Federal

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • June 10, 2024

    Treasury Dept. Beats IRS Agent's Religious Bias Suit

    The U.S. Department of the Treasury defeated an Internal Revenue Service agent's suit claiming he was disciplined for a three-day celebration of Easter mandated by his Christian faith, with a Florida federal judge finding the reprimand was based on performance rather than religion.

  • June 07, 2024

    LIHTC Developer Asks 11th Circ. To Undo Investor Takeover

    A developer told the Eleventh Circuit on Friday it is a victim of a scheme by investors using a lower court ruling to complete a takeover of two Tampa, Florida, senior housing complexes developed with federal low-income housing tax credits.

  • June 07, 2024

    Trust Can Deduct Property Income As Gift, IRS Says

    A trust can deduct gross income set aside as a charitable contribution stemming from the distribution of real property from the corporation that is the trust's sole shareholder, the IRS said in a private letter ruling released Friday.

  • June 07, 2024

    IRS Delays Deadlines In W.Va., Ky. Counties Hit By Tornadoes

    Certain West Virginia and Kentucky taxpayers impacted by tornadoes and other major weather events that hit the area April 2 now have until Nov. 1 to file various individual and business tax returns and make payments, the Internal Revenue Service said Friday.

  • June 07, 2024

    No Loss On Terminated Rate Agreements, Chief Counsel Says

    A company that executed forward-rate agreements cannot claim a loss in connection with the termination of the agreements because its adjusted basis in the agreements was zero, according to a memo released Friday by the IRS Office of Chief Counsel.

  • June 07, 2024

    IRS Updates EV Battery Reporting Guide For Tax Credits

    The Internal Revenue Service provided updated guidance Friday for automakers planning to provide a report on meeting the battery sourcing requirements that can qualify their new electric vehicle models for the consumer tax credit of up to $7,500.

  • June 07, 2024

    6th Circ. Finds Ethical Lapses Justify Bar On Firm's Outreach

    The Sixth Circuit said Thursday a Michigan federal judge shouldn't have faulted a law firm for attacking a proposed tax foreclosure class-action settlement in solicitation letters, but nevertheless upheld the judge's order barring contact with certain class members because of the firm's actual ethical lapses.

  • June 07, 2024

    Subsidiary Won't Lose Status Before Dissolving, IRS Says

    A court-ordered liquidation of an insurance company won't cause it to lose its status as a corporation before it completes its final dissolution, the Internal Revenue Service said in a private letter ruling released Friday.

  • June 07, 2024

    Dentons Adds Pair Of Husch Blackwell Tax Attys

    Two South Carolina tax attorneys have joined Dentons' corporate, tax and private client practice as partners after moving from Husch Blackwell LLP, the firm announced on Thursday.

  • June 07, 2024

    IRS Scrutinizing Hospitals' Tax Exemptions, Official Says

    The Internal Revenue Service's Tax-Exempt & Government Entities Division has started auditing tax-exempt hospitals to ensure they're complying with exemption requirements, an agency official said Friday.

  • June 07, 2024

    Halliburton Wrongly Denied $11.3M Deduction, Court Told

    The Internal Revenue Service is arbitrarily and wrongfully refusing to refund Halliburton over $11.3 million in tax deductions taken for a payment to a foreign government to secure the safety of the company's employees, Halliburton told a federal court.

  • June 07, 2024

    Fed. Circ. Panel Doubts Bid To Nix Actavis' $12M Deduction

    A Federal Circuit panel seemed skeptical of the government's bid to overturn a decision allowing drugmaker Actavis to deduct $12 million it spent fending off lawsuits as it secured approval to sell generics, raising the question during oral arguments Friday whether the company was being uniquely targeted.

  • June 07, 2024

    Taxation With Representation: Vinson, Latham, Ropes & Gray

    In this Week's Taxation with Representation, Waste Management buys Stericycle, Becton Dickinson pays $4.2 billion for Edwards Lifesciences' critical care products unit, Aquiline Capital Partners raises over $3.4 billion in fund capital, and Bain Capital buys PowerSchool Holdings.

  • June 07, 2024

    IRS Lists Shuttered Coal Areas For Energy Bonus Credits

    The Internal Revenue Service on Friday issued updated lists of areas, including closed coal mines and factories, where developers can qualify for additional tax credits for building their clean energy projects.

  • June 07, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, which included proposed foreign trust transaction reporting requirements.

  • June 06, 2024

    Medtronic Urges 8th Circ. To Back Its Transfer Pricing Method

    Medical device maker Medtronic reiterated Thursday its bid for the Eighth Circuit to revive its method for pricing intangible property that was licensed to a Puerto Rican affiliate, arguing the government's concessions show why the company's approach is more reliable.

  • June 06, 2024

    9th Circ. Denies Trust Refund Of Money Forfeited To IRS

    A trust lost its ownership claims to property when an Idaho federal court determined the property had been transferred to the trust fraudulently, the Ninth Circuit said Thursday, affirming a decision to deny a $225,000 tax refund.

  • June 06, 2024

    Estate Entitled To Deduct Payouts To Stepkids, 11th Circ. Told

    The U.S. Tax Court wrongly denied deductions to a former attorney's $81 million estate for million-dollar payouts it made to his stepchildren after they sued, the estate told the Eleventh Circuit, saying the payments satisfied legitimate claims against the estate and were therefore deductible.

  • June 06, 2024

    Tax Court Upholds Rejection Of Man's Biz Deductions

    A Floridian failed to adequately back up certain business loss deduction claims made on his tax return, the U.S. Tax Court said Thursday, backing the IRS' rejection of the claims and imposition of an accuracy-related penalty.

Expert Analysis

  • The Corporate Transparency Act Isn't Dead Yet

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    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.

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    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.

  • Employers, Prep For Shorter Stock Awards Settlement Cycle

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    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.

  • Demystifying IRS' Claims Of $851B Return On Investment

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    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.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    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.

  • A Proposal For Fairer, More Efficient Innocent Spouse Relief

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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.

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