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Federal

  • June 19, 2018

    Soda Taxes More Regressive Than Thought, Study Finds

    The financial impact of sugar-sweetened beverage taxes on low-income households is even more pronounced than commonly believed, the Tax Foundation said Tuesday, citing new research. 

  • June 19, 2018

    IRS’ Bid for Tax Data Doesn't Flout EU Law, Official Says

    Airbnb and other rental platforms do not appear to be violating European Union data protection rules when they give the Internal Revenue Service basic taxpayer information on EU citizen hosts and their guests, European Tax Commissioner Pierre Moscovici said.

  • June 19, 2018

    Nonprofit Asks 7th Circ. To End Clergy Housing Tax Break

    In a brief filed Monday, a nonprofit group asked the Seventh Circuit Court of Appeals to eliminate a tax exemption allowing clergy members to take out housing allowances from their gross income.

  • June 19, 2018

    Tax Law Expected To Reduce Giving By $17.2B, Report Says

    The federal tax overhaul will reduce charitable giving by about $17.2 billion in 2018, a 4 percent decrease, according to a report by the American Enterprise Institute.

  • June 19, 2018

    Meet The Judge Who Will Decide The ACA's Fate

    The Texas federal judge presiding over the latest legal assault on the Affordable Care Act has a BigLaw background, Capitol Hill connections, deep roots in the Lone Star State and a judicial track record that could send ACA supporters reaching for bottles of Xanax.

  • June 19, 2018

    Puerto Rico Announces School Supply Sales Tax Holidays

    The Puerto Rico Department of Treasury has announced that school supplies and uniforms will be free of sales and use tax on July 13 and 14, 2018, and Jan. 4 and 5, 2019.

  • June 19, 2018

    Property Manager Was Not A Contractor, Tax Court Finds

    A property manager was an employee of an Oklahoma limited liability company, not an independent contractor, the U.S. Tax Court said in a Tuesday ruling that found the company wasn’t entitled to employment tax relief. 

  • June 19, 2018

    Ex-IRS Special Agent Convicted For Filing False Tax Returns

    A federal jury in California has found a former Internal Revenue Service special agent guilty of filing false tax returns, stealing government money and attempting to obstruct a federal investigation into her alleged fraud, according to the U.S. Department of Justice.

  • June 19, 2018

    Club Owner Pleads Ignorance, Seeks Relief In 6th Circ.

    A Tennessee nightclub owner representing herself at the U.S. Tax Court clearly had no understanding of tax law and should have been informed that she could ask for a continuance, the Sixth Circuit was told.

  • June 19, 2018

    Sullivan & Cromwell Reps Cheniere In $580M Deal For MLP

    Sullivan & Cromwell LLP-led Cheniere Energy Inc. said Tuesday it will pay approximately $580 million to buy up all the shares it doesn't already own in a related master limited partnership, joining a growing number of energy companies adjusting their corporate structures following tax adjustments to MLPs by the Federal Energy Regulatory Commission.

  • June 19, 2018

    Citrus Growers Advised On Accounting Method Change By IRS

    The Internal Revenue Service released guidance Tuesday for citrus growers on how to obtain automatic consent to change their accounting method due to a new provision created by last year's federal tax overhaul.

  • June 19, 2018

    IRS Urges Tax Pros To Save On Forum By Registering Soon

    The Internal Revenue Service on Tuesday encouraged tax professionals to save money on a national tax forum in Atlanta by registering prior to June 26.

  • June 18, 2018

    Colleges' Subsidiary Losses Likely Deductible, Official Says

    The U.S. Treasury Department will most likely issue guidance stating that colleges and universities may deduct investment losses from related organizations, a Treasury official said Monday at a conference outside Washington, D.C.

  • June 18, 2018

    Oil Co. Loses Bid To Recoup $17.7M Tax Refund For Bad Debt

    A Texas federal judge handed the Internal Revenue Service a quick win Monday in a suit brought by oil field services company Baker Hughes Inc. seeking to recover $17.65 million in taxes it claims should have been allowed as a deduction for a bad debt made before it acquired BJ Services Co. in 2009.

  • June 18, 2018

    ‘Reference Sets’ Could Speed Up Transfer Pricing Cases

    The IRS is trying to create a “reference set library” of comparable company data used as benchmarks in transfer pricing cases — a move tax practitioners said could save time in audits or advance pricing agreements.

  • June 18, 2018

    Window Opened In Penalty Suits By IRS Errors May Not Last

    A recent decision by the U.S. Tax Court that discarded penalties in a $3.5 million tax case because the IRS lacked managerial approval for them could lead to the concession of additional penalties in existing cases, but tax practitioners and their clients should not bank on the agency continuing to commit such errors. 

  • June 18, 2018

    IRS Needs To Clarify Pass-Through Deduction, Tax Attys Say

    Coming guidance on the new pass-through deduction needs to clarify what income from which trades or businesses can be included as qualified business income, the American Bar Association Section of Taxation told the Internal Revenue Service on Monday.

  • June 18, 2018

    Proskauer Called ‘Conflicted’ In Sale Leaving $15M Tax Bill

    Proskauer Rose LLP was “hopelessly conflicted” when it advised a holding company in a sale to The Diversified Group Inc. nearly two decades ago that left trustees with a $15 million tax bill, the company said in a recent suit filed in New Jersey.

  • June 18, 2018

    Tax Court Denies Estate Quick Win Over $6.3M IRS Dispute

    The U.S. Tax Court denied partial summary judgment Monday to an estate's executor challenging some $6.3 million in tax deficiencies imposed by the Internal Revenue Service over split-dollar life insurance agreements entered into by the decedent. 

