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Calls To Taxpayer Advocates Go To Voicemail, TIGTA Says

by usoftax_admin | Aug 2, 2024 | Tax News

The Treasury Inspector General for Tax Administration called all 76 local Taxpayer Advocate Service phone lines to test their availability and only had calls answered twice, it said Friday, calling on the service to improve its monitoring of the lines.

Treasury Faces Complicated Path For Amount B Pricing Rules

by usoftax_admin | Aug 2, 2024 | Tax News

The U.S. Treasury Department signaled it is considering how to enact the OECD’s routine pricing plan known as Amount B, but U.S. tax attorneys expect a complicated compliance exercise if rulemakers establish the new transfer pricing approach.

Coca-Cola Poised To Appeal $2.7B Tax Bill With 11th Circ.

by usoftax_admin | Aug 2, 2024 | Tax News

The U.S. Tax Court signed off Friday on Coca-Cola’s $2.7 billion tax bill, setting the stage for the beverage giant to appeal the liabilities and related rulings in its long-running dispute over the IRS’ reallocation of the company’s foreign...

IRS Tells Tax Court AbbVie’s $1.6B Break Fee Is A Capital Loss

by usoftax_admin | Aug 2, 2024 | Tax News

The Internal Revenue Service correctly reclassified AbbVie’s $1.6 billion break fee to an Irish biotechnology company as a capital loss, the agency told the U.S. Tax Court, arguing that the failed merger is tantamount to disposing of property.

Taxation With Representation: Sullivan, Dechert, Kirkland

by usoftax_admin | Aug 2, 2024 | Tax News

In this week’s Taxation With Representation, BNP Parabis SA acquires an investment management subsidiary for €5.1 billion, Cleveland accounting firm CBIZ merges with competitor Marcum for $2.3 billion, and Arcosa Inc. inks a deal with a family-owned construction...

Liberty Global’s $110M Tax Refund Kosher, 10th Circ. Told

by usoftax_admin | Aug 2, 2024 | Tax News

The IRS is trying to block Liberty Global’s bid for a $110 million tax refund by improperly using a legal doctrine requiring transactions to have economic substance, the telecommunications giant told the Tenth Circuit, arguing it was allowed to make tax-driven...
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