Wyden Presses IRS to Probe Puerto Rican Legal Tax Advice

The top Senate Finance Committee Democrat is calling on the IRS to investigate tax planning advice provided by two of the largest global law firms the lawmakers say permitted high-net-worth clients to evade more than $100 million in federal taxes by claiming Puerto Rican residency.

Corporate Tax Disclosures Let Investors Peer Into the Black Box

Accounting Firms Navigate Compensation as AI Tools Upend Work

IRS Pivots to Fill Holes in Tax Filing Season After DOGE Cuts

How Tax Administration Reforms Could Pass Congress This Year

Bloomberg Tax Journals

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Transfer Pricing, Treaty Benefits Reshaped by OECD’s Tax Update

The OECD has handed tax authorities a robust, treaty-sanctioned framework to attack excessive debt financing, meaning corporate tax directors must ensure every intercompany financial transaction is backed by rigorous analyses, says STI Taxand’s Christos Theophilou.

Why Royalty Disputes Are Rising in Global Taxation: PepsiCo Case

International tax scrutiny is intensifying, with disputes increasingly focused on intangibles, cross-border structures, and the correct characterization of royalties, says Baker McKenzie’s Antonio Weffer.

Don’t Trust AI, Always Verify. Tax Law Still Needs Humans—Pt. 2

Tax professionals must move from passive reliance to active verification. “Human-in-the-loop” verification will preserve the integrity of the tax system, says a visiting adjunct faculty member at Texas A&M University.

Tax Developments

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U.S. Appeals Court Upholds Application of Economic Substance Doctrine to Disallow §245A Deduction in Multibillion-Dollar TCJA Transaction

The U.S. Court of Appeals for the Tenth Circuit affirmed the district court’s ruling that a multinational corporation’s four-step transaction series, known internally as “Project Soy,” lacked economic substance and ...

IRS Issues Revenue Ruling on Monthly Prescribed Interest Rates For May 2026

The IRS has issued revenue ruling providing various prescribed interest rates for federal income tax purposes for May 2026. The ruling establishes applicable federal rates under I.R.C. §1274(d), adjusted applicable ...

U.S. Tax Court Sustains Deficiency Determination for Unreported Form 1099-NEC Income

The U.S. Tax Court held that a taxpayer was liable for a federal income tax deficiency after failing to report $15,206 in nonemployee compensation reflected on Form 1099-NEC, despite claiming ...

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.

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Transfer Pricing, Treaty Benefits Reshaped by OECD’s Tax Update

The OECD has handed tax authorities a robust, treaty-sanctioned framework to attack excessive debt financing, meaning corporate tax directors must ensure every intercompany financial transaction is backed by rigorous analyses, says STI Taxand’s Christos Theophilou.

Five Questions With Katten Tax Planning Partner Saul Rudo

Bloomberg Tax Insights & Commentary is featuring a recurring questionnaire of prominent tax professionals who are willing to share their thoughts about their work and the practice of tax these days. Today we feature Saul E. Rudo, chair of Katten’s transactional tax planning practice in Chicago.

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