Federal
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May 31, 2024
Ex-UBS Exec Owes $4.7M In FBAR Penalties, Court Told
A former CEO of Swiss bank UBS' North American group faces a $4.7 million tax bill that the U.S. claims is due because he did not report his foreign bank accounts or assets, according to a suit filed in Connecticut federal court.
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May 31, 2024
IRS Can Seek Tax Beyond Bankruptcy Deal, 11th Circ. Affirms
A deal between the IRS and an Alabama real estate developer to settle his tax debt for $2 million during Chapter 11 bankruptcy proceedings wasn't final, and the agency can demand additional taxes from him, the Eleventh Circuit affirmed Friday.
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May 31, 2024
US, Bulgaria Sign Country-By-Country Reporting Agreement
The U.S. and Bulgaria signed an agreement Friday on the automatic exchange of country-by-country reports between the nations, Bulgaria's Ministry of Finance said.
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May 31, 2024
IRS Memo Backs Tax For Noninsurance Payments To Captives
When the IRS determines that a company's payments to its foreign captive insurer were not for actual insurance, the agency can assert a 30% tax on the captive for the income it received under the arrangement, the IRS chief counsel's office said in a memo released Friday.
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May 31, 2024
Texan's Estate Owes $3.4M For Missed Tax Pays, Court Told
A Texas man's estate owes over $3.4 million in unpaid taxes, interest and penalties because of missed payments stretching back over a decade, even after multiple extensions were granted to the two executors, the government told a federal district court.
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May 31, 2024
5 Tax Bills To Watch This Summer
House and Senate lawmakers return to Washington, D.C., on Monday, where several tax-related bills await them in both chambers, including a stalled package that would restore business tax breaks and expand the child tax credit. Here, Law360 takes a look at five bills that could move through Congress this summer.
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May 31, 2024
Calif. Man Owes 6 Years Of FBAR Penalties, IRS Tells Court
A Californian has failed to pay foreign bank account reporting penalties he was assessed that were tied to a business he owed in Mexico for six years, the Internal Revenue Service told a federal court.
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May 31, 2024
Fuel Producers Should Apply ASAP For Tax Credit, IRS Says
Fuel producers hoping to start claiming the clean fuel production credit as soon as January should register with the Internal Revenue Service by July 15, the agency said Friday, warning that registration applications made after that date are less likely to go through in time.
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May 31, 2024
IRS Delays Deadlines For Mass. Taxpayers Hit By 2023 Storms
Certain Massachusetts taxpayers impacted by severe storms and flooding that hit the state Sept. 11 now have until July 31 to file various individual and business tax returns and make payments, the Internal Revenue Service said Friday.
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May 31, 2024
Taxation With Representation: Cravath, Cleary, Fried Frank
In this week's Taxation With Representation, T-Mobile buys United States Cellular Corp.'s wireless operations, Energy Transfer plans to buy WTG Midstream, ConocoPhillips acquires Marathon Oil, and Goldman Sachs Alternatives raises over $20 billion for its direct lending strategy.
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May 30, 2024
Chicago Kiosk Salesman Gets 1 Year For Filing False Returns
An electronic-sweepstakes kiosk salesman from Chicago was sentenced to a year in prison for filing false tax returns that included more than $500,000 in inflated business expenses, according to Illinois federal court documents.
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May 30, 2024
IRS Adds 16 Tax Court Sessions To Calendar
The Internal Revenue Service announced 16 U.S. Tax Court sessions in September and October and named calendar administrators for the sessions in a notice released Thursday.
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May 30, 2024
Tax Court Nixes $30M In Conservation Easement Deductions
The U.S. Tax Court upheld on Thursday the IRS' rejection of more than $30 million in charitable contribution deductions for Alabama conservation easements for partnerships acting as test cases for a larger group that took $187 million in deductions.
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May 30, 2024
Tax Court Tosses Whistleblower Award Contest
The U.S. Tax Court ruled Thursday that it cannot review a woman's roughly $1,700 whistleblower award from the Internal Revenue Service because it does not meet a threshold for mandatory awards.
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May 30, 2024
IRS Names New Chief Taxpayer Experience Officer
The Internal Revenue Service has chosen an adviser in its Transformation and Strategy Office to serve as the agency's new chief taxpayer experience officer, according to a statement Thursday.
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May 30, 2024
Later Pillar 1 Due Date Set For June As Tax Talks Wrap Up
Diplomats agreed this week to finalize a treaty for reallocating some of large companies' tax payments and setting standards to simplify some transfer pricing in lower-income countries by June 30 after having missed a March deadline, according to a statement published Thursday by the OECD.
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May 30, 2024
Ex-KPMG Manager Joins Davis+Gilbert As Tax Partner
A former managing director at KPMG has joined New York law firm Davis+Gilbert LLP as a tax partner in its corporate and transactions practice, Davis+Gilbert announced.
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May 30, 2024
Black Business Owners Sue Over Impact Of Transparency Act
The Corporate Transparency Act creates unique burdens on businesses owned by people of color, immigrants and other marginalized groups, the Black Economic Council of Massachusetts and several company owners said in the latest legal challenge to the anti-money laundering law.
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May 30, 2024
Russian Gas Ex-CFO Says $44M FBAR Penalty Is Excessive
The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks told a Florida federal court that the $44 million in foreign account reporting penalties the government is seeking is illegally high.
