News & Analysis as of

Statutory Interpretation Tax Appeals

Hone Maxwell

Supreme Court Gives IRS Ability to Levy Taxpayers Without Tax Court Challenge

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In a pivotal ruling, the U.S. Supreme Court on June 12, 2025, held that the U.S. Tax Court lacks jurisdiction to hear a taxpayer’s Collection Due Process appeal under IRC § 6330 once the IRS can no longer pursue a levy,...more

Morgan Lewis

Los Angeles ‘Mansion Tax’ Update Regarding Office of Finance Assessments

Morgan Lewis on

Taxpayer disputes involving Los Angeles’s Measure ULA, the Homelessness and Housing Solutions Tax—commonly referred to as the “mansion tax”—are progressing through the city’s administrative review process. Property owners...more

Cadwalader, Wickersham & Taft LLP

YA Global Brings its Fight to the Appellate Level

On April 28, YA Global Investments, LP (“YA Global”) filed an appeal in the 3rd Circuit, contesting the Tax Court’s decision in YA Global Investments, LP v. Commissioner. In YA Global Investments, the court found that YA...more

Kilpatrick

4 Key Takeaways | Market Based Sourcing and Discretionary Adjustments

Kilpatrick on

On April 24th, Kilpatrick tax partner Jeff Reed presented during a New York City Bar SALT Committee meeting. Jeff discussed the recent Jefferies Group LLC & Subsidiaries New York Tax Appeals Tribunal decision....more

Cadwalader, Wickersham & Taft LLP

Asset Disposals in the "Real World"

The recent case of A Sajedi and others v HMRC [2025] UKFTT 297 (TC) in the UK First-tier Tribunal (“FTT”) is an interesting example of a UK taxation tribunal intervening to decide a litigated matter on grounds that neither...more

Blank Rome LLP

If You Don’t Ask, The Answer’s Always No

Blank Rome LLP on

One of the first rules of business is that you don’t leave money on the table. That adage is equally important in tax matters. Taxpayers can leave behind funds by failing to follow the rules. The importance of compliance with...more

Blake, Cassels & Graydon LLP

La Cour d’appel de la Colombie-Britannique confirme la cotisation de la taxe imposée aux acheteurs étrangers

La décision récente rendue dans l’affaire 1164708 B.C. Ltd. v. British Columbia (l’« affaire 1164708 B.C. Ltd. ») traite de l’applicabilité de la taxe supplémentaire sur les transferts de biens (property transfer tax) (la «...more

Blake, Cassels & Graydon LLP

B.C. Court of Appeal Upholds Assessment of Foreign Buyer Tax

The recent decision in 1164708 B.C. Ltd. v. British Columbia (1164708 B.C. Ltd.) addressed the applicability of the additional property transfer tax (ATT), commonly known as the “foreign buyer tax,” under British Columbia’s...more

Pullman & Comley, LLC

Jurisdiction 101: Connecticut Supreme Court Hands Down Win For Taxpayers

Pullman & Comley, LLC on

In a victory for taxpayers across the nutmeg state, the Connecticut Supreme Court recently held in 7 Germantown Rd., LLC v. City of Danbury, No. 21024, 2025 WL 309848 (Conn. Jan. 28, 2025) (“Germantown”) that the appraisal...more

McDermott Will & Emery

Supreme Court Overrules Chevron, Opening Door for New Tax Reg Challenges

McDermott Will & Emery on

On June 28, 2024, the Supreme Court of the United States reshaped the federal tax landscape when it overturned the long-standing Chevron doctrine in Loper Bright Enterprises v. Raimondo, No. 22-451. The Chevron doctrine, a...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Ground Source Heat Pump/Solar Energy System Equipment: New York Appellate Court Addresses Applicability of Tax Credit

The New York Supreme Court (Appellate Division) (“Court”) addressed in a January 9th decision the applicability of the New York Solar Energy System Equipment Tax Credit (“Tax Credit”) to a ground source heat pump system...more

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