Federal

  • October 07, 2024

    DC Circ. Skeptical Of Tax Tipster's Whistleblower Award Bid

    D.C. Circuit judges seemed skeptical Monday of a tax tipster's claim that the U.S. Tax Court had jurisdiction over his case seeking to overturn the IRS' denial of a whistleblower award, saying during oral arguments that the agency had found his tips unproductive early on.

  • October 07, 2024

    Justices Won't Review Contractor's $1.3M R&D Credit Suit

    The U.S. Supreme Court let stand Monday a Fifth Circuit decision denying a construction company's shareholders a six-figure tax refund for the company's $1.3 million research credit claim, denying a petition.

  • October 07, 2024

    TCJA Extension, Biz Tax Cut To Reward Top 5%, Report Says

    Former President Donald Trump's planned extension of the 2017 tax cuts and lowering of corporate rates contribute most among his platform to lowering taxes for the wealthiest 5% and hiking them for everyone else, the left-leaning Institute on Taxation and Economic Policy said Monday in a report.

  • October 04, 2024

    Defunct Yoga Studios' Founder Cops To Tax Evasion

    The founder of a defunct chain of prominent and lucrative yoga studios who was accused of hiding $1.6 million in income from the Internal Revenue Service pled guilty to tax evasion, New York federal prosecutors said Friday.

  • October 04, 2024

    DC Circ. Won't Reconsider Whistleblower's $690M Claim

    The D.C. Circuit on Friday rejected a whistleblower's request that it rehear a ruling upholding the denial of up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program.

  • October 04, 2024

    Fed. Circ. Revives HR Co.'s $1.6M Tax Penalty Refund Bid

    A human resources company that sought $1.6 million in tax penalty refunds should not have been rejected for its failure to attach power-of-attorney forms to its requests, the Federal Circuit said Friday in vacating a decision by the U.S. Court of Federal Claims.

  • October 04, 2024

    Promise Of OECD's Payments Tax Treaty Called Into Question

    The OECD-designed tool to provide developing countries with better means to apply a minimum tax on income sent from their jurisdictions to low-taxed entities within a corporate group is inadequate to address those countries' revenue needs, tax policy organizations said.

  • October 04, 2024

    Former NJ Doctor Owes $4.8M In FBAR Penalties, Court Told

    A former physician in New Jersey faces a tax bill of almost $5 million for failing to report 19 bank accounts he opened at Indian banks, the government told a federal court.

  • October 04, 2024

    IRS Probes Atty Over Promotion Of Deferred Law Firm Fees

    The Internal Revenue Service is investigating a lawyer it suspects of promoting a scheme to illegally shield attorneys from taxes on legal fees, according to an Ohio federal court petition seeking to enforce summonses for documents in the case.

  • October 04, 2024

    Justices Accept Ex-Chicago Alderman's False Statement Case

    The U.S. Supreme Court said Friday that it would review the conviction of an ex-Burke Warren MacKay & Serritella PC attorney and former Chicago alderman under a federal statute that prohibits making false statements to influence certain financial institutions.

  • October 04, 2024

    Taxation With Representation: Gibson Dunn, Weil, Simpson

    In this week's Taxation with Representation, DirectTV buys EchoStar's video business for $10 billion, Marsh McLennan inks a $7.75 billion deal for McGriff Insurance, and PepsiCo closes a $1.2 billion deal to purchase Siete Foods.

  • October 04, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included proposed regulations that would define which electric vehicle charging ports and other similar infrastructure that taxpayers can build in underserved communities to qualify for a tax credit.

  • October 03, 2024

    12 Lawyers Who Are The Future Of The Supreme Court Bar

    One attorney hasn't lost a single U.S. Supreme Court case she's argued, or even a single justice's vote. One attorney is perhaps "the preeminent SCOTUS advocate." And one may soon become U.S. solicitor general, despite acknowledging there are "judges out there who don't like me." All three are among a dozen lawyers in the vanguard of the Supreme Court bar's next generation, poised to follow in the footsteps of the bar's current icons.

  • October 03, 2024

    US Partnership Excluded From Tax Treaty, Irish Court Says

    A Delaware corporation with three Irish subsidiaries must pay Irish taxes on distributions to its U.S. partners because a U.S.-Ireland tax treaty designed to prevent double taxation does not apply, the Irish High Court ruled.

