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Federal

  • December 14, 2018

    TCJA Could Spur Several Copycats, US Treasury Official Says

    Despite complaints about key international provisions of the U.S. tax overhaul, several countries have signaled interest in copying some of the measures, a senior official with the U.S. Department of the Treasury has said.

  • December 14, 2018

    Global Risk-Standard Unity Sought For Tax Rifts: IRS Official

    The U.S. and other countries participating in a pilot program on global tax dispute resolution are working toward common risk-assessment standards, but concede uniformity of data for multinational enterprises’ country-by-country reporting isn’t likely, an IRS official has said.

  • December 14, 2018

    Treasury To Re-Examine Obama Tax Rules On Debt In 2019

    The U.S. Department of the Treasury will reassess controversial Obama-era rules on tax avoidance through intercompany lending once the 2017 tax overhaul law’s international provisions are in place next year, a top-ranking official said Friday.

  • December 14, 2018

    Fed Circ. Upholds Two Tax Refund Denials But Allows Third

    The Federal Circuit on Friday partially upheld a lower court finding rejecting a couple’s attempt to get tax refunds on shareholder income for two years, but reversed one rejection because the court erred by not making sufficient factual findings.

  • December 14, 2018

    No IRS Project On Guarantee Pricing, Treasury Official Says

    The U.S. Treasury Department and the Internal Revenue Service aren’t working on transfer pricing regulations that cover the pricing of guarantees in cross-border financing arrangements, a Treasury official said Friday in sharing the government’s current thinking.

  • December 14, 2018

    Texas Judge Strikes Down Entire ACA

    In a shocking decision, a Texas federal judge ruled late Friday that the entire Affordable Care Act must be invalidated because its individual mandate, a cornerstone of the landmark law, will soon become unconstitutional.

  • December 14, 2018

    Income Brought Home By Repatriation A Priority For IRS

    Taxpayers can prioritize income brought home through the deemed repatriation for accounting purposes, according to IRS guidance released Friday addressing how to organize overseas profits while calculating deductions and foreign tax credits under the 2017 federal tax overhaul.

  • December 14, 2018

    Biz Owner Siphoned Funds In $2.8M Tax Row, 11th Circ. Finds

    The president and sole shareholder of a construction company fraudulently transferred more than $650,000 to herself while shirking $2.8 million in tax liabilities, the Eleventh Circuit found Thursday.

  • December 14, 2018

    Bid To Dismiss State Immunity Row Is In Vain, Justices Told

    The California tax agency said Friday that a computer chip inventor’s attempt to persuade U.S. Supreme Court justices to dismiss its fight against claims of wrongdoing in Nevada was too late and misleading.

  • December 14, 2018

    GOP Govs. Ask Congress To Kill Health Premium, Device Taxes

    Republican governors from 12 states have asked outgoing House Speaker Paul Ryan and Senate Majority Leader Mitch McConnell to cut health care taxes on insurance premiums and medical devices, claiming they have hurt the economy and held down wages.

  • December 14, 2018

    Pa.'s Challenge To Birth Control Rules Cleared To Proceed

    A Pennsylvania federal judge has given the state the go-ahead to seek a second injunction against Trump administration rules that weaken the Affordable Care Act’s birth control mandate, lifting a stay in the case Friday.

  • December 14, 2018

    Mileage Rates For Work, Moving Expenses Issued By IRS

    The standard mileage rates for taxpayers to assist in determining the deductible costs of operating an automobile for business, charitable, medical or moving expense purposes for 2019 were issued by the Internal Revenue Service on Friday.

  • December 14, 2018

    Employer Can Disclose Tax Return Information To Employees

    The Internal Revenue Service released email advice Friday saying an employer was authorized to disclose return information to its employees. 

  • December 14, 2018

    Parent Co. Gets Extra Time For Asset Acquisition Election

    The Internal Revenue Service released a private letter ruling Friday granting a parent company extra time to make an election that would allow one of its subsidiaries’ purchases to be considered an asset acquisition. 

  • December 14, 2018

    Foundation Allowed To Provide Journalism Fellowship Grants

    The Internal Revenue Service released a letter ruling Friday granting approval to a private nonprofit foundation to award tax-free educational grants as part of a 12-month fellowship to postgraduates seeking to advance their careers in journalism.

  • December 14, 2018

    Foundation Allowed To Provide Pharmacist Education Grants

    The Internal Revenue Service released a letter ruling Friday granting approval to a private nonprofit foundation to award tax-free educational grants to support certain pharmacists and researchers.

  • December 14, 2018

    Education Org. Told Grant Not Unusual For Tax Purposes

    The Internal Revenue Service released a letter ruling rejecting an advance approval request that a potential grant to a nonprofit educational organization be deemed an unusual grant for tax purposes.

  • December 14, 2018

    Foundation Allowed To Provide Higher Education Scholarships

    The Internal Revenue Service released a letter ruling Friday granting approval to a private nonprofit foundation to award tax-free scholarship grants for charter high school students to pursue higher education.

