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Federal

  • October 22, 2018

    IRS Asks For Comment On Reportable Transaction Disclosures

    The Internal Revenue Service on Monday asked for public input on reportable transaction disclosures and on the procedures for large businesses to join its compliance program.

  • October 22, 2018

    IRS Seeks Feedback On Employer Child Care Tax Credit

    The Internal Revenue Service is seeking comment on reporting requirements for employers requesting a tax credit for providing child care, the agency said Monday.

  • October 22, 2018

    IRS Seeks Comments On Procedure For Accounting Changes

    The Internal Revenue Service is seeking comment on a revenue procedure that involves changes in accounting periods or methods, the agency said Monday.

  • October 22, 2018

    Contact Info Changed For Taxpayer Correspondence Meeting

    Contact information for the Nov. 8 meeting of the Taxpayer Advocacy Panel Correspondence Project Committee has changed, the Internal Revenue Service said Monday.

  • October 21, 2018

    Small Partnerships Not Heeding New Rep. Rules, Panelists Say

    Despite the potential unilateral power granted to the new role of partnership representatives during Internal Revenue Service examinations, experts at a tax conference Sunday said some smaller partnerships are not paying enough attention to what needs to be done to address the changes.

  • October 21, 2018

    JCT In Tough Spot Over Tax Overhaul 'Bluebook,' Expert Says

    Because of the partisan nature of the federal tax overhaul, the Joint Committee on Taxation likely will face high pressure on how to address the new law in the committee’s “Bluebook,” long considered an authoritative source of legislative history, a tax expert said Sunday at a New York University forum on federal taxation.

  • October 19, 2018

    Opportunity Zone Regs Could Still Leave Openings For Abuse

    Guidance released Friday by the U.S. Department of the Treasury on the deferral of taxable gains under the opportunity zone program leaves potential avenues for abuse by investors, who may be able to take advantage of uncertainty over the treatment of vacant lots, as one example.

  • October 19, 2018

    $51B A Year In US-Backed Bonds Go To State Works: CBO Report

    A recent report by the Congressional Budget Office said U.S. states and localities used a yearly average of $43 billion in tax-exempt bonds and $8 billion in tax credit bonds backed by the federal government for transportation and infrastructure projects from 2007 through 2016.

  • October 19, 2018

    IRS Defends Reporting Notice For Insurers Before 6th Circ.

    The Internal Revenue Service’s attorney defended the agency Friday before Sixth Circuit judges trying to understand why an insurer’s lawsuit challenging a reporting requirement amounts to a banned attempt to restrain tax collection.

  • October 19, 2018

    Tax Prep Biz Owner Gets 9 Years Over Bogus Returns

    The owner of a tax preparation company was sentenced Friday in a Virginia federal court to nine years in prison for preparing thousands of tax returns for clients who claimed bogus tax credits and expenses.

  • October 19, 2018

    Biz Owner Can Deduct Lawsuit Defense Costs, 5th Circ. Told

    The owner of a cleaning company has told the Fifth Circuit Court of Appeals that his business should be able to deduct his legal fees incurred during a wrongful death suit, which was settled for $2.3 million, even though the case did not involve business activities.

  • October 19, 2018

    Firm Tells 9th Circ. IRS Wrongly Collected Late Tax Penalty

    A California law firm told the Ninth Circuit Friday that the Internal Revenue Service wrongly imposed a late-filing penalty for an informational tax return and the lower court upheld the decision based on the incorrect conclusion that the form was not sent on time.

  • October 19, 2018

    Manafort, Ailing In Jail, Faces February Sentencing Date

    Former Trump campaign chairman Paul Manafort will be sentenced in February for his conviction on charges of subscribing to false tax returns, bank fraud and failing to disclose offshore bank accounts, a Virginia federal judge ordered Friday, after attorneys complained the embattled politico's health has suffered from his incarceration.

  • October 19, 2018

    Taxation With Representation: Wachtell, Simpson, Cravath

    In this week’s Taxation With Representation, Harris Corp. snags L3 Technologies Inc. for $35 billion, Novartis AG inks $2.1 billion deal with Endocyte Inc., Invesco Ltd. scoops Massachusetts Mutual Life Insurance Co.’s asset management unit OppenheimerFunds for $5.7 billion, and Oncor Electric Delivery Co. and Sempra Energy nab InraREIT for $1.3 billion.

  • October 19, 2018

    Virgin Islands Seeks Stay Of Judgment Against Its Excise Tax

    The U.S. Virgin Islands asked a federal court Friday to stay a judgment that the territorial government is appealing: a finding that an excise tax is unconstitutional because it impedes interstate commerce.

  • October 19, 2018

    NJ Man Who Owes $16M In Tax Tried To Dodge Liens, DOJ Says

    A New Jersey man who owes more than $16 million in taxes has concealed his ownership of multiple properties to evade federal tax liens on them, according to a complaint filed recently by the U.S. government.

  • October 19, 2018

    Skyscraper Owners Seek Quick Tax Court Win Over $10M Penalty

    Penalties over $10 million are inappropriate for a disallowed conservation easement because the rejection was based on a first impression of tax law and the taxpayer relied in good faith on its tax experts, the taxpayer said in a summary judgment motion filed in the U.S. Tax Court.

