Federal
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January 14, 2025
House GOP Urges TCJA Permanency At First 2025 Tax Hearing
The 2017 tax law's expiring provisions, including the opportunity zone tax incentives, credit for advanced manufacturing and child tax credit expansion, must be made permanent as soon as possible, House Ways and Means Committee Chairman Jason Smith said Tuesday.
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January 14, 2025
IRS Floats Counting Affiliate Pay In $1M Pay Deduction Cap
Compensation from affiliates of publicly traded companies would count toward the $1 million limit on tax deductions for performance-based pay of high-earning employees under rules proposed Tuesday by the U.S. Treasury Department and Internal Revenue Service.
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January 14, 2025
Man Didn't Prove Travel, Vehicle Deductions, Tax Court Says
An Ohio man the IRS said incorrectly claimed nearly $14,000 in travel- and vehicle-related costs failed to substantiate them, the U.S. Tax Court said Tuesday, including failing to remember the names of trade shows he said he attended in the middle of the COVID-19 pandemic.
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January 14, 2025
Easement Worth $1M, Not $18M, Gov't Tells 11th Circ.
The U.S. Tax Court was right to believe expert testimony that a claimed conservation easement donation of roughly $18 million was only worth $1 million, the government told the Eleventh Circuit, urging it to reject the donors' claims that the expert was unreliable.
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January 14, 2025
IRS Appoints 18 Members To Advisory Council
The Internal Revenue Service appointed 18 new members to its advisory council to serve three-year terms starting this month, the agency said Tuesday.
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January 14, 2025
IRS Releases Latest Surprise Healthcare Bill Calculation Rate
The Internal Revenue Service provided Tuesday a percentage increase for calculating certain out-of-network healthcare coverage for 2025 under legislation that barred surprise medical bills.
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January 14, 2025
Trump Announces Plans To Create 'External Revenue Service'
President-elect Donald Trump said Tuesday that he planned to create an "External Revenue Service" that would collect tariffs and revenue from foreign countries.
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January 14, 2025
IRS Updates Scam Protections For 2025 Filing Season
The Internal Revenue Service announced changes Tuesday for the 2025 tax filing season designed to help protect taxpayers and tax professionals from scams and schemes, including updates to certain forms and increasing reviews and education.
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January 14, 2025
Feds Ask 2 Years For Ex-Pol On Tax, Pandemic Aid Charges
A former Massachusetts state senator should spend two years in prison after being convicted of illegally obtaining unemployment assistance and filing a false tax return, the federal government argued, citing the "greed" at the heart of the politician's conduct.
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January 14, 2025
DOL Finalizes ERISA Voluntary Correction Program Changes
The U.S. Department of Labor's employee benefits arm has finalized changes to a program allowing retirement plan managers to voluntarily self-correct when they fail to forward employee contributions on time or make other transaction errors, according to a notice the agency posted online Tuesday.
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January 13, 2025
Special Counsel Slams Biden's Critique Of Son's Prosecution
The special counsel who oversaw the investigation into Hunter Biden, which was wiped out by a presidential pardon, released a report published Monday criticizing President Joe Biden's "baseless accusations" that his son was "selectively" prosecuted and warning that such comments threaten "the integrity of the justice system as a whole."
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January 13, 2025
Feds Say Par Funding Fraud Caused $404M In Losses
Prosecutors and defense attorneys spent hours in a marathon hearing Monday trying to convince a Pennsylvania judge of how much financial damage they thought the principals of the Par Funding merchant lending business did by allegedly fleecing investors, with the government pushing for a $404 million figure.
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January 13, 2025
IRS Puts Out Spinoff Rules, Multiyear Reporting Regime
The Internal Revenue Service released proposed regulations Monday for a narrow set of corporate separation transactions, known as spinoffs, that the agency will approve as tax-free ahead of time, alongside guidance detailing multiyear reporting requirements for those deals.
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January 13, 2025
AGs, Lobbyists Ask Justices To Keep Shell Co. Law Blocked
The U.S. Supreme Court should deny the federal government's emergency application to stay a Texas district court's injunction on a law aimed at cracking down on crimes committed with shell companies, according to numerous state attorneys general and interest groups and a handful of small businesses.
