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Joined January 2012
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The IRS needs to implement a strategy to prevent the fraud schemes of noncompliant return preparers that could cost the agency millions, according to a watchdog’s report. taxnotes.co/3WNJTvp
A former property owner failed to prove that a county's foreclosure judgment against his former property was invalid, despite the foreclosure proceeding notices listing the wrong address, the state appellate court has ruled. taxnotes.co/4euhJvu
Chicago has launched a pilot program that provides up to $5,000 in property tax debt relief to help residents in certain communities keep their homes. taxnotes.co/4snUEjQ
Calls for a review of Canada’s tax system are mounting as a coalition headed by CPA Ontario urges the government to use its upcoming budget to support business and respond to U.S. tax reform. taxnotes.co/4ioHLSh
Only Finland, Hungary, Malta, and Slovakia objected to the proposed mandate to negotiate with the European Parliament on the optional 28th regime for innovative companies known as EU Inc. taxnotes.co/4zdNuS2
The IRS changed its approach to so-called friendly doctor arrangements after years of experience led it to become more comfortable assuming that the structures comply with state law, an agency official said. taxnotes.co/3WwKcL3
The government asked the Fifth Circuit to reverse a district court’s decision vacating Treasury’s microcaptive listed transaction regulations, arguing they lawfully required disclosure of arrangements that hold the potential for tax avoidance or evasion. taxnotes.co/4soCSgz
Perspective: Five Yulchon LLC practitioners examine South Korea’s transfer pricing method rules as applied to intangible transactions and the audit implications for taxpayers. taxnotes.co/4icPlzc
Perspective: Umberto Lorenzi and Stefano Urzì examine evolving Italian case law on interest-free intercompany loans and the development of commercial reasons as a possible justification for the absence of interest under the arm’s-length principle. taxnotes.co/4jsO9df
Perspective: Chris William Sanchirico and Reed Shuldiner identify the major policy challenges for circular partnerships and propose solutions for reform. taxnotes.co/4i1LbtG
Perspective: William Hays Weissman analyzes two recent California court decisions that held for the taxpayers and reinforced the limits of local taxation. taxnotes.co/4dNFs9I
Perspective: Jasper L. Cummings, Jr., examines how original issue discount rules apply to intercompany debt. taxnotes.co/4eJQM78
"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…
Perspective: Helena Thor explores the prerequisites for limited tax liability on carried interest in Germany. taxnotes.co/4idXS4R
Perspective: Billy Hamilton examines Florida’s proposed constitutional amendment to increase the homestead property tax exemption and restrict growth in assessments for nonhomestead properties. taxnotes.co/4sdeFd3
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. taxnotes.co/4ysomFN
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. taxnotes.co/47vkOaY
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