increase the homestead property tax exemption and restrict growth in assessments for nonhomestead properties. https://t.co/NHiVoOczRy

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Perspective: Eman Cuyler examines recent appellate decisions addressing the section 6213(a) deadline for filing Tax Court deficiency petitions and the growing divide among circuit courts over whether the deadline is subject to equitable tolling. https://t.co/gRrVNgJqqK

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Perspective: Raffaele Petruzzi and Siddharth Jain examine the changes to permanent establishments, transfer pricing, and tax certainty from the 2025 update to the OECD’s model tax convention. https://t.co/3oqJ3IdAgl

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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. https://t.co/GBSMJBGJ44

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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. https://t.co/5zM1tVmRke

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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. https://t.co/IAPch8NvIX

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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. https://t.co/aLXYMDp5VQ

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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: https://t.co/ymIMOvdfaY

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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. https://t.co/NQcGT7mXOS

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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. https://t.co/poP89nCw28

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Treasury and the IRS are still targeting February 2027 to release revised proposed regulations addressing the corporate alternative minimum tax, an official said. https://t.co/X5FQ442pCG

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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. https://t.co/1IAup1Evfo

[Tax Notes @TaxNotes]

"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." https://t.co/gvOvhK3YrZ

[Tax Notes @TaxNotes]

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. https://t.co/v6vX1pEHrz

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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. https://t.co/wOMj4ZbDIg

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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. https://t.co/P0Gpd4jKL3

[Zorka Milin @ZorkaMilin]

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.

[Tax Notes @TaxNotes]

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. https://t.co/zR8z83qhqZ