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January 13, 2025
Tax Firm Asks Court To Ax Final IRS Microcaptive Rules
A global tax services provider asked a Texas federal court to vacate finalized tax rules requiring the reporting of certain transactions involving captive insurance companies deemed as potentially abusive, arguing the guidance goes beyond the agency's authority.
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January 13, 2025
Sen. Warren To Grill Treasury Pick On Trump's Tax Agenda
Sen. Elizabeth Warren, D-Mass., plans to ask Treasury secretary nominee Scott Bessent at his confirmation hearing in front of the Senate Finance Committee on Thursday about President-elect Donald Trump's tax agenda and plans for the Internal Revenue Service, according to a letter she sent the nominee.
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January 13, 2025
Tax Court Spares Woman From Fine For Frivolous Arguments
A woman who frivolously claimed her wages were nontaxable owes $15,700 in taxes and penalties, but she doesn't owe a fine for making groundless arguments, the U.S. Tax Court said in an opinion Monday.
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January 13, 2025
IRS Eases Process Of Insurance Co. Alternate Tax Revocation
The Internal Revenue Service laid out a streamlined process Monday by which certain insurance companies that took an elective application of an alternative tax may obtain automatic consent to revoke that election.
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January 13, 2025
The Tax Angle: GOP Lawmakers Grapple With TCJA Renewal
From a look at Congress setting parameters for consideration of legislation to renew the GOP's 2017 tax overhaul law to other upcoming tax action in the House and Senate, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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January 13, 2025
Tax-Exempt Regs Should Cover Trust Payments, Tribes Say
Five tribal leaders told the U.S. Treasury Department on Monday that trust payments distributed to members, including those issued to minors and special-needs individuals, should be included among the tribal welfare benefits that recent proposed rules would exempt from federal income taxes.
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January 13, 2025
Ariz. Taking Rebate Tax Fight With IRS To 9th Circ.
Arizona is turning to the Ninth Circuit its battle with the Internal Revenue Service over the federal taxation of its 2023 rebates to taxpayers with dependents, the state told the lower court that dismissed its case.
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January 13, 2025
Trump Wants Higher SALT Cap, House Republican Says
President-elect Donald Trump wants to increase the $10,000 federal cap on state and local tax deductions, a House Ways and Means Committee member said Monday.
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January 13, 2025
Tax-Lien Biz Atty Accused Of Duping Bank Can't Touch Money
A Manhattan federal judge declined Monday to unfreeze assets on behalf of a former compliance lawyer accused of duping a bank into lending his tax-lien investment firm $20 million, complicating his plan to go to trial with private counsel.
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January 13, 2025
Justices Won't Review Reversal Of Firm's Tax Penalty Win
The U.S. Supreme Court let stand Monday a Fifth Circuit decision overturning a jury ruling that a wealth management company didn't owe $579,000 in tax penalties because an employee's mental health problems excused the company's failure to file information returns on time.
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January 12, 2025
Justices To Review Whether Ex-Wife Can Challenge Tax Levy
The U.S. Supreme Court will review a Third Circuit decision allowing a woman to continue challenging what she claims was an improper application of her tax payment to her ex-husband's bill even after the Internal Revenue Service stopped pursuing a proposed property seizure against her.
Expert Analysis
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The Corporate Transparency Act Isn't Dead Yet
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.
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How New EU Tax And Transfer Pricing Rules May Affect M&A
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.
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Employers, Prep For Shorter Stock Awards Settlement Cycle
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.
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Demystifying IRS' Claims Of $851B Return On Investment
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.
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How Firms Can Ensure Associate Gender Parity Lasts
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.
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A Proposal For Fairer, More Efficient Innocent Spouse Relief
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.
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7 Common Myths About Lateral Partner Moves
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.
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Proposed Hydrogen Tax Credit Regs May Be Legally Flawed
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.
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Navigating ACA Reporting Nuances As Deadlines Loom
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.
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6 Pointers For Attys To Build Trust, Credibility On Social Media
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.
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Why Biz Groups Disagree On Ending Chevron Deference
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.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
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.
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A Look Ahead For The Electric Vehicle Charging Industry
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.