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Taxation Tax Appeals

Mayer Brown

Tax Law Highlights - Impact of the Tax Reform on Administrative and Judicial Litigation: Jurisdiction and Related Issues

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ADMINISTRATIVE LITIGATION - Introduction: Tax Reform and the Possible Increase in Litigation; Operation of IBS tax inspection...more

Pillsbury - SeeSalt Blog

Putting Regulations to the Test: California Taxpayers Cleared to Challenge Regulations in OTA Appeals

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

Paul Hastings LLP

German Federal Fiscal Court Questions Double RETT on Share Deals

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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

Vorys, Sater, Seymour and Pease LLP

Ohio General Assembly Makes Changes to Real Property Complaint Process

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

Vorys, Sater, Seymour and Pease LLP

Ohio Supreme Court Doubles Down on Applying a Plain and Ordinary Meaning to Sales Tax Exemptions

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

Proskauer - Tax Talks

Eighth Circuit Affirms Mayo Clinic’s “Educational Organization” Status and UBTI Refund

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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

Dickinson Wright

Tax Planning Misstep? Ontario Court of Appeal Says No to Rectification

Dickinson Wright on

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

Fox Rothschild LLP

IRS Leadership Turmoil Continues With Appointment of Yet Another Acting Chief Counsel While Chief of Appeals Announces Retirement

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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

Jackson Lewis P.C.

Remote Work Challenges After New York Tax Appeals Tribunal Upholds Income Tax “Convenience Rule”

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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

Eversheds Sutherland (US) LLP

Eversheds Sutherland SALT Scoreboard – Quarter 1, 2025

This is the first edition of the Eversheds Sutherland SALT Scoreboard for 2025. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...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

McDermott Will & Schulte

ALJ Rules That a Taxpayer Is a Qualified New York Manufacturer Even Though Qualifying Property Was Operated by a Third Party

The New York State Division of Tax Appeals determined that E. & J. Gallo Winery is a qualified New York manufacturer (QNYM) even though its only property in New York that could allow it to qualify for QNYM classification – a...more

Rivkin Radler LLP

New York Examines Federal Income Tax Issues –Conformity and . . . Disclosure?

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Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve...more

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