Federal
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May 09, 2024
IRS Lien Against Woman Properly Sustained, Tax Court Says
The U.S. Tax Court found Thursday that an Internal Revenue Service agent didn't abuse her discretion when sustaining a federal lien against a Texas anesthesiologist who repeatedly failed to address issues flagged by the agent.
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May 09, 2024
House Bill Would Increase Penalties For Tax Info Disclosure
House Ways and Means Committee Chairman Jason Smith introduced legislation co-sponsored by all the panel's Republican members to boost penalties for unauthorized releases of taxpayer data, according to a statement Thursday.
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May 09, 2024
IRS Details Process For Suspending Tax Pro File Numbers
The IRS described a process Thursday for suspending authorization file numbers assigned to tax professionals pending further review because of possible identity theft or other fraud and said in a statement that the risks potentially compromised numbers pose for tax pros and taxpayers are a growing concern.
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May 09, 2024
Mich. Doctor Ordered To Stay In Jail Until Assets Repatriated
A Michigan doctor fighting accusations that he failed to report his foreign bank accounts will stay in jail, as a federal court declined to release him Thursday when he didn't comply with an order to deposit over $1 million to cover the judgment against him.
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May 09, 2024
Tax Interest Rates To Stay Same In 3rd Quarter
The Internal Revenue Service's interest rates for overpayments and underpayments of tax won't change in the third quarter of 2024, the agency said Thursday.
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May 09, 2024
Plumbing Co. Owner Cops To Tax Scheme Tied To Gold Bars
The co-owner of a Boston plumbing supply company pled guilty Thursday to underreporting his business and personal income, after prosecutors said he plowed some of the unreported receipts into $10 million worth of gold and silver bars.
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May 09, 2024
Treasury's Energy Tax Credit Regs Leave Room For 'Chaining'
The U.S. Department of the Treasury has said it is prohibiting the practice known as chaining that links two new ways to monetize clean energy tax credits, but recent final rules governing the two methods left the door open to possible exceptions.
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May 09, 2024
Biden Taps Housing Atty, 2 More For Tax Court
President Joe Biden nominated three attorneys Thursday to serve as judges on the U.S. Tax Court, including a housing attorney who specializes in federal low-income housing tax credits, a legislative counsel for the Joint Committee on Taxation and an IRS attorney.
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May 09, 2024
Pension Plans Want Witness Stopped In $2B Danish Dispute
U.S. pension plans accused by Denmark's tax authority of committing $2.1 billion in fraud against the European country by taking illegal refunds on dividends asked a New York federal court to reject the authority's request to depose a witness who pled guilty in Denmark.
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May 09, 2024
IRS Turning to Final PFIC Rules This Year, Official Says
The Internal Revenue Service expects to "begin in earnest" this year on final regulations for partnerships that hold stock in passive foreign investment companies, including guidance that would treat partnerships as an aggregate of their partners, an agency official said Thursday.
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May 09, 2024
Chamberlain Hrdlicka Rehires Tax Atty From Atlanta Boutique
Chamberlain Hrdlicka White Williams & Aughtry PC has rehired one of its former tax attorneys, who joins the firm in Atlanta after working at a tax law-focused boutique, the firm announced Wednesday.
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May 09, 2024
IRS Publishes Inflation-Adjusted HSA Amounts
The Internal Revenue Service issued the inflation-adjusted amounts Thursday for health savings accounts for 2025 as well as the maximum amount that may be made available for excepted benefit health reimbursement arrangements.
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May 08, 2024
Fla. Man Owes $2.3M Tax For Late Mother's Estate, US Says
A Florida man spent millions of dollars on mortgage payments on his and his family members' properties using funds from his late mother's estate instead of paying the more than $2.3 million in taxes that the estate owed, the government said in its bid for an early win.
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May 08, 2024
Bill To Undo SEC Crypto Accounting Bulletin Passes House
Lawmakers in the U.S. House of Representatives on Wednesday voted to overturn the U.S. Securities and Exchange Commission's controversial cryptocurrency accounting guidance despite protests from Democrats to take a more targeted approach to amend the directive and a White House pledge to veto the bill.
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May 08, 2024
IRS May Float Disguised Sale Partnership Rules, Official Says
The Internal Revenue Service is considering "re-proposing" regulations that it withdrew in 2019 regarding the disguised sale of property to or by a partnership, an agency official said Wednesday.
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May 08, 2024
Top House Tax Writer Pushing Schumer For Tax Bill Vote
House Ways and Means Committee Chairman Jason Smith has urged Senate Majority Leader Chuck Schumer to bring up the tax bill passed by the House in January, Smith said Wednesday, adding that the delay is jeopardizing the proposal's support.
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May 08, 2024
TCJA Extension Would Cost $4.6T, CBO Report Says
Extending the provisions of the Tax Cuts and Jobs Act for 10 years under a proposal from Republicans would increase the U.S. deficit by $4.6 trillion, according to a report issued Wednesday by the Congressional Budget Office after a request from Democratic senators.
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May 08, 2024
DOJ Says Man Owes $6.2M After Failing To Report Foreign Biz
A man owes tax penalties of $6.2 million to the U.S. after failing to disclose his ownership interests in two foreign entities from 1997 to 2004, the government told a California federal court Wednesday.
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May 08, 2024
Biz Groups Tell 10th Circ. Economic Substance Doesn't Apply
The economic substance doctrine doesn't apply when a business considers tax in making a choice between two legally permissible alternatives, two organizations told the Tenth Circuit in their briefs supporting Liberty Global's position in its $109 million tax refund bid.
