Daily Tax Report ®

State Challenge to SALT Cap Rule Should Be Barred, Treasury Says

Hochul Calls Trump Advisers’ SALT Cap Proposal ‘Empty Gesture’

OECD Plans Transaction, Incentive Rules Under Global Tax

Countries involved in the OECD tax deal negotiations are working on guidance to determine how certain transactions and incentives will be treated under the global minimum tax, a Treasury official said Thursday.

Swiss Government Rejects Proposed Super-Rich Inheritance Tax

Two Tax Firms Seek to Block IRS’s Automatic Credit Processing

ExxonMobil Tax Refund Inapplicable to Liberty Global, IRS Says

Canada Weighs Uranium, Oil Export Tax to Push Back on Trump

Fuel Producers Prep for Tax Credit Without IRS Rules (Podcast)

Fuel producers are trying to prepare for a tax credit regime change, even though the Treasury Department has failed to issue rules around those credits.

PRACTITIONER INSIGHTS

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Ireland’s Global Minimum Tax Rules Honor Commitment to Reforms

Robert Dever

Pinsent Masons

State Tax Fairness Advocates to Push Back on Corporate Tax Cuts

Amber Wallin

State Revenue Alliance

Sunsetting Tax Cuts Suggests a Shift to Business Protection Mode

David Stewart

Squire Patton Boggs

Tax Developments

IRS Internal Revenue Bulletin: 2024-51 IRB Released

The IRS has published its Internal Revenue Bulletin. [Internal Revenue Bulletin 2024-51 (Dec. 16, 2025)]

IRS Notice: Extension of Time for Partnerships to Provide Forms 8308 for Exchanges Occurring in 2024 (IRC §751)

Relief for calendar year 2024 (similar to the relief provided in Notice 2024-19 for calendar year 2023) from certain penalties under I.R.C. §6722, imposed for failures by certain partnerships to ...

Case: Taxpayer Failed to Formally Exhaust Administrative Remedies for Refund Claim Before Initiating Litigation; Court Lacked Subject Matter Jurisdiction (D.C.C.) (IRC §7422)

Taxpayer failed to properly exhaust administrative remedies before filing suit for a refund, held the district court, granting the government’s motion to dismiss for lack of subject matter jurisdiction. Taxpayer, ...

PODCASTS

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IRS Audits of Intercompany Transactions Build Steam

What Trump Victory Holds for IRS, Upcoming Tax Talks

Corporate Tax Leaders Weigh AI's Risk-Reward Calculus

Tax Pros Grapple With Complex Corporate Book Tax Rules

From the Analysts

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: OECD’s Pillar 2 Subject to Tax Rule

The Subject to Tax Rule allows developing countries that are members of the OECD’s Inclusive Framework to reclaim some source jurisdiction taxing rights ceded under tax treaties with developed nations.

BTAX OnPoint: US Country-by-Country Reporting

US country-by-country reporting requirements for large companies form a significant part of the data that informs the Pillar 2 initiative.

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

CAMT Series Part 1: What Are the Basic Rules for Calculation?

Baker McKenzie practitioners present the first in a series of articles analyzing the proposed CAMT regulations.

Examining the Taxation of Digital Services in Zambia

Zambia’s VAT Cross Border Electronic Services Regulations enhance the administration of VAT in the evolving global landscape of digital and electronic services and has helped Zambia become an attractive market for international digital service providers, say Corpus Legal practitioners.

Courts Worldwide Diverge in Applying the Principal Purpose Test

Although over 100 countries have signed the Multilateral Instrument, courts around the world have diverged in their application of the Principal Purpose Test, says Christos A. Theophilou of STI Taxand.

Latest Stories

France’s Credit Rating Cut as Political Crisis Imperils Finances

Moody’s Ratings cut France’s credit grade, heaping pressure on the new government to bring a ballooning deficit under control after far-right leader Marine Le Pen toppled the previous prime minister over a budget dispute.

By Zoe Schneeweiss, William Horobin and Phil Serafino

IRS Lowers 2025 Target for Partnership Audits as New Hires Train

The IRS plans to open 3,600 audits into partnerships in fiscal year 2025—a lower goal than the previous year’s—as it ramps up training of new hires.

Widow Sues US for Tax Refund of Unprocessed Theft Loss Deduction

A widow sued the US Friday seeking over $39,000 for a theft loss deduction for 2021 and a recovery of $5,000 in penalties, which she claims was made in error, according to a federal lawsuit.

Treasury Details Plans for International Tax Regulations

The Treasury Department on Friday detailed plans to release regulations on several international tax issues.

FROM ACROSS BLOOMBERG TAX

Daily Tax Report: International

Daily Tax Report: State

Transfer Pricing Report

The Exchange: Tax Insights & Commentary

Daily Tax Report: International
Daily Tax Report: State
Transfer Pricing Report
The Exchange: Tax Insights & Commentary

Canada Gazettes Consolidated Text of Income Tax Act

The Canadian Official Gazette Dec. 10 published Act No. R.S.C., 1985, c. 1, on the consolidated text of the Income Tax Act, as of Nov. 26. [Canada, Government Legal Database, ...