  • December 14, 2018

    2nd Circ. Overturns Couple's Tax Deficiencies

    The Second Circuit on Friday reversed a U.S. Tax Court judgment against a couple for income tax liabilities, saying that the court had wrongly recharacterized certain payments as taxable dividends.

  • December 14, 2018

    LLC Gets More Time To Apply For Inventory Accounting Method

    The Internal Revenue Service released a private letter ruling Friday granting a limited liability company extra time to elect to apply to use a last-in, first-out method to account for certain inventory items. 

Featured Stories

  • 5 Top Federal Tax Decisions of 2018

    No Photo Available

    Federal courts in 2018 denied Facebook a right to IRS appeals in a $7 billion tax dispute, convicted Donald Trump’s former campaign chairman and said a California family had to pay taxes on retirement account contributions routed through Bermuda. Here, Law360 takes a look back at some of the biggest tax decisions by federal courts in the past year.

  • Blockchain Threatens To Smash Tax System Into Pieces

    Alex M. Parker

    Blockchain and similar distributed accounting technologies could be at the verge of revolutionizing and decentralizing user-supported services, transforming the tax landscape and potentially giving tax administrations a serious headache.

  • 2018 International Tax Policy: Year In Review

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    The U.S. Department of Treasury has spent the past year attempting to interpret the federal tax overhaul’s complex international measures while a global debate over how to tax digital revenue simmered overseas. Here is a look back at six major tax policy developments in the U.S. and around the world.

Expert Analysis

  • The Good News For Nonprofits On Transit Benefit Compliance

    George Constantine

    Nonprofit organizations struggling to comply with a new tax on parking and public transit benefits for their employees received three pieces of somewhat good news on Dec. 10. Attorneys at Venable LLP provide the details.

  • CFCs Hope For Only Intercompany Debt Per Section 163 Regs

    Lindsey Goble

    The IRS' Section 163(j) proposed regulations set out a complex process for determining the deductibility of an applicable controlled foreign corporation business interest expense. However, CFCs that have only intercompany debt can elect out of a Section 163(j) limitation, say Lewis Greenwald and Lindsey Goble of DLA Piper.

  • Lessons In Keeping Accountant-Client Emails Privileged

    Mark Leeds

    In U.S. v. Adams, the taxpayer successfully asserted that attorney-client privilege extended to emails with his accountant, but failed to protect underlying documents due to muddy practices. Attorneys at Mayer Brown LLP distill the court’s decision and provide unclouded strategies for keeping communications with accountants away from government scrutiny.

  • A Look At New IRS Guidance For Discounting Unpaid Losses

    Kristan Rizzolo

    The IRS recently proposed regulations for discounting unpaid losses under Internal Revenue Code Section 846. This necessary guidance, affecting both long- and short-tail insurers, removes obsolete regulations following the Tax Cuts and Jobs Act, say Kristan Rizzolo and Graham Greene of Eversheds Sutherland LLP.

  • Few Taxpayers Should Use New Offshore Disclosure Protocol

    Patrick McCormick

    Last month, the IRS updated its voluntary disclosure practices. For taxpayers without criminal exposure, the updated protocol can provide the optimal route for an offshore disclosure, but more palatable options likely exist for the significant majority of noncompliant taxpayers, says Patrick McCormick of Drucker & Scaccetti.

  • Reading Tea Leaves: The Oral Argument In Dawson V. Steager

    Edward Zelinsky

    Comments during oral argument in Dawson v. Steager suggest the U.S. Supreme Court will strike as discriminatory a West Virginia statute that taxes pensions of federal retirees. The question is how broadly the justices will apply the doctrine of intergovernmental tax immunity, says Cardozo School of Law professor Edward Zelinsky.

  • How To Help Realize A Tax Equity Market For Carbon Capture

    Hunter Johnston

    In February, Congress amended Internal Revenue Code Section 45Q, creating a tax equity market that supports investment in carbon capture and storage projects. Additional guidance, like that proposed by the Carbon Capture Coalition, is needed in a number of key subject areas to unlock this market, says Hunter Johnston of Steptoe & Johnson LLP.

  • Key Choices For Investors Under New Partnership Audit Rules

    Brad Wagner

    For 2018 returns, partnership tax audit adjustments will be assessed at the partnership — not the partner — level, causing a potentially inequitable result in the typical foreign blocker structure. The IRS has issued favorable, albeit complex, regulations to address this scenario, says Brad Wagner of Wagner Duys & Wood LLP.

  • Nonprofits And Volunteers: Understanding The Risks

    Ryan Portugal

    Nonprofit organizations commonly rely on volunteers to help achieve their mission. But circumstances in which volunteers can be treated as employees for purposes of tax, employment or negligence laws can have costly ramifications, says Ryan Portugal of Williams Parker Harrison Dietz & Getzen.

  • Shifting Federal Policies Sow Discord In US Real Estate

    Eric Rapkin

    Changes in tariffs, tax law and bank deregulation present a confusing picture of short-term gains and long-term risk for real estate. Eric Rapkin of Akerman LLP takes a look at the industry's "winners" and "losers" following these developments.