Federal

  • December 05, 2021

    Prince's Estate, IRS Settle Valuation Dispute In Tax Court

    The estate of the pop star Prince has settled its valuation dispute with the Internal Revenue Service, according to an order in the U.S. Tax Court.

  • December 03, 2021

    JPMorgan Beats 'Frivolous' Suit Claiming Trust Fraud

    A federal judge has tossed a Florida man's suit accusing JPMorgan Chase and an Ohio law firm of fraudulent trust administration and defrauding the court, and ordered him and his attorney to cover the defendants' attorney fees and costs as a sanction for filing the "frivolous" suit.

  • December 03, 2021

    CPA Tied To Russian Gas Co. Faces More Tax Charges

    A Florida accountant has been hit with additional federal tax evasion charges in a criminal case accusing him of hiding $93 million overseas that he earned through ties to a Russian gas company.

  • December 03, 2021

    Man's $832K Tax Debt Still Collectible, 3rd Circ. Told

    A Pennsylvania federal court rightly concluded that a man's litigation broadened the window for the U.S. government to pursue nearly $833,000 in tax liabilities he owed for 1986 through 1991, the government told the Third Circuit on Friday.

  • December 03, 2021

    NJ Man's Income Tax Liability Affirmed By 3rd Circ.

    A New Jersey man is still on the hook for more than $187,700 in income tax liabilities after the Third Circuit affirmed a district court decision imposing the liabilities because he failed to prove the assessments were erroneous.

  • December 03, 2021

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin, which included a ruling saying applicable federal rates for income tax purposes rose in December.

  • December 03, 2021

    Taxation With Representation: Skadden, Latham

    In this week's Taxation With Representation, insurance broker Arthur J. Gallagher & Co. will acquire the reinsurance broking arm of rival Willis Towers Watson, industrial 3D printing business Essentium will go public with blank-check company Atlantic Coastal, and Distributed energy firm Voltus will go public by merging with special purpose acquisition vehicle Broadscale Acquisition Corp.

  • December 02, 2021

    IRS' Math Correct In Vineyard Owner's FBAR Row, Court Told

    A California federal court should affirm the Internal Revenue Service's calculation of roughly $440,000 in foreign bank account reporting penalties against a vineyard owner, the U.S. government said, arguing the computation was based on the law and agency procedures.

  • December 02, 2021

    Biz Groups Urge Justices To Hear NJ Partnership Fee Row

    A host of business advocacy organizations urged the U.S. Supreme Court on Thursday to hear a partnership's challenge to New Jersey's partnership-filing fees, arguing that the per-partner levies are unconstitutional because they aren't apportioned.

  • December 02, 2021

    $824K FBAR Judgment Satisfied, US Tells Court

    A New Hampshire woman who failed to report foreign bank and financial accounts satisfied an $824,000 judgment against her, the U.S. government told a federal court.  

  • December 02, 2021

    TIGTA Says IRS Program Not Comprehensively Managed

    The Internal Revenue Service's implementation of part of its modernization program lacked a comprehensive management structure, the Treasury Inspector General for Tax Administration said in a report released Thursday.

  • December 02, 2021

    14 GOP Sens. Press IRS On ProPublica Taxpayer Data Leak

    The Republican members of the Senate Finance Committee are pressing Internal Revenue Service Commissioner Chuck Rettig for answers on whether the agency was the source of taxpayer data leaked to news organization ProPublica.

  • December 02, 2021

    Congress Clears Stopgap Funding Bill For Treasury, IRS

    Congress approved a short-term government funding bill Thursday that would keep the U.S. Department of the Treasury, the Internal Revenue Service and other federal agencies open through Feb. 18.

  • December 02, 2021

    10th Circ. Axes Appeal Of $50M Judgment In Solar Tax Scheme

    A man can't escape a $50 million disgorgement judgment related to his company's abusive tax scheme, the Tenth Circuit affirmed Thursday, saying an expert's testimony in U.S. Tax Court wasn't sufficiently at odds with the same expert's district court testimony.