  • October 19, 2018

    Foundation Granted Approval To Award Scholarship Grants

    The Internal Revenue Service on Friday released a letter ruling granting approval to a private nonprofit foundation to award tax-free scholarship grants to students to improve the art and science of a particular field.

  • October 19, 2018

    IRS Grants Extension For Production Payment Election

    The Internal Revenue Service granted a limited liability corporation’s request for an extension to file an election statement for production payments in a private letter ruling released Friday.

  • October 19, 2018

    IRS Agrees With Holding Co. On Normalization Requirements

    The Internal Revenue Service agreed with a holding company’s interpretation that the normalization method of accounting can’t be used in certain situations in which depreciation creates a tax benefit, according to a private letter ruling released Friday.

Featured Stories

  • Opportunity Zone Regs Could Still Leave Openings For Abuse

    Amy Lee Rosen

    Guidance released Friday by the U.S. Department of the Treasury on the deferral of taxable gains under the opportunity zone program leaves potential avenues for abuse by investors, who may be able to take advantage of uncertainty over the treatment of vacant lots, as one example.

  • OIRA Review Unlikely To Substantially Alter Treasury Rules

    No Photo Available

    A White House office has newfound authority to review rules issued by the U.S. Department of the Treasury, but based on the oversight conducted so far, the change is unlikely to result in dramatic alterations to tax regulations.

  • Cos. Hope For Easy Way Out Of Employee Stock Option Rules

    Amy Lee Rosen

    Burdensome requirements of a new program allowing eligible employees to defer tax on the exercise of certain employee stock option programs have many companies hoping the Internal Revenue Service will provide an easy out in forthcoming guidance.

Expert Analysis

  • Series

    Trade Wars: Restricting Foreign Access To US Technology

    Hdeel Abdelhady

    The tech industry is now at the center of policies designed to protect U.S. technology from foreign access and influence — including not only restrictions on foreign investment, but also supply chain exclusions, limits on academic research, curbs on third-country technology transfers and measures against foreign control of key raw materials, says Hdeel Abdelhady of MassPoint Legal and Strategy Advisory PLLC.

  • Are You An Inadvertent US Shareholder In A Foreign Corp?

    Saren Goldner

    Attorneys at Eversheds Sutherland LLP provide a practical approach to evaluating ownership of non-U.S. entities under the new Subpart F rules and to dealing with the consequences of becoming a U.S. shareholder in a CFC in which you have no control.

  • Foreign Investors May Benefit From Opportunity Zones

    Galia Antebi

    Galia Antebi and Nina Krauthamer of Ruchelman PLLC discuss the elements of the opportunity zone tax code provision and the related options for non-U.S. investors, who generally are not subject to U.S. taxation on dispositions of capital property other than U.S. real property.

  • Series

    Trade Wars: Top 10 Trump Trends

    Charles Skuba

    The inner workings of the Trump economics and trade team remain foggy, but the administration's trade strategy can be discerned from the public statements of the president and his advisers. Unpredictability, mercantilism, bilateralism and a willingness to accept collateral damage are among the most important patterns, says Charles Skuba of Georgetown University’s McDonough School of Business.

  • Inside NonBelief Relief's Challenge To A Tax Filing Exemption

    Samuel Brunson

    Last week, nonprofit NonBelief Relief filed a lawsuit in a D.C. federal court challenging the IRS' mandatory exception from filing annual information returns given to churches — but not to other nonprofits — on the grounds that it violates the First Amendment's establishment clause. Professor Samuel Brunson of Loyola University Chicago School of Law takes a first look at the case.

  • Tax Savings Available With Pre-Immigration Planning

    Patrick McCormick

    A multitude of tax considerations are relevant for those considering immigration to the United States. Taking action prior to immigration is paramount in both optimizing planning opportunities and avoiding prospective tax headaches, says Patrick McCormick of Drucker & Scaccetti.

  • Series

    Trade Wars: When Trade And National Security Converge

    Mario Mancuso

    Increasing tariffs, new scrutiny of foreign investments in U.S. companies, and export controls over “emerging and foundational” technology are part of a Trump administration strategy to advance national security objectives using economic tools. These measures are ushering in a new era of trade restrictions, say attorneys with Kirkland & Ellis LLP.

  • Series

    Trade Wars: Anti-Dumping And Countervailing Duty Trends

    Shelby Anderson

    In the first article of this special series on the Trump administration's trade policies, attorneys from Covington & Burling LLP explore how a notable increase in U.S. anti-dumping and countervailing duty enforcement actions is creating significant compliance challenges for foreign companies and U.S. importers.

  • Tax Evasion Knows No Borders

    Kim Marie Boylan

    The former CEO of a U.K. bank recently pled guilty to charges under the Foreign Account Tax Compliance Act, following a U.S. Department of Justice sting operation spanning several countries. The conviction sends a clear message that U.S. authorities will prosecute not only U.S. account holders, but those who facilitate tax evasion, whatever their nationality, say attorneys at White & Case LLP.

  • Deducting SEC Disgorgement In A Post-Kokesh World

    Pamela Johnston

    The U.S. Supreme Court's ruling last year in Kokesh has an unintended consequence — the IRS and state taxing authorities have been applying the decision to challenge deductions for disgorgement paid as a result of U.S. Securities and Exchange Commission settlements. However, a settling party can still qualify for a deduction, say attorneys with Foley & Lardner LLP.