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May 08, 2024
4th Circ. Asks If High Court Ruling Bars Credit Suisse Tipster
A Fourth Circuit panel questioned Wednesday whether a U.S. Supreme Court ruling prevented it from reviving a whistleblower case by a former Credit Suisse employee alleging the bank helped U.S. citizens evade taxes after paying a $2.6 billion criminal penalty.
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May 08, 2024
Auto Cos. Brace For EV Battery Compliance Hurdles
New federal regulations aimed at shoring up the domestic electric vehicle manufacturing supply chain give automakers a much-needed two-year cushion to navigate a compliance minefield, and to figure out how to reinvigorate the recent waning consumer demand for electric vehicles.
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May 08, 2024
Minn. Man Sentenced To Prison For Role In $6.7M Fraud
A Minnesota man was sentenced in federal court to 108 months in prison and told to pay more than $4.7 million in restitution for running a scheme that led to the filing of false tax returns that caused roughly $6.7 million in tax losses, the U.S. Department of Justice said.
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May 08, 2024
Ambulance Co.'s Former Owner Gets 6 Years For Tax Evasion
The former owner of an ambulance company was sentenced to more than six years in federal prison for failing to pay employment taxes to the federal government and obstructing the Internal Revenue Service as it tried to collect, according to Virginia federal court documents.
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May 08, 2024
A Foley Hoag Co-Chair Joins Litigation Firm As Name Partner
Litigation and dispute resolution firm Elliott Kwok Levine & Jaroslaw LLP will operate under a new name after welcoming as its newest name partner a former federal prosecutor who most recently co-chaired Foley Hoag LLP's white-collar crime and government investigations practice.
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May 08, 2024
DOD Trucking Contractor Owner Indicted On $1M Tax Evasion
The owner of a trucking company that hauled military supplies for the U.S. Department of Defense tried to evade more than $1 million in taxes partly by using a nominee company headed by her former dispatcher, according to an indictment by a federal grand jury in Ohio.
Expert Analysis
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How Cities Can Tackle Post-Pandemic Budgeting Dilemmas
Due to increasing office vacancies around the country, cities may consider politically unpopular actions to avoid bankruptcy, but they could also look to the capital markets to ride out the current real estate crisis and achieve debt service savings to help balance their budgets, say attorneys at Cadwalader.
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Guidance Adds Clarity To Energy Communities Bonus Credits
Recent IRS guidance on the Inflation Reduction Act's changes to tax credits for renewable energy projects offers much-needed pointers for developers and financing parties, and should allow them to more comfortably incorporate special bonus credits for projects in energy communities into their transactions, say Jorge Medina and Ira Aghai at Shearman.
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Taxing The Digital Economy: The Good, The Bad And The Ugly
U.S. tech companies should watch for important developments in international taxation, including the resolution of Apple's decade-old state aid case, growing frustration with the Organization for Economic Cooperation and Development's global tax plan and adoption of the digital services tax instead, says Joyce Beebe at Rice University's Baker Institute for Public Policy.
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Big Tax Changes For Multinational Cos. In Budget Proposal
The Biden administration’s fiscal year 2024 budget proposes changes that would materially alter decades-old Internal Revenue Code provisions, requiring a shift in multinational corporations' tax planning strategies comparable to that required after enactment of the Tax Cuts and Jobs Act, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.
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SVB Collapse Reinvigorates Bank Accounting Debate
Silicon Valley Bank's sudden collapse revives questions over whether fair value or amortized cost accounting is the most appropriate for banks' financial reporting — a controversy that's crucial for understanding what information could have helped market participants better understand SVB's financial condition, say consultants at Analysis Group.
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Brownfield Renewables Guidance Leaves Site Eligibility Murky
Recent IRS guidance sheds some light on the Inflation Reduction Act's incentives for renewable energy development on contaminated sites — but the eligibility of certain sites for brownfield status remains uncertain, say Megan Caldwell and Jon Micah Goeller at Husch Blackwell.
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Get Ready For IRS Criminal Crackdown On Crypto
Recent developments at the IRS, from a new operating plan to the announcement of a centralized data center, signal that the agency is ramping up criminal enforcement against those using digital assets to evade tax liabilities — and given its high conviction rate, companies and individuals must prioritize compliance, say attorneys at BakerHostetler.
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NFT Tax Guidance Shows IRS Interest In Crypto Enforcement
The IRS' first ever guidance addressing the federal income tax treatment of NFTs indicates the agency could take a potentially aggressive stance in enforcing U.S. tax laws in the NFT and crypto spaces, which could have a significant impact on the self-directed IRA market, say attorneys at BakerHostetler.
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Substantiation Is Key When Gifting Crypto To Charity
A recent Internal Revenue Service memorandum makes clear that the agency will require substantiation when gifting cryptocurrency to charity, even for relatively small amounts, so donors need to be aware of the important differences between crypto and typical cash donations, says Sheryl Morrison at Lathrop GPM.
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Senate Credit Suisse Report Puts Attention On Banks, Trusts
The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.
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Seeking IRS Accountability For Faulty Microcaptive Notice
Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.
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Biden Admin. Proposals Both Encourage And Thwart EV Adoption
While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.
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Heed PCAOB's Warning On Proof-Of-Reserves Reports
While directed at investors, the Public Company Accounting Oversight Board's recent advisory on proof-of-reserves reports is a timely and stark warning to crypto entities, as well as their customers and accounting firms, to tread carefully in their reliance on these reports as proof of financial stability, say Patrick Bryan and Deborah Meshulam at DLA Piper.