Molly Moses

September kicked off with the announcement of tariffs on semiconductors and ended with the U.S. Tax Court's long-awaited ruling on a computational dispute involving Facebook, with Siemens USA's trial and a bill that would change the U.S. base erosion and anti-abuse tax in the middle. Here, Law360 looks at some of the biggest international tax developments of the past month.

A Maryland cancer research laboratory that said it had no income in 2021 is contesting IRS tax assessments totaling $4.5 million, telling the U.S. Tax Court that the government's imputing of an underpayment violates the U.S. Constitution.

A partnership's late-filed petition in the U.S. Tax Court was due to circumstances beyond its control in a case where the final partnership adjustment from the IRS was mailed correctly but returned by the U.S. Postal Service as undeliverable, the court held Monday.

A California man's technology business can't deduct the $59 million in losses it claimed for 2016 and 2017, the U.S. Tax Court held Wednesday in a case in which it also rejected the IRS' determinations of his individual income.

An attorney for Siemens USA asked the U.S. Tax Court on Monday to consider all elements of the restructuring that followed the company's 2017 acquisition of Mentor Graphics and led to a $3.5 billion deduction the following year.

The U.S. Tax Court has jurisdiction in the case of a partnership that missed the 90-day window for filing its petition under an Internal Revenue Code rule enacted as part of the 2015 Bipartisan Budget Act, the court held Wednesday, finding that the 2015 regulations warranted a result different from that reached by the court in an earlier case.

Airbnb lost its constitutional challenge to a French penalty for failure to collect and remit tourist tax, with a court finding the minimum fine of €750 ($865) was appropriate given the difficulty that collecting the tax poses to local authorities.

The U.K.'s Upper Tribunal declined to allow a man who kept inadequate till records and tried to introduce last-minute evidence at a hearing to bring a second challenge to a First-tier Tribunal's decision upholding value-added tax assessments against him.

OECD To Publish Comments On Services Draft In August

The OECD plans to publish at the end of August the comments it received on draft revisions to transfer pricing guidelines dealing with intragroup services, an official said at a conference Thursday.