News & Analysis as of

Tax Appeals

Rivkin Radler LLP

Unconstitutionally Excessive FBAR Penalties? It Depends

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You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more

Tucker Arensberg, P.C.

Allegheny County Moves Tax Appeal Deadline to October 1 - Limited Time for Assessment Relief

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In Allegheny County, tax appeal season has already begun for 2025. For every tax year, County property owners have the ability to file an assessment appeal. ...more

Kilpatrick

5 Key Takeaways - New York Tax Update

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On September 5th, Kilpatrick tax partner Jeff Reed presented during a webinar hosted by HalfMoon Education, Inc. The webinar discussed recent New York tax developments. Here are five key takeaways from the webinar...more

Bricker Graydon LLP

Nexus Pipeline Settlement Update

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The Nexus Pipeline (Nexus), which transports natural gas from eastern Ohio to Canada, was placed in-service in 2018. Nexus appealed its initial tax valuation in November 2019 and ultimately reached a settlement regarding tax...more

Mayer Brown

New Trial Method at CARF: Virtual Plenary - MF Ordinances No. 1,239 and 1,240/2024

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On August 5, 2024, Brazilian Ministry of Finance (MF) Ordinances No. 1,239 and 1,240/2024 were published in the Federal Official Gazette, providing operating rules for non-concurrent sessions of the Administrative Tax Appeal...more

Cadwalader, Wickersham & Taft LLP

Burlington: Good News for the Secondary Debt Market

In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) (“Burlington”) the Upper Tribunal (“UT”) dismissed HMRC’s appeal, holding that the First-tier Tribunal (“FTT”) was right to conclude that the anti-abuse provision...more

Ballard Spahr LLP

Pennsylvania: It’s Time to Appeal Your Real Estate Taxes

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The Pennsylvania deadlines for appealing 2025 real estate taxes are fast approaching. There are several factors to consider in determining whether to appeal....more

Vinson & Elkins LLP

IRS’s Alternative Dispute Resolution Has Room for Improvement

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The IRS Independent Office of Appeals has renewed its focus on alternative dispute resolution (ADR). In this article, V&E counsel Stephen Josey examines the ADR program and dives into how the agency can tweak its mediation...more

McDermott Will & Emery

Supreme Court Overrules Chevron, Opening Door for New Tax Reg Challenges

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On June 28, 2024, the Supreme Court of the United States reshaped the federal tax landscape when it overturned the long-standing Chevron doctrine in Loper Bright Enterprises v. Raimondo, No. 22-451. The Chevron doctrine, a...more

McDermott Will & Emery

California Legislatively Overturns Recent Office of Tax Appeals Taxpayer Win

The California State Legislature overturned Microsoft’s recent win at the Office of Tax Appeals, which held that the gross amount of dividends received from foreign affiliates outside its water’s-edge group should be included...more

Holland & Knight LLP

Colombia: Alivios y efectos tributarios Plan de Desarrollo "Bogotá Camina Segura" (2024 a 2027)

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Con el Acuerdo Distrital 927 de junio 11 de 2024, el Concejo Distrital de Bogotá aprobó el Plan de Desarrollo "Bogotá Camina Segura" para los años 2024 a 2027 del Alcalde Carlos Fernando Galán, del cual destacan los...more

Blank Rome LLP

NYS Tax Appeals Tribunal Finds SaaS Fees Are Subject to Sales Tax

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The New York State Tax Appeals Tribunal recently upheld a sales tax assessment issued to a company that provided services to customers mostly through what the company described as a software-as-a-service (“SaaS”) model. In...more

Holland & Knight LLP

Tax Court: As to Listed Transaction, IRS Must Adhere to APA

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In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more

Jackson Lewis P.C.

New York Expands Rationale For State Income Tax “Convenience Rule”

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The November 30, 2023, opinion of a New York administrative law judge in In the Matter of the Petition of Edward A. and Doris Zelinsky upholds the state’s so-called income tax “convenience rule” with an expanded legal...more

Buckingham, Doolittle & Burroughs, LLC

What to Do If Your Business Receives a Tax Audit

When your business receives an audit engagement letter, don’t panic. While an audit may be time-consuming, costly, and invasive, having an experienced advocate on your side to navigate you through the process and represent...more

Sherman & Howard L.L.C.

Colorado Property Tax Appeals, Part 2

Property taxes play a crucial role in supporting our local communities. The revenue generated from property taxes goes directly toward funding public schools, county governments, special districts, municipal governments, and...more

Cadwalader, Wickersham & Taft LLP

Complex Borrowing and Group Structures

The Court of Appeal’s (“CA”) ruling in April 2024 in the case of BlackRock Holdco 5 LLC v HMRC (“BlackRock”) considered the deductibility of interest on a $4 billion intra-group loan put in place as part of the funding...more

Nelson Mullins Riley & Scarborough LLP

Navigating South Carolina Tax Sales: County’s Posting of Conspicuous Notices

In an unpublished opinion released on May 12 in Grayson Dailey v. SC Home Holdings, LLC (Op. No. 2024-UP-164), the South Carolina Court of Appeals upheld the tax sale of real property in Lexington County over the objection of...more

Sherman & Howard L.L.C.

Colorado Property Tax Appeals

Property taxes are on the rise in Colorado, and many residents are looking for ways to appeal their property tax assessments. If you own real property, it is essential to understand the process of review and appeal, known as...more

Cadwalader, Wickersham & Taft LLP

“Ephemeral” Payments and Beneficial Entitlement

Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises.  The decision of the UK’s Court of Appeal in Hargreaves Property Holdings Limited [2024] EWCA Civ 365,...more

Rivkin Radler LLP

IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability

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Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more

Blank Rome LLP

Microsoft Prevails in California Dispute on Inclusion of Gross Foreign Dividends in Apportionment Formula

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In a decision that may have significant repercussions regarding apportionment for California corporate tax purposes, the California Office of Tax Appeals (“OTA”) has denied the Franchise Tax Board’s (“FTB”) petition for a...more

Bricker Graydon LLP

Supreme Court of Ohio Rules Extraterritorial Municipal Income Taxation Constitutional During Covid-19 Emergency

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On February 14, 2024, the Supreme Court of Ohio issued a 5-2 decision holding it was constitutional for a municipality to continue levying income taxes on employees performing work beyond municipal boundaries during the...more

Holland & Knight LLP

California OTA Ruling Favors Microsoft on Foreign Dividend Sales Factor Treatment

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The California Office of Tax Appeals (OTA) denied a request for rehearing of a July 2023 OTA opinion favorable to Microsoft Corp. that could have wide-ranging impacts for a water's edge filer in California, particularly one...more

McDermott Will & Emery

Microsoft Scores Massive Win in California, Opens the Door for Others Nationwide

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The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also...more

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