  • October 03, 2024

    Assisted Living Owner Can't Deduct Losses, Tax Court Says

    The owner of an assisted living company may not deduct passive losses for a group home he renovated because he spent too few hours working on repairs to qualify as a real estate professional, the U.S. Tax Court ruled Thursday.

  • October 03, 2024

    TIGTA Says $12.9B In Early Distributions Missing Added Tax

    Roughly 2.8 million taxpayers in 2021 received early retirement distributions totaling $12.9 billion but did not pay the additional 10% tax or file for an exception, the Treasury Inspector General for Tax Administration said Thursday.

  • October 03, 2024

    Bankruptcy Doesn't Pause Tipster's Case, Tax Court Says

    A tax tipster's bankruptcy filing doesn't pause his U.S. Tax Court case challenging the Internal Revenue Service's denial of his request for a whistleblower award, the Tax Court ruled Thursday, saying the award case doesn't concern his tax liability.

  • October 03, 2024

    IRS Expanding Scope Of Free Online Tax-Filing Program

    The Internal Revenue Service will expand its free online tax-filing program to accommodate more types of income, credits and deductions in 2025, Commissioner Daniel Werfel said Thursday.

  • October 03, 2024

    3M Tells 8th Circ. Chevron's End Dooms IRS In $24M Dispute

    Multinational conglomerate 3M said Thursday that the U.S. Supreme Court's striking down of Chevron deference dictates that the Eighth Circuit overturn a U.S. Tax Court decision that supported the IRS' reallocation of $24 million from the company's Brazilian affiliate.

  • October 03, 2024

    IRS Used $2B Of Funding Boost For Operating Expenses

    The IRS has used $2 billion of the funding boost it received under the Inflation Reduction Act to supplement its annual funding, according to the Treasury Inspector General for Tax Administration.

  • October 03, 2024

    IRS Missing Out On $1.4B In Taxes On Gambling Winnings

    The Internal Revenue Service's failure to enforce income tax filing requirements for recipients of a form to report gambling winnings has cost it an estimated roughly $1.4 billion in additional tax revenue, the Treasury Inspector General for Tax Administration said Thursday.

  • October 03, 2024

    IRS Issues Part-Time Worker 403(b) Retirement Plan Guidance

    The Internal Revenue Service and U.S. Treasury Department published guidance Thursday on how long-term, part-time employees' Internal Revenue Code Section 403(b) retirement plans will be affected by the Secure 2.0 Act of 2022, which will apply to such plans starting in 2025.

  • October 03, 2024

    K&L Gates Boosts Houston Shop With Ernst & Young Tax Ace

    K&L Gates LLP strengthened its Houston office this week with the hire of a tax partner with nearly three decades of expertise in advising multinational corporations on U.S. taxation on cross-border acquisitions and other transactions.

  • October 03, 2024

    Calif. Can't Delay Bank's $20.7M Tax Refund, FDIC Tells Court

    A California tax collection agency shouldn't be allowed to delay a $20.7 million tax refund it owes the shuttered Signature Bank, the Federal Deposit Insurance Corp. told a New York federal court, saying that as the bank's receiver, it's entitled to the money now.

  • October 03, 2024

    Tax Deadlines Delayed For Victims Of Wash. Reservation Fires

    Taxpayers on the Yakama Nation's reservation in Washington state will have until Feb. 3 to file individual and business tax returns and make payments following wildfires, the Internal Revenue Service said Thursday.

Expert Analysis

  • A Proposal For Fairer, More Efficient Innocent Spouse Relief

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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.

  • A Post-Mortem Analysis Of Stroock's Demise

    Author Photo

    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

    Author Photo

    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

  • Planning A Defense As IRS Kicks Off Sports Losses Campaign

    Author Photo

    Sports team owners and partnerships face potential examination under the Internal Revenue Service’s recently announced sports industry losses campaign, and should be preparing to explain what drove their reported losses and assembling documentation to support their tax return positions and accounting methods, say Sheri Dillon and Jennifer Breen at Morgan Lewis.

  • What New Calif. Strike Force Means For White Collar Crimes

    Author Photo

    The recently announced Central District of California strike force targeting complex corporate and securities fraud — following the Northern District of California's model — combines experienced prosecutorial leadership and partnerships with federal agencies like the IRS and FBI, and could result in an uptick in the number of cases and speed of proceedings, say attorneys at MoFo.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

    Author Photo

    While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.