Bloomberg Tax Journals

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How Will Generative AI Affect Value Chains and Transfer Pricing?

As GenAI continues to evolve, companies should monitor potential changes in their business models and value chains to understand the impact on existing transfer pricing structures and policies.

South African Tax Rules Murky on Debt, Preference Share Funding

Technical analysis of South Africa’s evolving tax treatment of debt and preference share funding instruments is presented with a focus on the March 2025 Tax Court ruling on raising fees and 2025 Tax Laws Amendment Bill relating to hybrid equity instruments.

How Does OBBBA Affect Canada-US Individuals Tax Comparisons?

Individual tax laws in Canada and America are compared.

Tax Developments

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Case: U.S. Tax Court Upholds IRS Penalties on Microcaptive Insurance Scheme

The U.S. Tax Court held that the taxpayers were liable for accuracy-related penalties related to their microcaptive insurance arrangements, affirming the IRS’s penalty determinations. Taxpayers, a married couple including a ...

Case: U.S. Tax Court Upholds Separate Carryback Elections for Tax Losses (T.C. Memo)

The U.S. Tax Court held that the taxpayer was permitted to relinquish the carryback period for its standard net operating loss while retaining the 10-year carryback for its specified liability ...

Case: Court Grants IRS’s Motion to Dismiss, Finds Taxpayer Not Entitled to Refund

The U.S. District Court for the Southern District of California issued a decision dismissing taxpayer’s 2014 and 2015 refund claim for lack subject matter jurisdiction. Taxpayer filed a lawsuit seeking ...

Companies Face Tariff-Induced Transfer Pricing Audit Risks

Enrolled Agents Anticipate IRS Chaos for Next Tax Filing Season

Congressional Deadline on Shutdown Deal Adds to IRS Challenges

IP Poses Risks, Opportunities for Companies' Tariff Planning

IRS Shakeup: How Is the US Tax Agency Adapting to Trump's Vision?

Since President Donald Trump took office, the IRS has faced transformative changes, including a substantial reduction in its workforce and the appointment of seven different commissioners or acting commissioners.

Latest Stories

Senate Republican Presses IRS on Tax Treatment of Crypto Staking

Senator Todd Young is urging the IRS to review and reconsider earlier guidelines on the tax treatment of rewards cryptocurrency owners collect in exchange for “staking,” or locking assets on a blockchain network to aid its operation and validate transactions.

FROM ACROSS BLOOMBERG TAX

Daily Tax Report InternationalDaily Tax Report StateTransfer Pricing ReportThe Exchange: Tax Insights & Commentary
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