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Federal

  • August 21, 2018

    Calif. Resident Pleads Guilty To Hiding $1M In Israeli Bank

    A Los Angeles resident pled guilty to a failure to disclose more than $1 million in holdings in an Israeli bank previously found responsible for helping Americans dodge tax liabilities, and he could face prison as a result, the U.S. Justice Department said Monday.

  • August 21, 2018

    IRS Seeks Comment On Reporting Burden For Tax-Exempt Orgs

    The Internal Revenue Service on Tuesday solicited public feedback on its information collection requirements for tax-exempt organizations.

  • August 21, 2018

    IRS Urges Tax Pros To Educate All Employees On Data Security

    The Internal Revenue Service on Tuesday urged tax professionals to improve data security education for all office employees, including those who are not tax return preparers.

  • August 21, 2018

    PwC Asks For Transition Rule On Foreign Branch Income

    The U.S. Treasury Department and Internal Revenue Service should create a transition rule to allow U.S. taxpayers to carry forward certain foreign tax overpayments to offset foreign branch income under the new federal tax law, PwC wrote in a letter on behalf of DefCo Holdings Inc. released Tuesday.

  • August 21, 2018

    LLC Owners Ask 6th Circ. To Rehear IRS Privacy Law Case

    Two Michigan business owners have urged the Sixth Circuit to reconsider its decision to toss their claim that the Internal Revenue Service violated the Right to Financial Privacy Act by issuing two John Doe summonses, claiming the case is one of first impression among circuits and of importance to privacy protections.

  • August 21, 2018

    European Banks Ask US Treasury To Keep FATCA Extensions

    A federation of European banks asked the U.S. Department of the Treasury to indefinitely extend the transition period for foreign bank account reporting requirements, saying regulation changes will have unintended consequences on European securities markets, according to a letter released Tuesday.

  • August 21, 2018

    Puerto Rico Senate Approves Treasury Secretary Nominee

    In a bipartisan vote, the Puerto Rico Senate Monday approved Teresita Fuentes as Treasury secretary.

  • August 20, 2018

    Jay Peak Receiver Settles Tax Dispute With Vermont Town

    A Florida federal court has approved a settlement reached between the court-appointed receiver for the failed Jay Peak EB-5 project and the town of Jay, Vermont, on interest and penalties stemming from $2 million in property taxes paid late to the town.

  • August 20, 2018

    Tax Court Says Fees Were Disguised Profit Distributions

    The U.S. Tax Court on Monday said two types of fees originally paid as tax-exempt distributions to S corporations and C corporations that were members of a partnership were actually disguised distributions of corporate profits and taxable to the individual shareholders.

  • August 20, 2018

    Baker Hughes Appeals Denial Of $18M Tax Refund To 5th Circ.

    Texas oil company Baker Hughes Inc. will appeal a Texas federal court’s recent decision to deny it a nearly $18 million tax refund over a multimillion-dollar payment to a Russian subsidiary made by BJ Services Co. before it was acquired in 2009.

  • August 20, 2018

    Fla. Rapper Sentenced To 3 Years For $150K Tax Fraud

    A Tampa rap artist was sentenced Friday in Florida federal court to three years behind bars for running a tax refund scheme that bilked nearly $150,000 from the IRS while he was a student at Tallahassee Community College.

  • August 20, 2018

    Tribe Opposes Discovery Order Appeal In Mich. Tax Row

    The Keweenaw Bay Indian Community on Monday urged a federal district court judge to deny Michigan officials’ appeal of a magistrate judge’s discovery order in a suit over the state’s tax authority.

  • August 20, 2018

    Seminoles Urge 11th Circ. To Revive Suit Over Utilities Tax

    The Seminole Tribe of Florida pressed the Eleventh Circuit on Friday to revive its suit over a state tax on electricity the tribe uses for federally regulated activities, saying it deserves a ruling on precisely what tribal activities are and aren't covered by the tax.

  • August 20, 2018

    SEC Roundup: Cos. Predict Limited Impact From Altera Saga

    The Ninth Circuit’s recent issuance — and subsequent withdrawal — of a pro-IRS ruling in a cost-sharing suit against Altera Corp. caused quite a stir in the tax community, but according to a review of U.S. Securities and Exchange Commission filings, most companies anticipate minimal changes to their transfer pricing structures despite the court's call to reconsider the case.

  • August 20, 2018

    Virgin Islands Gov't Hit With $97M Tax Refund Class Action

    A U.S. Virgin Islands taxpayer has brought a proposed class action against the U.S. Virgin Islands government, saying it hasn’t paid nearly 20,000 income tax refunds totaling $37 million for the 2016 tax year and the government owes $97 million in refunds since 2007.

  • August 20, 2018

    US Gov’t Asks For Quick Win In $23M Recycling Tax Case

    The U.S. government has asked a Missouri federal judge to dismiss a lawsuit brought by private equity-backed recycling companies regarding a levy for the 2006 tax year, now in excess of $23 million, imposed by the Internal Revenue Service.

  • August 20, 2018

    3rd-Party Funder Gets $1.75M In IRS Tea Party Class Action

    An Ohio federal court has awarded $1.75 million in fees to a third party that funded a class action alleging the Internal Revenue Service illegally targeted Tea Party groups vying for nonprofit status that resulted in a $3.5 million settlement.

  • August 20, 2018

    Comment Sought By IRS On Fiduciary Relationship Reporting

    The Internal Revenue Service is seeking public comment on its information reporting requirements for fiduciary relationships, the agency said Monday.

  • August 20, 2018

    House Bill Offers Tax Credit To Employers For Wage Hikes

    A bill that has been introduced in the U.S. House of Representatives would provide a tax credit to employers who increase wages for their employees.

