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8th Circ. To Weigh In On 3M’s Fight Over Income Allocations

by usoftax_admin | Jan 3, 2024 | Tax News

The Eighth Circuit will hear 3M’s challenge to a U.S. Tax Court ruling that kept it on the hook for $23 million in taxes tied to earnings that the IRS allocated from the company’s Brazilian affiliate under contested regulations.  

10th Circ. To Hear Liberty Global’s $109M Tax Refund Case

by usoftax_admin | Jan 3, 2024 | Tax News

Telecommunications company Liberty Global Inc. has appealed to the Tenth Circuit regarding a Colorado federal court’s decision that denied the company a $109 million tax refund claim by concluding that underlying intercompany transactions lacked economic...

Deloitte – EMEA regional indirect tax interview (iii)

by usoftax_admin | Jan 3, 2024 | Tax News

Interview with Krzysztof Wilk, partner, Deloitte Poland

IRS may use group status in setting TP loan rates

by usoftax_admin | Jan 3, 2024 | Tax News

The US Internal Revenue Service could consider a company’s membership in a corporate group when deciding on an interest rate for an intragroup loan extended to the firm

Fed. Circ. Shoots Down Bid To Revive $550M In Fuel Credits

by usoftax_admin | Jan 3, 2024 | Tax News

The Federal Circuit on Wednesday denied a Philadelphia energy company $550 million in tax credits reserved for alternative fuels, becoming the third appellate court to conclude that a mixture of butane and gasoline doesn’t qualify as an alternative fuel...

Ayahuasca Church Pushes Back On IRS Claims At DC Circ.

by usoftax_admin | Jan 2, 2024 | Tax News

An Iowa church that has used a federally prohibited psychedelic as part of its rites is contesting the IRS’ assertion that it only exists for illegal purposes, telling the D.C. Circuit it is committed to obeying the law.
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