Federal
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June 12, 2024
Digital Taxes May Take Hold Regardless Of Treaty Signing
An internationally agreed-upon freeze on digital levies may continue to thaw even if countries meet their impending deadline to sign a related treaty for new corporate tax rules, in part because the accord faces a hazy path to formal ratification.
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June 12, 2024
Feds Strike Deal Ending $7M FBAR Penalty Cases
The U.S. government agreed to settle a pair of foreign bank account reporting cases in which it had sought a total of $7 million from a former insurance broker and his wife's estate, according to a court order filed Wednesday in California federal court.
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June 12, 2024
Groups Push Back On Stock Buyback Tax Test's Scope
The U.S. Treasury Department's proposed stock buyback tax rules go too far in trying to assess whether the main purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, two groups said in comments released Wednesday.
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June 12, 2024
St. Louis Atty Urges Acquittal After Tax Avoidance Conviction
A Missouri attorney who was found guilty of participating in a $4 million tax avoidance scheme alongside her father and a North Carolina insurance agent is looking to wipe out the verdict, arguing there wasn't enough evidence to convict.
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June 12, 2024
IRS Nix Of $45M Easement Deduction Invalid, Donor Says
A North Carolina partnership asked the U.S. Tax Court to invalidate an Internal Revenue Service adjustment that slashed its $45.6 million deduction for its donation of a conservation easement, saying the agency failed to follow proper administrative procedures.
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June 12, 2024
Treasury Issued Over $1B In Clean Vehicle Tax Credits
The clean vehicle tax credit of up to $7,500 has saved buyers more than $1 billion in total upfront costs since January, the U.S. Treasury Department announced Wednesday, saying the figures represent a major milestone in lowering transportation costs since the incentive was updated in 2022.
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June 12, 2024
First 'Survivor' Winner Wants $3M Tax Case Tossed
The winner of the first season of the TV series "Survivor" asked a Rhode Island federal court to toss the government's case against him seeking nearly $3.3 million in unpaid taxes, saying the liabilities stem from his flawed criminal conviction for tax evasion nearly 20 years ago.
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June 12, 2024
4 Taxpayer Advocacy Panel Committees To Meet In July
Four Taxpayer Advocacy Panel committees will hold public meetings in July focused on improving customer service at the Internal Revenue Service, the agency announced Wednesday.
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June 11, 2024
SVB Wants A Trial Over Its $605M Tax Bill From IRS
The parent company of failed Silicon Valley Bank has told a New York bankruptcy judge it wants him to decide if it owes the Internal Revenue Service more than $605 million in taxes.
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June 11, 2024
US Issues Sanctions For $50M Guyana Gold Tax Evasion
Two Guyanese businessmen and a Guyanese official were sanctioned by the U.S. Treasury Department on Tuesday after a probe into a corruption scheme that helped the businessmen evade $50 million in gold export taxes that should have been paid to Guyana's government, Treasury said.
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June 11, 2024
Trucks Don't Qualify For $400M Tax Exemption, 6th Circ. Told
A Tennessee company's refurbished trucks do not qualify for the safe harbor from the heavy-truck excise tax and should not be exempt from roughly $400 million in excise taxes, penalties and interest, the U.S. government told the Sixth Circuit.
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June 11, 2024
Aflac Matriarch's Estate Says IRS Missing Info In $11.7M Fight
The Internal Revenue Service's push to recover $11.7 million in deficiencies and penalties from the estate of the matriarch of the family that founded Aflac is predicated on a "mistaken understanding" regarding a trust, the estate told the U.S. Tax Court.
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June 11, 2024
Compliance Costs Outweigh Min. Tax Gains, Biz Reps Say
Multinational businesses are concerned that the burden of complying with the 15% global minimum tax outweighs any potential revenue gains associated with the burgeoning system, tax attorneys and a trade association representative said during a panel Tuesday.
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June 11, 2024
House Panel Chair Seeks To End Media Org's Tax Exemption
The House's top tax writer wants the Internal Revenue Service to revoke the tax-exempt status of a nonprofit Mideast-focused news outlet, telling Commissioner Daniel Werfel that the organization is aiding Hamas.
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June 11, 2024
Lawmakers Urge Biden To Back Brazil's Int'l Wealth Tax Plan
Sen. Bernie Sanders and Democratic lawmakers asked the Biden administration Tuesday to support the global minimum tax on billionaires being proposed by Brazil, which is encouraging the Group of 20 nations to endorse the initiative at its meetings next month.
