On May 2, 2023, the Department of the Treasury and Internal Revenue Service (“IRS”) issued proposed Treasury Regulations (REG-124064-19) that would, in certain cases, terminate the application of ...

While a claim of conversion has grown to extend beyond tangible property to keep up with computerized use, courts are still grappling with how far to extend the tort. In their Commercial Division ...

Oklahoma public schools are bracing for a tax cut that it seems no one can predict with much certainty. Schools are always waiting this time of year to see what happens with the state budget, but one ...

The IRS on Tuesday issued proposed regulations that would in certain cases terminate the continued application of Sec. 367(d) when intangible property is repatriated to certain U.S. persons after ...

At the end of the Tax Court’s 2016 opinion in Medtronic, a short section briefly summarizes and summarily rejects what the opinion describes as the IRS’s “alternative allocation under section 367(d).” ...

Wisconsin's effort to tax a railroad's custom software has been ruled unlawful by a federal appeals court. Union Pacific Railroad Co. refused to pay more than $2.6 million Wisconsin claimed it owed on ...

In In re Estate of Debra E. Hunt v. Arabia Vargas, a trial court granted summary judgment interpreting a will to devise a large share of the testatrix’s personal property to her life partner. No.