  • August 20, 2018

    IRS Seeks Comment On Reporting Fixed Investment Trusts

    The Internal Revenue Service solicited public comment Monday on its information-reporting requirements for widely held fixed investment trusts.

Featured Stories

  • SEC Roundup: Cos. Predict Limited Impact From Altera Saga

    No Photo Available

    The Ninth Circuit’s recent issuance — and subsequent withdrawal — of a pro-IRS ruling in a cost-sharing suit against Altera Corp. caused quite a stir in the tax community, but according to a review of U.S. Securities and Exchange Commission filings, most companies anticipate minimal changes to their transfer pricing structures despite the court's call to reconsider the case.

  • TCJA Transition Tax Could Hit Trusts, Blocked Income

    No Photo Available

    A quirk in how the Tax Cuts and Jobs Act’s deemed repatriation treats trusts, escrow accounts, income “blocked” by foreign laws and other forms of immobile income — which the U.S. Department of Treasury declined to address in recently released rules — could leave financial institutions and other companies across the spectrum with headaches and an unexpectedly higher tax bill.

  • 12 Books Tax Attorneys Should Read Before Summer Ends 

    Amy Lee Rosen

    As summer winds to a close, a lawyer's thoughts may wander to relaxing on the beach with a drink in hand and a good book to read to escape the taxing demands of the office. Here are 12 that should be on a tax lawyer's reading list.

Expert Analysis

  • How Section 382 Interacts With New Tax Act Provisions

    Todd Reinstein

    Although Section 382 of the Internal Revenue Code generally was left unchanged by the Tax Cuts and Jobs Act, issues have arisen regarding its application to a new provision that modifies the first-year treatment of certain deductions related to qualified property under the rules, say Todd Reinstein and Annette Ahlers at Pepper Hamilton LLP.

  • Section 45Q Tax Credit Increase May Spur Carbon Capture

    David Lowman

    The Bipartisan Budget Act of 2018 significantly increased and extended the Section 45Q tax credit for the capture and sequestration of carbon oxides. This development is expected to significantly boost deployment of carbon capture and storage across the U.S. and represents a potential opportunity for emitting companies, oil and gas companies and industrial users of carbon oxides, say David Lowman and Frederick Eames of Hunton Andrews Kurth LLP.

  • Why 25% Foreign-Owned Blocker Corps. Must File Form 5472

    Brad Wagner

    The IRS has recently become very aggressive in asserting penalties for failing to file a Form 5472 — used to identify potential tax issues with regard to transactions between a U.S. corporation and related foreign shareholder, says Brad Wagner of Wagner Duys & Wood LLLP.

  • Plan Sponsors Should Consider Pension De-Risking

    Elliot Dinkin

    For some plan sponsors, the prospect of engaging in a pension risk transfer may seem cost-prohibitive. However, the cost of transferring risk is lower than what many sponsors perceive, says Elliott Dinkin of Cowden Associates Inc. 

  • As IRS Eases Reporting, States Target Dark Money Reforms

    Amber Maltbie

    At the same time that the IRS is making it easier for nonprofits to shield their donors from inadvertent disclosure by eliminating a reporting requirement on annual tax filings, some states, such as Maine and Montana, continue to trend toward greater disclosure of donors to politically active nonprofits. It is thus imperative that nonprofits are cognizant of the complex and inconsistent rules among federal, state and local jurisdictions, say attorneys at Nossaman.

  • Long-Awaited Bonus Depreciation Insight For Partnerships

    Junaid Chida

    Earlier this month, the IRS finally released proposed regulations under the bonus depreciation provisions of the Tax Cuts and Jobs Act. The guidance provides long-awaited clarification on the availability of 100 percent bonus depreciation to partnership basis adjustments, say attorneys at O'Melveny & Myers LLP.

  • A Close Look At IRS Proposed Pass-Through Deduction Rules

    Stephen Looney

    Last week, the IRS proposed regulations under Internal Revenue Code Section 199A, providing guidance on the new deduction available to pass-through entities and sole proprietorships. Mostly taxpayer friendly, the lengthy proposed regs are likely to undergo some changes before becoming finalized, say Stephen Looney and Edward Waters of Dean Mead Egerton Bloodworth Capouano & Bozarth PA.

  • Unclear Which Way Wind Blows After Reversal Of Alta Wind

    Julie Marion

    The Federal Circuit recently reversed the U.S. Court of Federal Claims decision in Alta Wind v. United States, finding the trial court's method of valuing the wind farm properties did not accurately represent their fair market value. The decision was unclear, however, about how the lower court should determine the value on remand, leaving the renewable energy industry with a number of questions, say attorneys at Latham & Watkins LLP.

  • Retirement Provisions May Survive Doomed Tax Reform 2.0

    Lai King Laim

    On July 24, a two-page framework for “Tax Reform 2.0," a second round of tax-cut legislation, was released by the House Ways and Means Committee. One aspect of the framework, improving American's retirement savings, has bipartisan support and might make it into legislation passed by Congress before the end of 2018, says Lai King Lam of McGuireWoods Consulting LLC.

  • Controlled Foreign Corp. Restructuring For US Taxpayers

    Carl Merino

    The Tax Cuts and Jobs Act introduced a number of changes targeting U.S. companies that were intended to reduce incentives to shift earnings overseas. However, these provisions, which have had a disparate impact on U.S. citizens who own closely held companies overseas or are beneficiaries of offshore succession planning schemes, will force a re-examination of many existing structures for affected U.S. taxpayers, say Carl Merino and Dina Kapur Sanna of Day Pitney LLP.