  • December 02, 2021

    Tax Court Says NY Man Can't Claim Grandkids As Dependents

    A New Yorker owes a $6,453 tax deficiency because his grandchildren aren't his dependents, since they also lived with their mother and she also claimed them, the U.S. Tax Court said Thursday.

  • December 02, 2021

    V&E Elects 13 New Partners In US, UK

    Vinson & Elkins LLP will start the new year with 13 new partners, announcing Wednesday that it had promoted 13 attorneys across eight practice areas in the U.S. and the U.K.

  • December 02, 2021

    Ex-DOJ Atty Wrongly Denied IRS Court Costs, 9th Circ. Told

    The Ninth Circuit should undo a U.S. Tax Court decision that denied a former U.S. Department of Justice attorney $31,600 in litigation costs after he successfully challenged an IRS tax bill, a taxpayer group told the appeals court.

  • December 02, 2021

    IRS Won't Follow 8th Circ.'s Nix Of Education Requirement

    The Internal Revenue Service won't follow the Eighth Circuit's decision to invalidate a requirement that educational organizations have formal instruction as a prime function for the purposes of a tax exemption, the agency said in an action on decision.

  • December 01, 2021

    No Tax Court Redo For Coke In $3.3B Transfer Pricing Row

    Coca-Cola can't challenge its loss in a $3.3 billion transfer pricing dispute with the IRS after the U.S. Tax Court found the company filed its reconsideration bid far past the typical deadline, counsel for the company confirmed Wednesday.

  • December 01, 2021

    Rettig Hopes To Hire 25,000 IRS Workers In 18 Months

    The Internal Revenue Service could add 25,000 positions in the next 18 months if Congress comes through with the money needed to expand the workforce, Commissioner Chuck Rettig said Wednesday.

  • December 01, 2021

    Yellen Sticks By $400B IRS Enforcement Revenue Estimate

    Treasury Secretary Janet Yellen said Wednesday that President Joe Biden's $1.75 trillion domestic agenda would raise more tax revenue from new IRS audits than a CBO estimate, countering criticism from Republican lawmakers who predict higher budget deficits and inflation. 

  • December 01, 2021

    House Subcommittee To Discuss Hidden Wealth

    The House Ways and Means Oversight Subcommittee will hold a meeting on the subject of hidden wealth next week, the subcommittee chairman said Wednesday.

  • December 01, 2021

    US Asks Court To Sell Properties To Cover $1.1M FBAR Fine

    A New York federal court should sell a man's properties to cover more than $1.1 million in penalties for failing to report foreign bank accounts that it found him liable for more than a year ago, the U.S. government said Wednesday.

  • December 01, 2021

    IRS Releases Guidance On Low-Income Housing Credit Floor

    The Internal Revenue Service offered guidance Wednesday regarding whether a 4% floor related to the low-income housing credit applied to low-income buildings in three scenarios.

  • December 01, 2021

    Tax Court Affirms NY Couple's $800K Tax And Penalty Bill

    The U.S. Tax Court on Wednesday affirmed nearly $800,000 in taxes and penalties on a New York couple, saying their tax return and agreements to extend assessment deadlines were valid even though they were signed by representatives.

Featured Stories

  • Dems Face Intraparty Fight Over Tax Incentive Cutoffs

    Alan K. Ota

    As congressional Democrats try to cut a bicameral deal on the House-passed reconciliation bill containing President Joe Biden's domestic agenda, they face intraparty disputes over potential restrictions on the child tax credit and other individual tax incentives.

  • 7 Things Tax Pros Are Grateful For This Thanksgiving Season

    Amy Lee Rosen

    From the continued extension of federal and state tax deadlines because of the pandemic to clarification on forgiven Paycheck Protection Program loans and the agreement on a global corporate tax overhaul, tax attorneys are grateful for many things this Thanksgiving. Here, Law360 reviews seven developments tax professionals are thankful for this year.

  • Corp. AMT Plan May Blur Line Between Tax, Financial Data

    Natalie Olivo

    A proposed alternative minimum tax based on financial statements has sparked concerns among accounting experts, who worry that blending two separate systems for measuring corporate income could undermine the underlying — and intentionally different — purposes of each one.