  • June 18, 2018

    IRS Can Improve On Scrutiny Of Workers' Comp, Audit Finds

    The Internal Revenue Service needs to provide effective oversight of its workers' compensation claims by obtaining updated medical status records, among other improvements, the Treasury Inspector General for Tax Administration said in a report released Monday.

Featured Stories

  • Meet The Judge Who Will Decide The ACA's Fate

    No Photo Available

    The Texas federal judge presiding over the latest legal assault on the Affordable Care Act has a BigLaw background, Capitol Hill connections, deep roots in the Lone Star State and a judicial track record that could send ACA supporters reaching for bottles of Xanax.

  • Window Opened In Penalty Suits By IRS Errors May Not Last

    Amy Lee Rosen

    A recent decision by the U.S. Tax Court that discarded penalties in a $3.5 million tax case because the IRS lacked managerial approval for them could lead to the concession of additional penalties in existing cases, but tax practitioners and their clients should not bank on the agency continuing to commit such errors.

  • SEC Roundup: Big US Cos. Book $140B In Repatriation Tax

    No Photo Available

    Since enactment of the U.S. tax overhaul, 66 public companies in the Fortune 500 have set aside $140 billion to pay the law’s levy on repatriated past earnings from foreign subsidiaries, according to corporate regulatory filings. Here, Law360 Tax Authority looks at what companies have said about the tax law’s foreign income provisions in recent reports to shareholders.

Expert Analysis

  • Tax Reform Adds Value To 2017 Changes In Accounting Methods

    Ellen McElroy

    The IRS’ annual automatic accounting method changes for 2017 and the 2017/2018 corporate tax rate differential created by last year's tax overhaul together provide companies with a unique opportunity to benefit permanently from changes that would otherwise be temporary, say Ellen McElroy and Michael Resnick of Eversheds Sutherland LLP.

  • Are Whistleblower Appeal Filing Deadlines Jurisdictional?

    Michael DeBlis

    The District of Columbia Circuit Court of Appeals will soon hear argument concerning whether a filing deadline set forth in the Internal Revenue Code can limit the Tax Court's ability to review decisions of the IRS Whistleblower Office. The court's ruling will affect all whistleblower appeals because the D.C. Circuit is the only court where whistleblower cases can be reviewed, says Michael DeBlis of DeBlis Law.

  • Excise Tax Problems? Retirement Compensation May Help

    Lowell Walters

    Tax-exempt and governmental entities are now subject to a 21 percent excise tax on excess compensation and severance pay given to their five most highly paid employees. If done with care, converting compensation to retirement plan contributions can help reduce or avoid these excise taxes, says Lowell Walters of Carlton Fields.

  • Highway Trust Fund Is Out Of Gas — Time For Mileage Fees

    Joshua Andrews

    Revenue from the federal gas tax — last increased in 1993 — continues to decline, leaving infrastructure critically underfunded. But pilot programs in multiple states have now proven that mileage-based road user fees can replenish the Highway Trust Fund and be implemented practically and fairly, say Joshua Andrews, Charles Stitt and Theodore Bristol of Faegre Baker Daniels Consulting.

  • Questions To Answer Before Investing In An Opportunity Fund

    Marc Schultz

    The opportunity zone program is an exciting new tax incentive offering substantial benefits for its participants. However, many questions about the program remain outstanding, most of which need to be resolved in order for opportunity funds to succeed as expected, says Marc Schultz of Snell & Wilmer LLP.

  • Timely File Payroll Taxes Because The IRS Is Watching

    Michael DeBlis

    After a study showed widespread noncompliance, the IRS has begun taking a tougher stance on employers' failure to timely meet payroll tax filing and payment requirements. Defenses for failure to comply are few, the penalties are stiff, and liability can be personal, so advisers should have clients respond to IRS inquiries with extreme care, says Michael Deblis of Deblis Law.

  • Opinion

    Exempt Indian Country From The 'Kiddie Tax'

    Nicole Elliott

    Congress should move to exclude the transfer of tribal funds to young tribal members from being taxed under the "Kiddie tax," a tax instated in 1986 and amplified by the Tax Cuts and Jobs Act, say attorneys at Holland & Knight LLP.

  • Unique Considerations In Cryptocurrency Estate Planning

    Michael Kearney

    Security features unique to cryptocurrency put investors at risk of losing such assets upon incapacity or death. Understanding these features and crafting a plan that addresses certain important factors will help assure digital assets are effectively passed on to heirs and beneficiaries, say Michael Kearney and Joseph Doll at Cole Schotz PC.

  • Tandem Nonprofit And For-Profit Cos. Must Walk Fine Line

    Allen Bromberger

    In tandem corporate structures, a nonprofit and a for-profit business must walk a fine line. The for-profit company must sustain enough economic benefit to justify its participation while the nonprofit must minimize such benefit or call its tax-exempt status into question. The inherent conflict is unavoidable, but companies can minimize many of the risks through careful planning, says Allen Bromberger at Perlman & Perlman LLP.

  • Mazzei Case Educed An Unusual Tax Court Response

    Lawrence Hill

    The U.S. Tax Court yet again showed itself to be an unfavorable forum for litigating tax-advantaged transactions with its decision in Mazzei v. Commissioner of Internal Revenue — deciding the taxpayers' foreign sales corporation structure lacked economic substance. However, this decision was particularly notable in featuring a rare Tax Court dissent, say Lawrence Hill and Kevin Platt of Winston & Strawn LLP.