Tax Notes

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[Tax Notes @TaxNotes]

Perspective: Robert Willens examines Shell PLC’s planned acquisition of ARC Resources Ltd., which will be taxable, and how the transaction could qualify for nonrecognition treatment under section 351. https://t.co/8jqSzRybRU

[Tax Notes @TaxNotes]

Perspective: Tony Santiago examines the gap between expectations and reality regarding artificial intelligence in tax and how it could strain the professional tax ecosystem. https://t.co/cjnln4BDvd

[Tax Notes @TaxNotes]

Perspective: Rachel Cook examines from a U.K. perspective how taxpayer mobility and intelligence-led enforcement are reshaping global compliance, increasing cross-border exposure to tax risk. https://t.co/IiDSV6XvSj

[Tax Notes @TaxNotes]

Perspective: Jacques Malherbe and Rik Strauven examine the conditions that have prompted a newly proposed Belgian digital services tax. https://t.co/BRYEwZ6zqu

[Tax Notes @TaxNotes]

Perspective: Jasper L. Cummings, Jr., examines how modifiers accompanying the term “trade or business” can change its meaning, exploring the twin presumptions that words always have the same meaning and different words mean different things. https://t.co/n2HkkbKe75

[Tax Notes @TaxNotes]

Perspective: Billy Hamilton examines tax proposals in Arkansas, California, Colorado, and Florida, finding that the issues may bleed over beyond the legislative session. https://t.co/nMsg4QOgsm

[Tax Notes @TaxNotes]

Perspective: Scott Levine explores the reasons behind Europe’s struggles to foster world-class technology companies despite its world-class scientists and engineers. https://t.co/XgncpFJtCc

[Tax Notes @TaxNotes]

"I think there were a couple of lessons learned from Congress's flirtation with section 899," Danielle Rolfes said. "The first one was that it worked." https://t.co/W0R5NBGvcu

[Tax Notes @TaxNotes]

Gov. Mike Dunleavy (R) must once again decide whether to approve legislation that would change Alaska’s apportionment laws by adopting market-based sourcing of sales. https://t.co/wOfwaBZpqD

[Tax Notes @TaxNotes]

Subsidiaries of Tyson Chicken Inc. are not eligible for a sales tax exemption on rented wooden pallets used for delivery of the chickens, the Arkansas Supreme Court held. https://t.co/QjQJutM9oh

[Tax Notes @TaxNotes]

The Canadian government has called for the country’s communications regulator to reconsider its controversial decision to require large foreign streaming services to effectively pay a tax to facilitate the implementation of the Online Streaming Act. https://t.co/cQr5KYZGTP

[Phyllis Jo Kubey @PKubeyEA]

@taxnotes @taxtrevor in yesterdays Tax Court

[Tax Notes @TaxNotes]

While member states deleted tax references from the draft regulation on pan-European personal pension products (PEPPs), the European Commission called on the European Parliament to push for the tax measure in the upcoming negotiation. https://t.co/UtgO3wNsbe

[Tax Notes @TaxNotes]

A Democratic and a Republican senator jointly told a federal court that the Trump administration’s “Anti-Weaponization” Fund violates the Constitution’s spending, appropriations, and appointments clauses and should be permanently enjoined. https://t.co/0o29pOy6CQ

[Tax Notes @TaxNotes]

The IRS is reexamining private letter rulings that effectively allow some distressed companies to avoid cancellation of debt income and preserve tax attributes in bankruptcy restructurings. https://t.co/lMLZBcvUii

[Tax Notes @TaxNotes]

JUST IN: Treasury and the IRS have announced the intent to release proposed regulations regarding the excise tax on excess executive compensation for tax-exempt organizations. https://t.co/kVPXqfedXP

[Tax Notes @TaxNotes]

NEW: Brian Reed of @alvarezmarsal discusses the application of the economic substance doctrine in Liberty Global Inc. v. United States and the questions raised by the Tenth Circuit's interpretation.

Listen wherever you get your podcasts. 👇 https://t.co/VH5JAuXVsH

[Tax Notes @TaxNotes]

A taxpayer’s cryptocurrency staking rewards totaling over $33,000 were taxable and should have been reported as income because he had dominion and control over the assets, according to the Tax Court.

Read more from @taxtrevor: https://t.co/PZsGPuo6Bl

[Katie Lobosco @KatieLobosco]

Several experts told @taxtrevor that the agreement banning the IRS from pursuing tax claims against Trump is not normal or precedented because it 1) applies to more than one year and 2) includes "affiliates" who weren't parties in the lawsuit

[Tax Notes @TaxNotes]

Treasury and the IRS are aiming to issue proposed regulations on the newly permanent passthrough deduction this summer, according to Kevin Salinger, Treasury deputy assistant secretary for tax policy. https://t.co/MPvjrpsbKd