4 Key Takeaways | NY Sales Tax on Cloud-Based Document Management Services
Jones Day Presents: Large Business & International Examination Strategies: Fast Track Settlements
Jones Day Presents: LB&I Examination Strategies: Acknowledgement of Facts IDR
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
In the fictional world of John Wicks, the High Table enforces a strict code of conduct without which the lives of its inhabitants would mimic life in a Hobbesian state of nature. However, as dangerous and as rule-bound as...more
The Mexican Supreme Court of Justice (Suprema Corte de Justicia de la Nación or SCJN) upheld the authority of the Tax Administration Service (Servicio de Administración Tributaria or SAT) to require compliance with certain...more
The gigantic American Dream Mall located in East Rutherford, New Jersey challenged its tax assessments for the years 2019-2025 before the New Jersey Tax Court. ...more
In an unusually taxpayer-friendly decision, a three judge panel of the Pennsylvania Commonwealth Court concluded that Section 406 of the Tax Reform Code of 1971 (the code), 72 P.S. § 7406, is an exception to the general...more
Le ministère des Finances a publié récemment des projets de propositions législatives visant à mettre en œuvre des mesures élargissant les pouvoirs de vérification de l’Agence du revenu du Canada (l’« ARC »)....more
The New York State Tax Appeals Tribunal, affirming an Administrative Law Judge, held that the Internet Tax Freedom Act prohibits the Division of Taxation from subjecting to tax the receipts that Verizon New York, Inc....more
In a recently released, nonprecedential decision, the California Office of Tax Appeals (“OTA”) upheld a sales tax assessment of nearly $1 million against an owner/operator of dental practices, finding that the sale of the...more
ADMINISTRATIVE LITIGATION - Introduction: Tax Reform and the Possible Increase in Litigation; Operation of IBS tax inspection...more
The California Attorney General has confirmed the Office of Tax Appeals (OTA) may decline to apply a tax regulation in a taxpayer appeal if it conflicts with the relevant statute. OTA must afford appropriate deference to the...more
Since the poles were personal property (i.e., business fixtures), the taxpayer’s purchase was subject to Ohio sales / use tax unless an exemption applied. In Conduent State & Local Solutions, Inc. v. Harris, Ohio BTA Case No....more
Germany’s Federal Fiscal Court (BFH) has decided on the legitimacy of double assessment of real estate transfer tax in share deals. Tax authorities have taken the view that the acquisition of at least 90% of shares in a...more
Kilpatrick’s Jordan Goodman recently spoke at the Council On State Taxation – 2025 SALT Technology Workshop in the San Francisco Bay Area about the “The Top SALT Taxes Impacting the Technology Sector”. This workshop covered...more
Aramark provided food service operations to various clients (e.g., hospitals, universities, corporations, sports arenas, etc.). The clients paid Aramark a management fee. In addition, the clients reimbursed Aramark for the...more
Substitute House Bill 96 (H.B. 96), Ohio’s operating appropriations bill for fiscal years 2026 –-2027, was passed by the General Assembly on June 25, 2025 and signed by Ohio Governor Mike DeWine on June 30, 2025. The...more
On August 13, 2025, the Ohio Supreme Court overturned the Ohio Board of Tax Appeals (BTA) and the Ohio Tax Commissioner in Claugus Fam. Farm, L.P. v. Harris, 2025-Ohio-2807, Slip Opinion No. 2025-Ohio-2807, thereby allowing...more
The California Attorney General (AG) recently issued Legal Opinion No. 23-701 stating that the California Office of Tax Appeals (OTA) has the authority to determine whether tax regulations issued by the Franchise Tax Board...more
In proceedings to suspend enforcement, the German Federal Fiscal Court has expressed serious doubts about the administrative practice of imposing double real estate transfer tax in share deals. In particular, the court...more
On July 25, 2025, the U.S. Court of Appeals for the Eighth Circuit affirmed the District Court decision holding that the Mayo Clinic is entitled to an $11.5 million refund of certain unrelated business income taxes imposed on...more
A recent decision from the Ontario Court of Appeal is a good reminder that courts won’t bail you out just because a tax plan didn’t go as expected. In Pyxis Real Estate Equities Inc. v. Canada, 2025 ONCA 65, the Court made it...more
If you own retail, office, industrial or other commercial property in Pennsylvania, now is the time to review the tax assessment for your property against its current market value. The increase in interest rates has caused...more
The Internal Revenue Service continues to experience significant leadership transition during a period of ongoing internal upheaval and uncertainty. The latest developments are the appointment of Kenneth Kies as the new...more
In an opinion issued on May 15, 2025, the State of New York Tax Appeals Tribunal, the highest administrative forum for state tax appeals, upheld the application of the state’s income tax “convenience rule” imposing New York...more
The latest budget passed by the New Jersey legislature and signed by term-limited Governor Phil Murphy quietly enacted changes to New Jersey’s Mansion Tax, which affects not only residential properties but commercial...more
In Allegheny County, the tax appeal season will begin shortly for 2026. For every tax year, County property owners can file an assessment appeal. But allegedly, to continue providing certainty to taxpayers and taxing bodies...more
Le Conseil d'État réaffirme l’impossibilité pour l’administration fiscale de se fonder sur des correspondances entre un avocat et son client dans le cadre de procédures de redressement, tout en précisant que cette...more