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Tax Developments

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IRS PLR: Prior PLR Revoked, Taxpayer’s Per Incident Combined With Reimbursement Contracts Not Insurance (IRC § 831)

The IRS has published a private letter ruling on Section 831 revoking a prior private letter ruling that had determined that taxpayer’s 1997 contract X with a certain manufacturer was ...

IRS Notice: Extension of Temporary Relief for Foreign Financial Institutions Required to Report U.S. Taxpayer Identification

The IRS announced the extension of temporary relief for foreign financial institutions (FFIs) required to report U.S. taxpayer identification numbers for certain preexisting accounts. The temporary relief extends the temporary ...

IRS News Release: IRS, Security Summit Partners Remind Taxpayers to be Wary of Online Threats

The IRS and Security Summit partners Oct. 28 reminded taxpayers to be wary of online threats like identity theft and fraud. The partnership encourages everyone to be aware of the ...

Tax Pros Grapple With Complex Corporate Book Tax Rules

Reading Signals From Apple's $14 Billion EU Tax Ruling

How House Democrats Are Readying for 2025 Tax Talks

Tax Bill, Appropriations Loom as Lawmakers Come Back

From the Analysts

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BGOV OnPoint: Candidates Float Light-on-Detail Tax Ideas

The Trump and Harris campaigns have discussed tax policy at a high level, including how to deal with the expiration after 2025 of several provisions in the 2017 GOP tax overhaul.

BTAX OnPoint: Key California Tax Changes

California recently enacted legislation amending multiple provisions of the state’s income and sales and use tax laws. Together these changes are projected to increase taxes by billions of dollars per year, helping to close the state’s budget gap.

BGOV OnPoint: ‘Chevron’ Demise Changes Rulemaking, Legislating

The linked OnPoint reviews details of the June 28 US Supreme Court ruling rejecting a doctrine permitting federal courts to defer to an executive branch agency’s interpretation of an ambiguous law, overturning a 40-year-old precedent.

Best Buy, Apple, Others Make Millions From California Tax Deals

A few dozen California cities have lucrative deals with retail giants like Apple, Best Buy, and Nike. These deals result in the cities paying millions of dollars from their local tax revenue back to the companies. In this video, we explore how these deals work and what some city and state lawmakers are hoping to do about it.

Bloomberg Tax Journals

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How LATAM’s Principal Purpose Tests Impact Holding Companies

The adoption of anti-treaty shopping measures like the PPT in Latin American jurisdictions complicates the analysis of whether treaty benefits will continue to be available for holding companies, and the scope of protection for a grandfathered holding structure remains unclear, say KPMG practitioners.

New Regs Implement SECURE Changes to Plan Distributions (Part 1)

Dive into the new IRS regulations affecting retirement plan participants and beneficiaries with Kathryn J. Kennedy, former professor of law at the University of Illinois, for this first part of a two-part article series.

Scrutinize Your Buy-Sell Agreements in the Wake of ‘Connelly’

The U.S. Supreme Court’s June 6, 2024 determination in Connelly v. United States, that a corporation’s life insurance policy held for redemption of a deceased shareholder’s stock increases its fair market value, will significantly affect many buy-sell agreements, many of which utilize life and disability insurance as the ideal funding mechanism for payment of the purchase price upon death, disability, or retirement.

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FROM ACROSS BLOOMBERG TAX

Daily Tax Report: InternationalDaily Tax Report: StateTransfer Pricing ReportThe Exchange: Tax Insights & Commentary
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  • Transfer Pricing Report
  • The Exchange: Tax Insights & Commentary