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Trade & Procurement
Recent changes
IRS Action on Decision: Complex Media, Inc. v. Commissioner
The IRS has issued an Action on Decision regarding Complex Media, Inc. v. Commissioner. The decision clarifies that a taxpayer is bound by the form of a series of transactions as implemented, resulting in assets received having a carryover basis without a step-up. This action addresses the tax treatment of a Section 351 transaction and subsequent redemption.
Tax Refund for Crude Oil Exports Under Export Clause
The IRS has issued an Action on Decision regarding Trafigura Trading LLC v. United States, addressing whether a tax refund is due for crude oil exports due to the Export Clause of the U.S. Constitution. The case concerns the constitutionality of the tax funding the Oil Spill Liability Trust Fund.
IRS: CSX Corp. relocation benefits excludable under RRTA
The IRS has issued an Action on Decision disagreeing with the Eleventh Circuit's interpretation of the Railroad Retirement Taxation Act (RRTA). The IRS will not follow the court's ruling that certain relocation benefits paid by CSX Corp. were excludable from RRTA taxation as business expenses. This decision indicates the IRS's continued stance on taxing such benefits.
IRS Action on Decision: Backup Withholding Liability Statute of Limitations
The IRS issued an Action on Decision regarding backup withholding liability and the statute of limitations. The Fifth Circuit held that the limitations period for assessing backup withholding liability begins to run upon the filing of Form 1040 and Form 1099-MISC, even if payee TINs are omitted. The IRS disagrees with this interpretation.
Commerce Initiates Steel Wheels Trade Probe from Thailand
The U.S. Department of Commerce has initiated a circumvention inquiry into steel wheels imported from Thailand. This probe will determine if these imports are circumventing existing antidumping and countervailing duties on steel wheels from China, as requested by domestic producers Accuride and Maxion. The inquiry is applicable from March 19, 2026.
Wind Towers Duty Orders Review Continuation
The International Trade Administration (ITA) is continuing antidumping and countervailing duty (AD/CVD) orders on utility scale wind towers from Canada, Vietnam, Indonesia, and Korea. This action follows determinations by the Department of Commerce and the International Trade Commission that revoking these orders would likely result in continued dumping, subsidies, and material injury to the U.S. industry.
In re Det. of M.E. - Indigent Defense Caseload Limits
The Washington Supreme Court ruled that caseload limits in the Standards for Indigent Defense following CrR 3.1 are mandatory. The court also addressed trial court orders requiring the King County Department of Public Defense (DPD) to provide counsel in civil commitment cases, reversing in part orders pertaining to the King County Executive.
State v. Calloway - Washington Supreme Court Opinion
The Washington Supreme Court issued an opinion in State v. Calloway, addressing the constitutionality of the state's harassment statute in light of the U.S. Supreme Court's decision in Counterman v. Colorado. The court held that the statute is constitutional as it allows for a mens rea standard of recklessness, which aligns with the Counterman ruling.
MSPB Seeks Input for Merit Systems Studies
The U.S. Merit Systems Protection Board (MSPB) is seeking public suggestions for its research agenda on Federal workforce issues. Submissions are due by July 1, 2019, and are intended to help MSPB identify key topics for studies ensuring merit system principles are upheld.
Pipeline Safety: Sable Offshore Corp. Special Permit Request
The Pipeline and Hazardous Materials Safety Administration (PHMSA) is seeking public comment on a special permit request from Sable Offshore Corp. regarding pipeline safety. The notice provides a 14-day comment period for interested parties to submit their views.
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