Federal
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March 21, 2024
GOP Sens. Push Yellen To Commit To TCJA Extension
Senate Finance Committee Republicans on Thursday pushed Treasury Secretary Janet Yellen to commit to extending provisions in the Tax Cuts and Jobs Act, including the law's child tax credit expansion and the corporate and individual tax cuts.
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March 21, 2024
Man Faces Penalty After Debating Job Status, Tax Court Says
A Georgia man is responsible for a frivolous filing tax penalty after questioning his employment status, the U.S. Tax Court affirmed Thursday.
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March 21, 2024
UN Could Enhance Global Tax Agenda Setting, Officials Say
The United Nations could play an important role in shaping the agenda for global tax negotiations so it better reflects the priorities and concerns of developing countries, a variety of tax officials said Thursday during a conference.
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March 21, 2024
7th Circ. Won't Let Admitted Fraudster Ditch $1.3M Restitution
A woman who admitted to wire fraud in connection with a three-person scheme to file hundreds of false tax returns owes $1.3 million in restitution to the government, the Seventh Circuit ruled Thursday, rejecting the woman's claim that the amount was miscalculated.
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March 21, 2024
IRS Proposes Exceptions For 3rd-Party Summons Notices
The IRS proposed rules Thursday that would allow some exceptions to a requirement that the agency notify taxpayers within 45 days before issuing summonses to third parties in tax assessment and collection cases, including for certain time-sensitive examinations.
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March 21, 2024
Wyden Probes Swiss Bank's Ties To Billionaire Under Scrutiny
The Senate Finance Committee's Democratic majority launched an inquiry into Swiss bank Pictet Group's involvement with a U.S. billionaire under criminal investigation, raising questions about the bank's deferred prosecution agreement and $123 million fine by the U.S. Justice Department, committee Chairman Ron Wyden announced Thursday.
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March 21, 2024
Quintairos Prieto Taps Atlanta Atty To Lead New Tax Group
Quintairos Prieto Wood & Boyer PA said it had created a tax division that will be led by an Atlanta-based partner who has guided clients on civil and criminal tax law, reinforcing its national expertise in litigation, regulatory and corporate law matters.
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March 21, 2024
H&R Block Challenges FTC Judges In False Ad Battle
H&R Block asked a Missouri federal court to stop administrative law judges from overseeing a Federal Trade Commission proceeding that accuses the tax preparation company of deceptive advertising, claiming the judges have job protections that unconstitutionally shield them from presidential oversight.
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March 21, 2024
Senate Bill Seeks To End Tax-Free Merger Treatment
A bill introduced Thursday in the U.S. Senate would end manipulation of the Internal Revenue Code that allows certain corporate mergers to be tax-free.
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March 21, 2024
IRS Tweaks Proposed Partnership Treatment Rules
The Internal Revenue Service issued a correction notice Thursday fixing a reference in proposed regulations about the treatment of related people within partnerships.
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March 21, 2024
IRS Issues Fixes In Safe Harbor Regulations
The Internal Revenue Service issued two correction notices Thursday to amend final regulations focused on certain safe harbor exceptions.
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March 20, 2024
Endo Plan To Trim $5B In Debt Confirmed By NY Judge
Drugmaker Endo International got a New York bankruptcy judge's approval for its Chapter 11 plan that aims to cut more than $5 billion in debt and hand over ownership to its lenders, roughly a month after it finalized a $465 million deal to resolve criminal and civil opioid claims.
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March 20, 2024
Wyden Bill Would Target Abuse Of Annuity Trusts
A bill introduced Wednesday by the Senate Finance Committee chairman, Sen. Ron Wyden, D-Ore., would attempt to limit the abuse of a type of annuity trusts by the wealthy, in part by imposing a requirement that the instruments have a minimum term of at least 15 years.
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March 20, 2024
IRS Releases Foreign Housing Expense Limits For 2024
The Internal Revenue Service released adjustments to the limitation on foreign housing expense deductions and exclusions for 2024 on Wednesday.
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March 20, 2024
IRS Asks Justices To Scrap Couple's Late-Filed Tax Court Suit
The IRS asked the U.S. Supreme Court to consider reversing the Third Circuit's revival of a couple's challenge to their tax bill, saying the appeals court incorrectly concluded that a 90-day deadline for petitioning the U.S. Tax Court need not always be met.
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March 20, 2024
RI Ex-Broker Gets 8 Years In Ponzi Scheme
A Rhode Island man was sentenced to eight years in prison for running a decade-long Ponzi scheme to defraud investors and to evade his taxes.
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March 20, 2024
How The Supreme Court Could Narrow Chevron
After hours of oral argument in a closely watched administrative law case, it appeared that some U.S. Supreme Court justices could be open to limiting the opportunities for lower courts to defer to federal agencies' legal interpretations in disputes over rulemaking — and legal experts said there are a number of ways they could do it.
