Bloomberg Tax

Tax Developments

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Case: Motion to Reopen Denied Where No Extraordinary Circumstances Revealed Abuse of Discretion and New Evidence Would Not Change Outcome of the Case (5th Cir.) (IRC §6662)

New evidence must “probably ... change the outcome of the case” in order to meet the U.S. Tax Court’s standard for granting a motion to reopen, the Court of Appeals ...

Defendants’ Evidentiary and Sentencing Challenges to Tax-Related Convictions Were Without Merit (6th Cir.)

Appeal by Defendants, a local councilman and his executive assistant, alleging evidentiary and sentencing errors for tax-related convictions were without merit, the U.S. Court of Appeals for the Sixth Circuit ...

Case: District Court Had Subject Matter Jurisdiction Over Refund Claims, Administrative Procedures Act Challenge to Reportable Transaction Requirement Time-Barred (D.N.J.) (IRC §7422)

Plaintiffs, who sought a refund of penalties assessed for failing to report certain life insurance arrangements considered reportable transactions under Notice 2007-83, and whose previous complaint had been dismissed, exhausted ...

OECD's Manal Corwin Talks Next Steps in Global Tax Deal

Tax Firms Expand as Clean Energy Credit Demand Grows

IRS Cracks Down on NIL Collectives' Tax-Exempt Status

The Politics of the Global Tax Deal, and What's Next

From the Analysts

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Brazil’s Transfer Pricing Rules Create Compliance Challenge

Recent changes to Brazil’s transfer pricing rules mean multinational companies should start preparing for the application of new transaction methods, the arm’s length principle, and revised documentation requirements. Early adopters can start complying this year, though the new regime doesn’t take effect until 2024.

BTAX OnPoint: 2023 State Tax Department Survey

States must deal with the need to expand and modernize their tax policies to address emerging technologies, they told Bloomberg Tax in an annual survey.

How States are Taxing Electric Vehicle Charging

EV charging stations have landed in the crosshairs of states trying to make up for lost gas tax revenue, even while legislators are using incentives to propel the green energy transition.

Free Tax Filings Threaten $4 Billion TurboTax Business

Bloomberg Tax Journals

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How Brazilian Usufructs Can Be Used for Wealth Planning

Paul DePasquale of Baker McKenzie and Flávia Gerola of Trench Rossi Watanabe address usufructs as a wealth-planning tool for Brazilian families and relevant points of attention when dealing with US connections.

How US Employers Provide Health Plans to Puerto Rico Employees

US companies operating in Puerto Rico generally can offer their local employees the same health care benefits they offer their US employees but need to consider differences in the tax rules and be aware of tax savings opportunities, says Carlos Gonzalez of

GILTI Regs Support Foreign-Source Dividend Treatment by States

BDO’s National Technical Practice Leader for state and local taxes, Scott Smith, provides his take on whether states should treat global intangible low-taxed income as a foreign-source dividend for corporate income tax purposes.

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