Federal

  • December 19, 2024

    5th Circ. Urged To Deny Tax Break For Doc's Captive Insurance

    A physician who owns a network of urgent care clinics was correctly denied tax deductions along with his wife for over $1 million in premiums they paid to insurance companies they owned, the government told the Fifth Circuit, saying the captive arrangements didn't qualify as insurance for tax purposes.

  • December 19, 2024

    GAO Finds Direct File Pilot Successful, Suggests Upgrades

    The Internal Revenue Service conducted a successful test run this past tax season of Direct File, a new online tax return preparation service for individual taxpayers, but the agency could do more to expand access to the program, the U.S. Government Accountability Office reported Thursday.

  • December 18, 2024

    Tax Shelter Defendant Charged In Investment Ploy

    Federal prosecutors have accused two men, one of whom is already facing charges of promoting tax shelters, with wire fraud and money laundering in connection with their operation of a multimillion-dollar fraudulent investment fund, according to an indictment unsealed Wednesday in Colorado federal court.

  • December 18, 2024

    Dutch Bank Exec Gave IRS Good Tax Tip, DC Circ. Judge Says

    D.C. Circuit judges grappled Wednesday with the denial of a whistleblower award to a late Dutch bank executive who tipped off the IRS to tax reporting schemes, with one judge saying during oral arguments that the executive appeared to have handed the agency "gift-wrapped" evidence of wrongdoing.

  • December 18, 2024

    Dem Senators Probe IRS Pick's Past With Retention Tax Credit

    Senate Finance Committee Chairman Ron Wyden said Wednesday that he was investigating President-elect Donald Trump's Internal Revenue Service commissioner pick over his work promoting the fraud-riddled employee retention tax credit and had sent letters demanding information from two tax advisory firms he worked for.

  • December 18, 2024

    Man Must Pay $1.3M Tax After Losing Fight Over IRS' Timing

    A Nevadan owes the Internal Revenue Service more than $1.3 million for 2006 after a federal court rejected his arguments that the agency failed to timely pursue its tax claim against him.

  • December 18, 2024

    Short-Term Funding Bill Would Keep $20B For IRS Frozen

    The Internal Revenue Service would have $20 billion in Inflation Reduction Act funding remain temporarily frozen under a deal lawmakers struck to keep the government running until March 14.

  • December 18, 2024

    Upcoming IRS Regs Will Have Optional Amount B Pricing

    The Internal Revenue Service announced Wednesday that is planning to propose regulations that will give corporations the option to price certain cross-border transactions using a simplified and streamlined approach under a new international tax framework known as Amount B.

  • December 18, 2024

    IRS Pushes Some Retirement Plan Min. Distributions To 2026

    The Internal Revenue Service updated the effective date to January 2026 — instead of next year — for when some must start to withdraw the required minimum amount of funds from several types of individual retirement accounts that were amended by a December 2022 retirement savings law. 

  • December 17, 2024

    CORRECTED: Ineligible Calif. Securities Atty Accused Of Tax Crimes

    A Southern California securities attorney currently ineligible to practice law has gone over five years without filing any personal federal income tax returns, the U.S. Department of Justice alleged in announcing a recently unsealed indictment against the lawyer on Tuesday.

  • December 17, 2024

    Texas Judge Won't Pause Block Of Corp. Transparency Law

    A Texas federal judge on Tuesday denied the government's request to stay his nationwide block of a corporate transparency law while an appeal is pending, saying his view that Congress lacks the constitutional authority to enact the legislation is likely to prevail at the Fifth Circuit.

  • December 17, 2024

    Biz Group IDs Clean Fuel Production Registration Issues

    The process of registering as a clean fuel producer in order to be eligible to claim the associated tax credit under the Inflation Reduction Act has proved to be confusing because of a number of practical issues, a group representing the U.S. biogas industry said in a letter released Tuesday.

  • December 17, 2024

    IRS Extends Accounting Change Waiver Eligibility To 2024

    The Internal Revenue Service again adjusted a previous notice Tuesday to modify certain procedures for obtaining automatic consent of the agency commissioner to change methods of accounting for expenditures paid or incurred in taxable years beginning after 2021, extending them for another year.

  • December 17, 2024

    Payment To Ex-Wife Not Deductible Alimony, Tax Court Says

    A man's $35,000 payment to his ex-wife from stock proceeds is not deductible because it qualifies as a division-of-assets payment and not alimony, the U.S. Tax Court ruled in a bench opinion released Tuesday.

  • December 17, 2024

    US Seeks Foreclosure To Pay 'Survivor' Winner's $3.3M Taxes

    A federal magistrate judge should have recommended allowing the U.S. government to foreclose on two properties it claims are controlled by a winner of the "Survivor" TV series who owes $3.3 million in taxes, the government told a Rhode Island federal court.

  • December 17, 2024

    NY Urges Justices To Pass On IBM, Disney Royalty Tax Fight

    The U.S. Supreme Court should decline to hear appeals by IBM and Disney that claim New York state's tax treatment of royalties received from foreign affiliates resulted in unconstitutional discrimination against interstate commerce, the state told the court Tuesday.