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March 20, 2024
IRS Withholding Docs On Partnership Audits, Baker Atty Says
The Internal Revenue Service has not responded to a request for documents pertaining to the agency's scrutiny of large partnerships and should be forced to disclose them, an attorney with Baker McKenzie told a D.C. federal court.
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March 20, 2024
IRS Grants Income Exclusion To Those Fleeing 6 Countries
Individuals who fled conditions in Ukraine, Belarus, Sudan, Haiti, Niger and Iraq after specific dates in 2023 can exclude foreign earned income, and can exclude or deduct housing costs, from gross income that year because of adverse conditions in the countries, the IRS said.
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March 20, 2024
Law360 Announces The Members Of Its 2024 Editorial Boards
Law360 is pleased to announce the formation of its 2024 Editorial Advisory Boards.
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March 20, 2024
King & Spalding Adds Ex-PwC Tax Pro As Partner In NY
An experienced tax attorney has joined King & Spalding LLP in New York after working at PricewaterhouseCoopers LLP for six years.
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March 19, 2024
US Climate Law's Clean Energy Credit Requests Reach 45K
About 500 entities have requested registration numbers for more than 45,500 projects that aim to use the Inflation Reduction Act's clean energy tax credits, the Internal Revenue Service and U.S. Department of the Treasury said Tuesday.
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March 19, 2024
ABA Tax Section Seeks Revised Donor-Advised Fund Rules
The U.S. Treasury Department should revise excise tax rules for certain distributions from donor-advised funds in a manner that is consistent with regulations governing similar funds and that doesn't duplicate existing tax penalties, the American Bar Association Tax Section said.
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March 19, 2024
Staffing Co. Owner Gets 4 Years For Hiring Untaxed Labor
The owner of a staffing company in Key West, Florida, that hired untaxed and unauthorized workers was sentenced by a Florida federal judge to four years in prison and ordered to pay $3.5 million in restitution to the U.S. government, according to court documents.
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March 19, 2024
GILTI Figures Into CFC Applicability Project, Official Says
The U.S. global intangible low-taxed income system is factoring into continuing Internal Revenue Service work on whether a tax code provision limiting corporations from offsetting income with net operating or other tax losses after ownership changes applies to controlled foreign corporations, an agency official said Tuesday.
Expert Analysis
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What IRS Funding Increase Means For Taxpayers
The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.
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6 Tax Considerations For Life Sciences Collaboration Deals
Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.
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Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess
Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.
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Post-Litigation Refund Strategies To Defeat Class Certification
The Third Circuit's recent revival of the Duncan v. Governor of the Virgin Islands class action shows that defendants should strongly consider tendering refunds to class representatives — even after they file suit — to create a substantial obstacle to certification, say attorneys at Covington.
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Key Considerations For Seeking Relief From Double Taxation
Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.
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High Court Could Resolve Thorny Atty-Client Privilege Issue
The U.S. Supreme Court recently granted review in a federal grand jury proceeding that presents a rare opportunity to clarify — and possibly significantly expand — the scope of the attorney-client privilege for complex mixed-purpose communications with counsel, says David Greenwald at Jenner & Block.
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2 Tax Decisions Hold Key Transfer Pricing Takeaways
Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.
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Patagonia's Succession Plan Is A Blueprint For Biz Owners
While not every business owner is interested in giving their company away to a charitable purpose like Patagonia's founder recently did, the outdoor apparel company's unique situation highlights the considerations that should go into any succession plan, says Abosede Odunsi at Freeborn & Peters.
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The CHIPS Act: Key Takeaways For Semiconductor Industry
The Biden administration’s recently signed CHIPS Act signals that the U.S. is making progress toward bolstering the domestic semiconductor industry, and manufacturers must prepare by understanding the requirements of the act and associated Department of Commerce guidance, say attorneys at Miller & Chevalier.
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Digital Taxation Is Necessary, But Tough To Manage
The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.
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5 Considerations When Seeking Federal EV Funding
A recent White House fact sheet shows how federal efforts to support the full scope of the electric vehicle industry have moved the needle, but some details about how to use those funds are still being ironed out, and there are a few issues to watch, say attorneys at Morgan Lewis.
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Unpacking The Inflation Reduction Act's Energy Tax Credits
Provisions in the recently enacted Inflation Reduction Act that affect how taxpayers can monetize clean energy tax credits will change how clean energy projects are financed, but taxpayers that may not be allowed multiple credits need to determine which type of credit will be the most advantageous, say attorneys at BakerHostetler.
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How COVID Has Changed Project Development And Finance
Two and a half years into the pandemic, some COVID-19-specific provisions are now common in the project development and finance markets, while others are still undergoing negotiation, say Nate Galer and Katy McNeil at Mayer Brown.