Federal
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May 01, 2024
Senate Dems Reintroduce Bill To Tax And Regulate Cannabis
Senate Democrats on Wednesday reintroduced a cannabis legalization bill that would remove the drug entirely from the ambit of the Controlled Substances Act and impose a tax-and-regulate scheme akin to what is currently in place for alcohol and tobacco.
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May 01, 2024
IRS Updates PLR Procedure For Stock Spin-Off Transactions
The Internal Revenue Service issued updated procedures Wednesday for requesting private letter rulings pertaining to spin-off transactions, including what representations and analysis must accompany the requests.
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May 01, 2024
No Relief For Fla. Adviser Convicted In $80M Trading Scam
The Eleventh Circuit on Wednesday affirmed the conviction of a Florida investment adviser who bilked more than $80 million from the hundreds of people he persuaded to invest in a fraudulent company, after concluding he was not in custody when he made statements to the police.
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May 01, 2024
Family Trust Asks Justices To Review $16.2M Tax Row
A family trust established by grandparents for their five grandchildren asked the U.S. Supreme Court to review a Third Circuit ruling finding the trust was the nominee of an adult son with $16.2 million in tax liabilities, saying the decision stands to upset estate planning norms.
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May 01, 2024
7th Circ. Affirms Research Tax Credit Limit For Scoreboard Co.
A scoreboard maker can't include an executive's compensation in its research tax credit claims, a Seventh Circuit panel ruled, agreeing with the U.S. Tax Court that there was no proof to show how much time he spent on research relevant for the credit.
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May 01, 2024
Think Tank Says 'Distortive' DSTs Not The Right Way Forward
As jurisdictions around the world continue to struggle with how to adequately tax the increasingly digital economy, they should look to expand their consumption taxes, not enact digital services taxes, the Tax Foundation said.
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May 01, 2024
Ex-NFL Star Romanowski Files For Ch. 11 Amid $15M Tax Suit
Ex NFL star and Super Bowl champion Bill Romanowski has filed for Chapter 11 protection in California after being slapped with a $15.5 million income tax suit.
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May 01, 2024
Liberty Global Defends $109M Tax Refund Bid In 10th Circ.
Telecommunications giant Liberty Global urged the Tenth Circuit to revive the company's $109 million tax refund bid, arguing a lower court rejected the claim by wrongly disregarding intercompany transactions that are permitted under legislation involving the repatriation of foreign profits.
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May 01, 2024
Metal Biz Owner Cops To Tax Fraud On $2.8M Income
The owner of a metal fabrication company admitted to neglecting to report nearly $3 million in business income to the IRS, Connecticut federal prosecutors announced.
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May 01, 2024
Billionaire Energy Co. Founder Sues Booz Allen Over IRS Leak
Energy Transfer co-founder Kelcy Warren accused government contractor Booz Allen Hamilton of failing to supervise an employee who stole Warren's private tax information and that of thousands of other wealthy people while on assignment at the IRS, according to a complaint in Maryland federal court.
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May 01, 2024
Overtime Theft Scheme Earns Ex-Mass. Trooper 3 Years
The former second-in-command of a Massachusetts state police traffic safety unit was sentenced to three years in prison for his role in a widespread conspiracy to steal federally funded overtime through no-work shifts.
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May 01, 2024
Tax Credit Transfer Regs Show IRS Caution In Rulemaking
The IRS and Treasury's final rules on the sale and transfer of green energy credits maintained a strict reading of the statute while making few changes, a sign of caution by regulators amid judicial scrutiny of the government's rulemaking authority.
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May 01, 2024
Celeb Charity Says Law Firm Partner Went Rogue, Leaked Info
The nonprofit responsible for handling more than $8 million donated to NFL safety Damar Hamlin following his on-field cardiac arrest has lodged a suit in Illinois federal court against its former counsel, claiming a lawyer leaked private documents to the press as retribution for his firing after publicizing faulty information.
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April 30, 2024
Ex-Autonomy VP Says CEO Lynch Told Him To Lie To Investors
A former Autonomy business development executive testified Tuesday that CEO Mike Lynch directed him to lie to a hedge fund investor about prepaid royalty deals that boosted the company's upfront revenue numbers, saying at Lynch's criminal fraud trial that it was hard to say no to the "big boss."
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April 30, 2024
'Bitcoin Jesus' Dodged Nearly $50M In Taxes, Feds Say
The U.S. has charged an early bitcoin investor dubbed "Bitcoin Jesus" over allegations that he dodged approximately $48 million in taxes by filing false tax returns and concealing how much of the cryptocurrency he owned, according to an announcement from the U.S. Department of Justice on Tuesday.
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April 30, 2024
TCJA Expiration Would Lead To Tax Hikes, GOP Reps. Say
House Ways and Means Committee Republicans pressed Treasury Secretary Janet Yellen on Tuesday on whether President Joe Biden would support the extension of the 2017 tax law's expiring provisions, saying allowing them to end would cause tax hikes for low- and middle-income taxpayers.
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April 30, 2024
Crypto Exec Denies $2B Laundering Charges, Is Out On Bail
The CEO of crypto mixer Samourai Wallet has pled not guilty to charges he helped facilitate over $2 billion in illegal transactions and was released on $1 million bail after surrendering to federal authorities voluntarily.