  • December 17, 2024

    IRS Corrects Proposed Admin Requirements For Direct Pay

    The Internal Revenue Service issued a correction Tuesday to proposed regulations laying out administrative requirements for tax-exempt entities to elect out of their partnership status in order to take advantage of new rules enabling direct cash payment of clean energy tax credits.

  • December 17, 2024

    Ex-Pol Can't Shake Fraud Rap Over Jury's Racial Makeup

    A Massachusetts federal judge denied a Vietnamese-American former state senator's bid to undo his conviction for unlawfully accepting unemployment assistance and filing a false tax return, rejecting claims that jury selection was tainted by "racial animus" on the part of prosecutors.

  • December 17, 2024

    Magic Runs Out For Tax Pro Who Stiffed IRS Out Of $145M

    A New York City tax preparer who earned the nickname "the magician" while depriving the IRS of $145 million in revenue copped to tax evasion on Tuesday before a Manhattan federal judge.

  • December 17, 2024

    IRS Finalizes Expanded 'Coverage Month' For Premium Credit

    The Internal Revenue Service finalized rules Tuesday that will expand the definition of a coverage month for purposes of computing the health insurance premium tax credit.

  • December 17, 2024

    Justices Urged To Let Stand Ex-Wife's Tax Payment Suit

    A woman who said the IRS wrongly applied her tax payment to her ex-husband's bill asked the U.S. Supreme Court to let stand a Third Circuit ruling allowing her to challenge it, saying the decision doesn't conflict with any other rulings and involves an issue that rarely occurs.

  • December 16, 2024

    Mich. Judge Troubled By Scope Of Feds' CTA Data Collection

    A federal judge in Michigan said new disclosure requirements for small businesses seem burdensome and intrusive during a Monday hearing focused on the privacy implications of the currently blocked anti-money laundering law.

  • December 16, 2024

    Texan Still Owes 2021 Tax Bill Despite Levy For Other Year

    While the U.S. Tax Court is sympathetic to a Texan's complaint that the Internal Revenue Service's levy procedure will result in his facing an endless string of collection actions, he still must pay his $12,500 deficiency from 2021, the Tax Court said Monday.

  • December 16, 2024

    6th Circ. Affirms $3M Tax Bill For Gold Broker

    A gold and silver broker who made fatuous arguments that he wasn't subject to income taxes owes $3 million in liabilities, the Sixth Circuit ruled, upholding a U.S. Tax Court decision.

  • December 16, 2024

    Tax Court Says Couple Must Recalculate $36M Loss Claims

    An Illinois couple must recalculate the more than $36 million in net operating loss carryforward deductions they claimed in 2008 and 2009, the U.S. Tax Court said Monday, siding with the Internal Revenue Service's determination that they had improperly included a number of losses.

Expert Analysis

  • The Corporate Transparency Act Isn't Dead Yet

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    After an Alabama federal court's ruling last week rendering the Corporate Transparency Act unconstitutional, changes to the law may ultimately be required, but ongoing compliance is still the best course of action for most, says George Singer at Holland & Hart.

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.

  • Employers, Prep For Shorter Stock Awards Settlement Cycle

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    Companies that provide equity compensation in the form of publicly traded stock will soon have one less day to complete such transactions under U.S. Securities and Exchange Commission and Nasdaq rules — so employers should implement expedited equity compensation stock settlement and payroll tax deposit procedures now, say attorneys at Morgan Lewis.

  • Demystifying IRS' Claims Of $851B Return On Investment

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    The IRS' recently released analysis, estimating a $851 billion return on the government’s $80 billion investment in the agency, represents a huge increase over its 2022 estimate and that of the Congressional Budget Office and may be best viewed as a best-case scenario, says Joyce Beebe at the Baker Institute.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • A Proposal For Fairer, More Efficient Innocent Spouse Relief

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    Adding a simple election to the current regulatory framework for innocent spouse claims would benefit both taxpayers and the Internal Revenue Service by alleviating the undue burdens placed on those the program was intended to help and improving agency collections in such cases, says Laurie Kazenoff at Kazenoff Tax.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • Proposed Hydrogen Tax Credit Regs May Be Legally Flawed

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    While the recently proposed regulations for the new clean hydrogen production tax credit have been lauded by some in the environmental community, it is unclear whether they are sufficiently grounded in law, result from valid rulemaking processes, or accord with other administrative law principles, say Hunter Johnston and Steven Dixon at Steptoe.

  • Navigating ACA Reporting Nuances As Deadlines Loom

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    Stephanie Lowe at Liebert Cassidy walks employers through need-to-know elements of Affordable Care Act reporting, including two quickly approaching deadlines, the updated affordability threshold, strategies for choosing an affordability safe harbor, and common coding pitfalls.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • Why Biz Groups Disagree On Ending Chevron Deference

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    Two amicus briefs filed in advance of last month's U.S. Supreme Court oral arguments in Loper Bright Enterprises v. Raimondo highlight contrasting views on whether the doctrine of Chevron deference promotes or undermines the stable regulatory environment that businesses require, say Wyatt Kendall and Sydney Brogden at Morris Manning.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Look Ahead For The Electric Vehicle Charging Industry

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    This will likely be an eventful year for the electric vehicle market as government efforts to accelerate their adoption inevitably clash with backlash from supporters of the petroleum industry, say Rue Phillips at SkillFusion and Enid Joffe at Green Paradigm Consulting.

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