Coming in late with a mediocre one this week, like the Johnson and Johnson vaccine.

DECISIONS

Kakega Properties LLC et al. v. Commissioner – the difference between the highest and best economical use of a property before being donated for a conservation easement and after is used for calculating the value of said easement.  

NEWS OF NOTE

Hedge Fund Trader to Be Sent to Germany From U.K. in Tax Fraud (Cum-Ex) Case. (Bloomberg)

Apple and Epic—Toward a New Service Facilitator Tax. (Bloomberg Tax)

Tax ‘nudge’ letters to be sent to (UK) crypto investors. (Financial Times)

OP-ED/INTERESTS

SERVICE FACILITATOR TAX: The above-linked article in Bloomberg Tax lays out the idea of a “service facilitator tax” – that is based upon the marketplace facilitator tax many states are passing for marketplace facilitators (marketplaces for third parties to sell goods, think Amazon Third-Party and eBay). The basic thrust is an idea that tax can reach where antitrust can’t and inject market forces in to systems such as the Apple App Store commission model.