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April 30, 2024
Yellen Says US Pushing To Protect R&D Credit Under Pillar 2
U.S. Treasury Department negotiators are continuing to advocate for more favorable treatment of the country's research and development tax credit under the Pillar Two global minimum tax rules, Treasury Secretary Janet Yellen told the House Ways and Means Committee on Tuesday.
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April 30, 2024
IRS Issues Automatic Changes To Tax Code Procedures
The Internal Revenue Service issued Tuesday its annual list of automatic changes to Internal Revenue Code procedures, including provisions for gross income, trade or business expenses and capital expenditures, among others.
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April 30, 2024
IRS Rejects Arizona's Effort To Exempt State Tax Rebates
The state of Arizona can't sue the federal government to litigate the personal claims of its taxpayers, the Internal Revenue Service told a federal court in an effort to dismiss a bid by the state to exempt state tax rebates from federal income taxes.
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April 30, 2024
Attys, Broker Can't Escape $4M Tax Fraud Convictions
A North Carolina federal judge has denied acquittal requests from two tax attorneys and an insurance agent who were convicted for their roles in a $4 million tax avoidance scheme, saying he agreed with federal prosecutors who argued there was sufficient evidence for the underlying charges.
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April 30, 2024
Feds Endorse Easing Marijuana Status In Big Policy Shift
Federal drug enforcers will recommend loosening restrictions on cannabis for the first time since the drug was made federally illegal decades ago, the U.S. Department of Justice announced Tuesday.
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April 30, 2024
IRS Updates Guidance For Clean Jet Fuel Tax Credits
The Internal Revenue Service released guidance Tuesday that updated an environmental model that manufacturers of a low-carbon alternative to conventional jet fuel, such as ethanol, can use to qualify for a new tax credit and provided a safe harbor for producers to meet the incentive's requirements.
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April 30, 2024
The Tax Angle: TCJA Teams, Dear Colleague Letters
From a look at House GOP efforts to prepare for next year's expiration of their 2017 tax overhaul to ongoing attempts by lawmakers to draw attention and support for their own tax legislation, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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April 30, 2024
Ex-Mass. Pol Can't Sink Fraud Case With 'Imaginative' Attacks
A Boston federal judge on Tuesday rejected what he called an "imaginative and novel" effort by a former Massachusetts politician to dismiss charges of lying to get COVID-19 relief funds and underreporting income on his taxes.
Expert Analysis
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IRS' Tax Gap Statistics Don't Paint A Full Compliance Picture
The Internal Revenue Service's recent report indicating a widening tax gap sheds important light on tax compliance, underlines key pressure points and provides insights into how tax administration could be improved; but tax gap estimates also have their limits, says Joyce Beebe at Rice University.
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Labor Rules Will Unlock IRA Tax Credits' Full Value
Companies that make sure to follow the Inflation Reduction Act's unique labor rules will be in the best position to unlock the law's tremendous tax incentives aimed at promoting renewable energy, lowering greenhouse gas emissions and encouraging carbon sequestration, say Nicole Elliott and Timothy Taylor at Holland & Knight.
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Making The Most Of New Tax Credits For EV Charging Stations
The Inflation Reduction Act recently extended, expanded and renewed the tax credits available for electric vehicle charging station projects — but developers must navigate new challenges, including geographic and prevailing wage requirements, to take full advantage of the updated credits, says James English at Clark Hill.
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Key Income Tax Issues Triggered By Remote Employees
A host of fact-specific tax determinations arise in connection with remote work arrangements, from defining working-condition fringe benefit exclusions to nexus-dependent state withholding obligations, complicating compliance for corporate tax counsel and human resources professionals, say Thomas Cryan and Spencer Walters at Ivins Phillips.
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An Evaluation Of New Solar Energy Opportunities For REITs
The Inflation Reduction Act's changes to investment tax credit rules will make it possible for real estate investment trusts to own solar facilities and also benefit economically from tax credits, but certain limitations remain, say attorneys at Mayer Brown.
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Cases Show Real-World Laws Likely Apply In Metaverse
Although much has been written about the so-called unprecedented legal issues raised by the metaverse, recent federal cases demonstrate that companies can expect metaverse activities to be policed and enforced much like they would be in the physical world, say attorneys at Crowell & Moring.
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Justices Poised To Reject Narrowing Unclaimed Property Law
After U.S. Supreme Court oral arguments in the so-called MoneyGram case — a dispute between Delaware and several other states over which has the right to about $300 million in unclaimed property — the court seems ready to rule against Delaware, but nuances of the court's reasoning will have a broader sweep, say attorneys at Alston & Bird.
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How High Court Could Change FBAR Penalty Landscape
On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.
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IRS Memo May Change IP Royalty Tax Prepayment Planning
A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.
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What IRS Funding Increase Means For Taxpayers
The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.
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6 Tax Considerations For Life Sciences Collaboration Deals
Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.
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Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess
Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.
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Post-Litigation Refund Strategies To Defeat Class Certification
The Third Circuit's recent revival of the Duncan v. Governor of the Virgin Islands class action shows that defendants should strongly consider tendering refunds to class representatives — even after they file suit — to create a substantial obstacle to certification, say attorneys at Covington.