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June 11, 2024
Kostelanetz Partners Talk Benefits Of Atlanta Tax Firm Tie-Up
Kostelanetz LLP partners Bryan Skarlatos and Todd Welty discuss the firm’s recent combination with Atlanta boutique Welty PC.
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June 11, 2024
Charity Founder Charged With Embezzling $2.5M, Evading Tax
The founder of a New York City charity embezzled $2.5 million in donations meant for low-income families and then failed to report the earnings to the Internal Revenue Service or pay tax on them, according to a criminal complaint unsealed Tuesday in New York federal court.
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June 11, 2024
IRS Schedules 3 Taxpayer Advocacy Panel Meetings For July
Three Taxpayer Advocacy Panel committees will hold public meetings in July focused on improving customer service at the Internal Revenue Service, the agency announced Tuesday.
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June 10, 2024
Ex-LA Chinatown Bank CFO Gets 3 Years For Embezzlement
The former chief financial officer of a bank based in Los Angeles' Chinatown has been sentenced to three years in prison after pleading guilty to bank fraud for embezzling more than $700,000 from his employer.
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June 10, 2024
Exec Wants IRS To Destroy Or Yield Docs In Summons Fight
The IRS should be forced to destroy or return bank records it obtained from a cryptocurrency executive charged in a 2020 bitcoin fraud investigation because the agency failed to notify him and his company of the summonses for the records, they told a Texas federal court Monday.
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June 10, 2024
Tax Court Rejects 'Shoebox' Method To Support Biz Expenses
The U.S. Tax Court rejected Monday the tax deductions that three California residents had claimed on their businesses' returns, saying their "shoebox" method of bundling receipts as evidence failed to substantiate their business expenses.
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June 10, 2024
Big Tech Urges US Reprisal Over Canada's Impending DST
The Office of the U.S. Trade Representative should open formal dispute proceedings with the Canadian government in response to a 3% digital services tax that is expected to soon pass in the Canadian Senate, business groups with members in the U.S. tech industry said Monday.
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June 10, 2024
IRS Needs Plan To Reduce Office Space, TIGTA Says
While the Internal Revenue Service has successfully decreased its unneeded office space by 8% since 2018, it needs a long-term space reduction plan with annual targets to efficiently continue to reduce its footprint, the Treasury Inspector General for Tax Administration said in a report released Monday.
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June 10, 2024
Judge Unseals Some Testimony Of Trump Tax Info Leaker
A federal magistrate judge on Monday ordered the unsealing of some testimony from a former IRS contractor about how he illegally gained access to former President Donald Trump's tax returns in a billionaire's case suing the agency over the breach.
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June 10, 2024
10th Circ. Affirms Couple Can't Ax $833K Income Tax Payment
A couple's wide-ranging arguments that the Internal Revenue Service should not have been allowed to assess that they owe over $833,000 in unpaid income taxes and penalties failed to sway the Tenth Circuit on Monday, as the court affirmed a ruling against them.
Expert Analysis
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Former Minn. Chief Justice Instructs On Writing Better Briefs
Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.
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What To Know About IRS' New Jet Use Audit Campaign
The Internal Revenue Service recently announced plans to open several dozen audits scrutinizing executive use of company jets, so companies should be prepared to show the business reasons for travel, and how items like imputed income and deduction disallowance were calculated, say attorneys at Morgan Lewis.
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Stay Interviews Are Key To Retaining Legal Talent
Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.
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Judicial Independence Is Imperative This Election Year
As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.
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Spartan Arbitration Tactics Against Well-Funded Opponents
Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.
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What Recent Study Shows About AI's Promise For Legal Tasks
Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.
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How FinCEN Proposal Expands RE Transaction Obligations
Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.
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What To Know About Employee Retention Credit Disclosures
Employers that filed potentially erroneous employee retention credit claims should take certain steps to determine whether the IRS’ voluntary disclosure program is a good fit and, if so, prepare a strong application before the window closes on March 22, say attorneys at Dentons.
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Litigation Inspiration: A Source Of Untapped Fulfillment
As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.
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Unpacking FinCEN's Proposed Real Estate Transaction Rule
Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.
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Think Like A Lawyer: Forget Everything You Know About IRAC
The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.
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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.