Canada Gazettes Consolidated Text of Income Tax Application Rules

The Canadian Official Gazette Dec. 10 published Act No. R.S.C., 1985, c. 2, on the consolidated text of the Income Tax Application Rules, as of Nov. 26. [Canada, Government Legal ...

Canada Gazettes Consolidated Text of Income Tax Regulations

The Canadian Official Gazette Dec. 10 published Regulation No. C.R.C., c. 945, on the consolidated text of the Income Tax Regulations, as of Nov. 26. [Canada, Government Legal Database, 12/10/24] ...

Jersey Gazettes Entry Into Force Date for 2025 Budget Law

The Jersey Official Gazette Nov. 29 published Law No. 72/2024, announcing the same date entry into force of Finance (2025 Budget) (Jersey) Law 202. [Jersey, Government Legal Database, 11/29/24]

Lithuania MOF Announces Government Approval of Draft Law to Ratify DTA With Taiwan

The Lithuanian Ministry of Finance Dec. 11 announced the government approval of a draft law to ratify the DTA with Taiwan. [Lithuania, Ministry of Finance, 12/11/24]

United Kingdom Gazettes Welsh Statutory Instrument on Land Transaction Tax Rates for Residential Property Transactions

The United Kingdom Official Gazette Dec. 10 published Welsh Statutory Instrument No. 1311/2024, amending land transaction tax rates for higher rates residential property transactions in Wales. The statutory instrument includes ...

Amazon Owes $12.5 Million in Sales Tax, South Carolina Says

Amazon is responsible for about $12.5 million in sales and use taxes because it’s a seller under state law, and was so even before an amendment expanding responsibility to “marketplace facilitators” was in effect, South Carolina’s tax agency told the state’s high court.

Illinois DOR Releases Bulletin on Implementation of Illinois Gives Tax Credit Act

The Illinois Department of Revenue (DOR) released Informational Bulletin FY 2025-14 in December 2024, detailing the implementation of the Illinois Gives Tax Credit Act. Effective for tax years ending on ...

California CDTFA Adopts Regulations Regarding Filing Sales, Use Tax Redetermination Petitions

The California Department of Tax and Fee Administration (CDTFA) Dec. 11 adopted regulations concerning filing sales and use tax redetermination petitions. The rules include the procedures for filing petitions relating ...

Chicago Budget Vote Delayed to Next Week Amid Tax-Hike Rift (1)

Chicago Mayor Brandon Johnson, lacking the votes to pass his budget on Friday, said his administration will negotiate with aldermen through the weekend to garner enough support by next week for approval of his $17.3 billion spending plan for 2025.

NY Tax Tribunal Focuses on 'Necessity' in Remote Work Challenge

A closely monitored challenge to New York’s taxation of remote workers will hinge on whether the New York State Tax Appeals Tribunal determines it was a “necessity” for a Connecticut resident to work in his home when his Manhattan office closed during the Covid-19 pandemic, according to a transcript of the oral arguments.

Georgia DOR Releases New Sales Tax Rate for Clay County

The Georgia Department of Revenue (DOR) released a new sales tax rate for Clay County, effective Jan. 1, 2025. The new rate is set to eight percent. [Ga. Dep’t of ...

Bar Group Urges Clarity on Foreign Affiliates' Loan Guarantees

The Treasury Department and the IRS should clear up uncertainties in a portion of the tax code that limits foreign affiliates’ guarantees of loans to US taxpayers, a bar group said Friday.

Outgoing IRS Chief Counsel Laments Increasingly Dense Tax Rules

IRS Chief Counsel Marjorie Rollinson, who plans to retire early next year, urged tax practitioners and private industry to work with the government to simplify the tax system.

Australia Moves Up Software-Tax Compliance Guidance to January

Australian authorities expect to issue guidance in January, sooner than previously expected, on their compliance approach to taxation of companies’ software sales and development payments.

Philip Morris Beats North Carolina in $6 Million Credit Cap Bout

The North Carolina Supreme Court found on Friday that a 2003 change in law placed a $6 million cap on cigarette export credits that can be used in a single year because that’s consistent with the state’s previous interpretation of the law.

Switzerland Withdraws Special Tax Status for Indian Companies

The Swiss government has decided to withdraw the “most favored nation” status for India, a move that will raise taxes for India’s multinationals operating in the country, starting next year.

US's Top OECD Negotiator Scott Levine to Leave Treasury (1)

Scott Levine, the US’s top delegate to the OECD tax deal talks, announced Friday he would be stepping down from his post at the Treasury Department.

The Fed Can’t Ignore All of Trump’s Intentions: Bill Dudley

The Fed can and must at times make assumptions about what politicians will do. And as the labor market loosens and inflation recedes, monetary policy will gradually move from restrictive to neutral, likely achieving a soft landing.

New York Clears Path for 80,000 Homes. It's a Start: Editorial

For a city known for its dynamism, New York is burdened with some exceptionally stifling housing regulations. So news that the city council has approved the largest rezoning effort since 1961 should be welcomed. Ideally, it will serve as an example for other cities that are impeding desperately needed construction.