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May 30, 2024
IRS To Make E-File Program Permanent, Plans Expansions
The Internal Revenue Service will make permanent the free online tax filing system it launched as a limited pilot program this year and plans to expand its scope, Commissioner Daniel Werfel said Thursday.
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May 29, 2024
10th Circ. Tosses Insurance Co. Appeal In Tax Court Dispute
The Tenth Circuit tossed an insurance company's challenge to a U.S. Tax Court ruling rejecting the company's effort to invalidate tax deficiency notices on Wednesday, saying it lacked authority to hear the case because the Tax Court's decision wasn't a final one that would end litigation.
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May 29, 2024
Miami Tax Preparers Should Be Barred For Fraud, DOJ Says
Two Miami-based tax professionals and their businesses should be barred from preparing federal tax returns for others because they repeatedly claimed fraudulent credits without their customers' knowledge, the U.S. Department of Justice told a Florida federal court.
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May 29, 2024
Baker McKenzie Grows Tax Practice With Ex-KPMG Adviser
Baker McKenzie announced the hiring of an experienced Chicago-based tax adviser as a principal who most recently spent sixteen and a half years at Big Four accounting firm KPMG.
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May 29, 2024
Presidential Candidate Convicted For $15.5M Tax Fraud
A tax-preparation business owner and 2024 presidential candidate was convicted on 33 counts of tax fraud after being accused of inflating deductions in a scheme federal prosecutors said caused more than $15.5 million in tax losses, according to Texas federal court documents.
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May 29, 2024
Treasury Details Which Tech Would Get Clean Energy Credits
Treasury released proposed rules Wednesday outlining which technologies would qualify for new zero-emission energy tax credits, saying wind, solar and geothermal are among those that would make the cut.
Expert Analysis
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Using Agreements To Cover Gaps In Hydrogen Storage Regs
The Inflation Reduction Act's incentives for energy storage have spurred investment in hydrogen storage and production, but given the lack of comprehensive regulations surrounding the sector, developers should carefully craft project and financing agreements to mitigate uncertainties, say Omar Samji and Sarah George at Weil, and attorney Manushi Desai.
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Secure 2.0 Takeaways From DOL's 2024 Budget Proposal
The U.S. Department of Labor’s fiscal year 2024 budget proposal provides insight into the most pressing Secure 2.0 implementation issues, including establishment of a search database for finding lost retirement savings and developing guidance on the execution of newly authorized emergency savings accounts, say attorneys at Maynard Nexsen.
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Avoiding Negative Tax Consequences In Loan Modifications
Borrowers who may be caught in the dramatic uptick in nonperforming commercial real estate loans should consider strategies to avoid income and capital gains tax that may be triggered by loan modifications, says Aman Badyal at Glaser Weil.
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Benefits And Beyond: Fixing Employee Contribution Failures
Employers must address employee contribution failures promptly in order to avoid losing significant tax benefits of 401(k) or 403(b) plans, but the exact correction procedures vary depending on whether contributions were less than or greater than intended, say attorneys at Seyfarth Shaw.
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Now Is The Time For State And Local Sales Tax Simplification
In the five years since the U.S. Supreme Court’s landmark decision in South Dakota v. Wayfair, state and local governments increasingly rely on sales tax, but simple changes are needed to make compliance more manageable for taxpayers, wherever located, without unduly burdening interstate commerce, says Charles Maniace at Sovos.
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Recent Bills Show Congress' Growing Maturity On Cannabis
Though two recently introduced cannabis reform bills, the Prepare Act and the Small Business Tax Equity Act, are unlikely to pass in this Congress, they demonstrate a new level of focus and sophistication on the part of lawmakers as it relates to cannabis at the federal level, says Irina Dashevsky at Greenspoon Marder.
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What To Make Of IRS' New Advance Pricing Guidance
Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.
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Compliance Obligations Still Murky For Superfund Excise Tax
Comments on the IRS' reinstatement of the Superfund chemicals excise tax show that, given taxpayers' lack of institutional knowledge and the government's previous failure to finalize clarifying guidance, further regulatory action is needed to help taxpayers understand their obligations, say Nicole Elliott and Mary Kate Nicholson at Holland & Knight.
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The Reciprocal Tax Bill Is A Warning Shot At Pillar 2
A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.
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3 Developments That May Usher In A Nuclear Energy Revival
A recent advancement in nuclear energy technology, targeted provisions in the Inflation Reduction Act and a new G7 agreement on nuclear fuel supply chains may give nuclear power a seat at the table as a viable, zero-carbon energy source, say attorneys at Vinson & Elkins.
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What Tax-Exempt Orgs. Need From Energy Credit Guidance
Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.
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Unconventional Profits Interest Structures Find New Support
A recent U.S. Tax Court ruling should provide comfort that less-than-plain-vanilla profits interest structures, created to achieve complicated economic arrangements, can succeed in generating more optimal tax outcomes, provided the terms are properly drafted, says Daren Shaver at Hanson Bridgett.
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Roadblocks For Cannabis Employers Setting Up 401(k) Plans
Though the Internal Revenue Code and the Employee Retirement Income Security Act generally allow cannabis businesses to establish 401(k) plans for their employees, companies must still pick their way through uncertainties around tax deductions and recruiting reliable vendors, say attorneys at Shipman & Goodwin.