Expert Analysis

  • Navigating CARES Act Social Security Tax Deferral Payments

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    Attorneys at Morgan Lewis examine Internal Revenue Service guidance on payment of employer-share social security tax deferrals due Jan. 3 under the Coronavirus Aid Relief and Economic Security Act, and offer tips for avoiding costly underpayment and late deposit penalties.

  • Tech Improvements That Can Help Gov't Tackle FOIA Backlog

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    Government agencies can implement effective technological solutions that will help them address the growing backlog of Freedom of Information Act requests, and avoid costly noncompliance litigation, by taking steps to identify agency-specific needs, develop cohesive strategies and obtain leadership buy-in, say Ken Koch and Erica Spector at KPMG.

  • IRS Memo Helps Clarify Research Credit Filing Requirements

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    A recently published Internal Revenue Service chief counsel memorandum offers long-awaited guidance about information requirements for taxpayers seeking research credit refunds and provides helpful notice of the agency’s litigating position where credits are denied, say Deborah Roth and Brian Coddington at Source Advisors.

  • Questions To Ask If Doing Business In A Corruption Hot Spot

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    Businesses facing new scrutiny after the U.S. Department of Justice's recently announced task force for combating human trafficking in Central America, the release of the Pandora Papers and continuing fallout from 2019's Panama Papers, should address compliance risks by having employees ask three questions about every transaction, say attorneys at White & Case.

  • New DOJ Corporate Crime Approach May Deter Self-Reporting

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    Deputy U.S. Attorney General Lisa Monaco's recent unveiling of a tougher white collar enforcement approach at the U.S. Department of Justice — focusing on corporate recidivism and compliance monitors — could result in companies being less willing to self-report wrongdoing or enter into resolutions with the government, say attorneys at Morgan Lewis.

  • Infrastructure Bill May Limit Cryptocurrency Loss Deductions

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    If enacted, provisions in ​President Joe Biden's ​​infrastructure bill would broaden a rule meant to prevent the harvesting of tax losses​, causing every cryptocurrency investor ​who wants to deduct a loss to consider whether it is worth cashing out to fiat currency and waiting 30 days before reinvesting to take a loss deduction, says Andrew Leahey at Hunter Creek Consulting.

  • The Infrastructure Bill Should Not Target Cryptocurrency

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    Congress should excise a provision in the pending infrastructure bill that would require anyone who accepts $10,000 in cryptocurrency for goods or services to report the transferring party's personal information to the Internal Revenue Service — this would be unnecessary, ill-advised and possibly unconstitutional, says James Burnham at Jones Day.

  • Opportunity Zone Regulations Require More Fine Tuning

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    Problems with the latest revisions to the qualified opportunity zone investment rules reinforce a recurring theme of regulatory hiccups that may prevent investors and communities from actualizing the program's potential benefits, unless we have more guidance, says Mitchell Goldberg at Berger Singerman.

  • Preserving Disgorgement Tax Deductibility In SEC Settlements

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    The U.S. Securities and Exchange Commission recently added language to its enforcement orders that could affect a settling party's ability to deduct certain disgorgement payments, but proper planning can help them satisfy Internal Revenue Service prerequisites, say attorneys at Sidley.

  • How The Global Tax Agreement Could Backfire For Biden

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    If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.

  • Tax-Exempt Orgs, Beware This 403(b) Plan Compliance Pitfall

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    A recent Internal Revenue Service publication puts 403(b) retirement plan sponsors on notice about a contribution aggregation compliance failure often identified in audits of government and tax-exempt entities, but risk can be minimized by ensuring plan documents and communications address the issue directly, say Greg Needles and Michael Gorman at Morgan Lewis.

  • Pandora Papers Reveal Need For Greater Tax Enforcement

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    The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.

  • Telehealth Providers Must Beware Of Fraud As Industry Grows

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    A recent fraud charge against a telehealth executive highlights the rise we're seeing in telefraud scams during the industry's pandemic growth, and there are some steps that all health providers should take to stay clear of potentially illegal arrangements, says LaTawnda Moore at Dinsmore.