Federal
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
Expert Analysis
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Taxing The Digital Economy: The Good, The Bad And The Ugly
U.S. tech companies should watch for important developments in international taxation, including the resolution of Apple's decade-old state aid case, growing frustration with the Organization for Economic Cooperation and Development's global tax plan and adoption of the digital services tax instead, says Joyce Beebe at Rice University's Baker Institute for Public Policy.
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Big Tax Changes For Multinational Cos. In Budget Proposal
The Biden administration’s fiscal year 2024 budget proposes changes that would materially alter decades-old Internal Revenue Code provisions, requiring a shift in multinational corporations' tax planning strategies comparable to that required after enactment of the Tax Cuts and Jobs Act, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.
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SVB Collapse Reinvigorates Bank Accounting Debate
Silicon Valley Bank's sudden collapse revives questions over whether fair value or amortized cost accounting is the most appropriate for banks' financial reporting — a controversy that's crucial for understanding what information could have helped market participants better understand SVB's financial condition, say consultants at Analysis Group.
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Brownfield Renewables Guidance Leaves Site Eligibility Murky
Recent IRS guidance sheds some light on the Inflation Reduction Act's incentives for renewable energy development on contaminated sites — but the eligibility of certain sites for brownfield status remains uncertain, say Megan Caldwell and Jon Micah Goeller at Husch Blackwell.
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Get Ready For IRS Criminal Crackdown On Crypto
Recent developments at the IRS, from a new operating plan to the announcement of a centralized data center, signal that the agency is ramping up criminal enforcement against those using digital assets to evade tax liabilities — and given its high conviction rate, companies and individuals must prioritize compliance, say attorneys at BakerHostetler.
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NFT Tax Guidance Shows IRS Interest In Crypto Enforcement
The IRS' first ever guidance addressing the federal income tax treatment of NFTs indicates the agency could take a potentially aggressive stance in enforcing U.S. tax laws in the NFT and crypto spaces, which could have a significant impact on the self-directed IRA market, say attorneys at BakerHostetler.
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Substantiation Is Key When Gifting Crypto To Charity
A recent Internal Revenue Service memorandum makes clear that the agency will require substantiation when gifting cryptocurrency to charity, even for relatively small amounts, so donors need to be aware of the important differences between crypto and typical cash donations, says Sheryl Morrison at Lathrop GPM.
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Senate Credit Suisse Report Puts Attention On Banks, Trusts
The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.
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Seeking IRS Accountability For Faulty Microcaptive Notice
Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.
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Biden Admin. Proposals Both Encourage And Thwart EV Adoption
While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.
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Heed PCAOB's Warning On Proof-Of-Reserves Reports
While directed at investors, the Public Company Accounting Oversight Board's recent advisory on proof-of-reserves reports is a timely and stark warning to crypto entities, as well as their customers and accounting firms, to tread carefully in their reliance on these reports as proof of financial stability, say Patrick Bryan and Deborah Meshulam at DLA Piper.
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Cos. Should Heed IRS Warnings About Employee Tax Credit
The IRS has recently been cautioning employers claiming the pandemic-related employee retention credit to carefully review all the eligibility requirements and be wary of relying on third-party advisers regarding their qualification for the credit, say Eric Pearson and Timothy Voigtman at Foley & Lardner.
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Renewable Energy M&A Is Still Strong, Despite Challenges
The recent history of renewable energy has included ongoing supply chain issues, legislative challenges and rising interest rates — but mergers and acquisitions in the sector are expected to remain robust this year, fueled by growing demand and Inflation Reduction Act incentives, say consultants at FTI Consulting.