Perspective: Five Yulchon LLC practitioners examine South Korea’s transfer pricing method rules as applied to intangible transactions and the audit implications for taxpayers. taxnotes.co/4icPlzc

Perspective: Umberto Lorenzi and Stefano Urzì examine evolving Italian case law on interest-free intercompany loans and the development of commercial reasons as a possible justification for the absence of interest under the arm’s-length principle. taxnotes.co/4jsO9df

Perspective: Chris William Sanchirico and Reed Shuldiner identify the major policy challenges for circular partnerships and propose solutions for reform. taxnotes.co/4i1LbtG

Perspective: William Hays Weissman analyzes two recent California court decisions that held for the taxpayers and reinforced the limits of local taxation. taxnotes.co/4dNFs9I

Perspective: Jasper L. Cummings, Jr., examines how original issue discount rules apply to intercompany debt. taxnotes.co/4eJQM78

"The English Premier League is more than just football," @RobertGoulder writes. "It might be Britain’s greatest cultural export since the works of William Shakespeare." forbes.com/sites/taxnotes/20…

Perspective: Helena Thor explores the prerequisites for limited tax liability on carried interest in Germany. taxnotes.co/4idXS4R

Perspective: Billy Hamilton examines Florida’s proposed constitutional amendment to increase the homestead property tax exemption and restrict growth in assessments for nonhomestead properties. taxnotes.co/4sdeFd3

Perspective: Eman Cuyler examines recent appellate decisions addressing the section 6213(a) deadline for filing Tax Court deficiency petitions and the growing divide among circuit courts over whether the deadline is subject to equitable tolling. taxnotes.co/4ysomFN

Perspective: Raffaele Petruzzi and Siddharth Jain examine the changes to permanent establishments, transfer pricing, and tax certainty from the 2025 update to the OECD’s model tax convention. taxnotes.co/47vkOaY

Five years after its launch, the Multistate Tax Commission’s partnerships project is sending a draft model that combines its sourcing work to date to the Uniformity Committee for review. taxnotes.co/4kaeahF

The National Taxpayers Union (NTU) is arguing that it has standing to challenge California’s 2024 apportionment statute that excludes receipts and activities linked to deductible income. taxnotes.co/4ihbgp1

The 2022 EU solidarity contribution on energy companies was indeed fiscal in nature, but its nontax legal basis was lawful, an EU Court of Justice advocate general concluded. taxnotes.co/4BoO7JV

Proposed rules implementing a significant change to the way ownership of controlled foreign corporations is accounted for following a midyear ownership change are shaking up merger and acquisition deals, tax attorneys said. taxnotes.co/4z0XFcl

NEW: This week on the podcast, Tax Notes reporters @StephanieSoong and @PaezWrites break down the biggest international tax developments from the annual International Fiscal Association Congress in Melbourne, Australia. Listen now: taxnotes.co/4zMMd45

Treasury and the have IRS rolled out a new IRA compliance system that allows for the correction of unintentional errors caused by service providers and provides a waiver of the 60-day rollover requirement. taxnotes.co/4z5FJ0n

The IRS is looking beyond the technical treatment of disregarded entity debt as it reconsiders two letter rulings amid worries that taxpayers are using the guidance in those rulings to avoid cancellation of debt (COD) income, an agency official said. taxnotes.co/4i3hyK2

Treasury and the IRS are still targeting February 2027 to release revised proposed regulations addressing the corporate alternative minimum tax, an official said. taxnotes.co/3UIovqQ

A new specialty group within the IRS that will focus on attacking abusive tax shelters and schemes will also examine sophisticated issues like those related to private placement life insurance, IRS Chief Tax Compliance Officer Jarod Koopman told Tax Notes. taxnotes.co/4jHG44F

"The English Premier League is more than just football," @RobertGoulder writes. "It might be Britain’s greatest cultural export since the works of William Shakespeare." forbes.com/sites/taxnotes/20…