Federal
-
April 21, 2023
US Laundering, Casino Bribery Suit Too Vague, Co. Says
The U.S. government's lawsuit claiming $310,000 from a Northern Mariana Islands business fails to tie those funds to specific criminal tax evasion or money laundering that would warrant civil asset forfeiture and should be dismissed, the business told an islands federal court Friday.
-
April 21, 2023
Crypto Mechanism Upgrade Doesn't Create Gain, Loss
A taxpayer with cryptocurrency doesn't receive a gain or loss because an upgrade to the currency's native ledger changes the consensus mechanism to validate transactions, the Internal Revenue Service's Office of Chief Counsel said in a memorandum released Friday.
-
April 21, 2023
Ga. Biz Owners Urge Congress To Extend Pass-Through Relief
Lawmakers must extend the Tax Cuts and Jobs Act's 20% deduction for qualified pass-through income to help small businesses, witnesses told the House Ways and Means Committee on Friday during a field hearing held in Peachtree City, Georgia.
-
April 21, 2023
IRS Provides Figures For Bond Interest Income Exclusions
The Internal Revenue Service has published data on the nationwide average purchase price for U.S. residences and state- and territory-specific average purchase price safe harbors, which are used to determine whether bond interest can be excluded from gross income.
-
April 21, 2023
Senate Bill Seeks Restriction For Clean Vehicle Credits
Electric vehicles would be stripped of eligibility for the clean vehicle tax credit if their manufacturer benefited from any of three past energy-related government initiatives under a bill introduced in the U.S. Senate.
-
April 21, 2023
Weekly Internal Revenue Bulletin
The Internal Revenue Service released its weekly bulletin, which included proposed rules that would revise how certain microcaptive insurance transactions are to be reported and which are deemed abusive after court decisions upended guidance the government previously relied upon.
-
April 21, 2023
3rd Circ. OKs IRS Access To Del. Microcaptive Insurance Docs
The IRS can proceed with a summons seeking microcaptive insurance records from Delaware's insurance department after the Third Circuit affirmed on Friday a lower-court ruling finding that federal law requiring the disclosure of the records trumps state law barring their release.
-
April 21, 2023
Tax Avoidance School Operators Owe $93K, 9th Circ. Says
A couple who run a business called Freedom Law School that teaches tax avoidance schemes are liable for $93,000 in taxes and penalties for failing to report their own income, the Ninth Circuit ruled, upholding a U.S. Tax Court decision.
-
April 20, 2023
9th Circ. Snuffs Out CBD Co.'s Appeal Of Tax Arbitration Order
The Ninth Circuit tossed a CBD company's challenge to a lower court order requiring it to arbitrate a co-founder's claims that the business neglected to withhold $5.2 million in taxes from stock compensation, saying the company failed to prosecute its case.
-
April 20, 2023
Engineer Wins Split Tax, Export Trials In DOD Poaching Case
A Texas federal judge granted a request from a Chinese-born engineer for separate trials on charges of export violations and tax fraud, saying the tax allegations aren't sufficiently connected to claims that he improperly took a work laptop with sensitive military information to China.
-
April 20, 2023
Squire Patton Atty Nominated To Lead Ohio County Law Dept.
An Ohio partner at Squire Patton Boggs LLP with more than two decades of experience representing public entities has been nominated by Cuyahoga County, home to Cleveland, to serve as its new law director.
-
April 20, 2023
CPAs Ask IRS For Clarity On Digital Asset Losses
The Internal Revenue Service should clarify its guidance on how tax rules apply to losses of digital assets in light of recent crypto exchange bankruptcies including FTX's, the American Institute of Certified Public Accountants said in a letter to IRS Commissioner Daniel Werfel.
-
April 20, 2023
IRS Releases Foreign Insurance Calculation Guidelines
The Internal Revenue Service published values Thursday for certain foreign insurance companies to use when calculating their minimum effectively connected net investment income for taxable years beginning after 2021.
-
April 20, 2023
Tax Court Ends Whistleblower Case Over Lack Of Jurisdiction
The U.S. Tax Court dismissed a whistleblower award case Thursday because the Internal Revenue Service didn't act on her claims, leaving the court without jurisdiction, the Tax Court said.
-
April 20, 2023
Investors Must Report Annuities from Trusts, Tax Court Says
The annuity payments a group of investors received after their charitable remainder annuity trusts sold property are taxable income, the U.S. Tax Court ruled Thursday, upholding a determination by the Internal Revenue Service.
-
April 20, 2023
Peruvian Siblings Can't Quell IRS' Bank Records Summonses
A Florida federal court on Thursday dismissed a suit and denied an evidentiary hearing request by three Peruvian siblings trying to keep the Internal Revenue Service from accessing their bank records on behalf of the Peruvian government.
-
April 20, 2023
CPA Owes $5.5M Penalties Over Meal Deductions, Court Told
An accountant who has tangled with the government for decades over whether mariners can deduct free meals should pay $5.5 million in penalties for helping sailors illegally claim thousands of the deductions, the government told a California federal court.
-
April 20, 2023
Senate Bill Would Hike Social Security Taxes On High Earners
People with income of more than $400,000 would face increased Social Security and Medicare taxes under a bill introduced in the U.S. Senate, with the goal of extending the solvency of the programs.
-
April 20, 2023
Pension Plan Segment Rates Rise In April
Segment rates for calculating pension plan funding rose in April, the Internal Revenue Service said Thursday.
-
April 20, 2023
House Bill Seeks To Raise SALT Deduction Cap
The federal government's state and local tax deduction would increase to a cap of $15,000 annually for individual filers under a bill introduced in the House of Representatives.
-
April 20, 2023
Senate Bill Would Create 'Fair Share' Tax On High Earners
A so-called fair share tax would be imposed on people with adjusted gross incomes of $1 million or more under a bill introduced in the U.S. Senate.
-
April 19, 2023
House Panel To Examine Claims Big-Name Tax Case Was Bungled
The House Ways and Means Committee will investigate allegations by an Internal Revenue Service employee of the federal government's mishandling of a high-profile case, committee Chairman Jason Smith said Wednesday.
-
April 19, 2023
9th Circ. Panel Prods Film Exec's Challenge To IRS Summons
A Ninth Circuit panel on Wednesday questioned whether a film executive had shown enough evidence for dismissal of an IRS summons for documents related to his prosecution in Italy for tax evasion.
-
April 19, 2023
China Benefits Most From US Energy Credits, GOP Says
Chinese Communists, not rural or working-class Americans, are the primary beneficiaries of new U.S. renewable energy credits intended to ease the impact of global warming, House Republicans said Wednesday at a hearing called to disparage Democrats' new tax and climate law.
-
April 19, 2023
Ga. Trust Seeks $1.2M From IRS, Says Denied Due Process
The Internal Revenue Service caused a Georgia charitable trust to incur $1.2 million in damages as a consequence of denying it a due process hearing, the trust told a D.C. federal court as it sought reimbursement of that amount.
Expert Analysis
-
What Tax Court's Mylan Legal Fee Ruling Means For IP Suits
The U.S. Tax Court's recent ruling that Mylan Inc. could deduct as regular business expenses the legal fees it incurred defending itself against patent infringement suits from brand-name drug manufacturers has the potential to increase patent litigation and may make settlement less appealing, say attorneys at Snell & Wilmer.
-
Biden's Clean Energy Goals Require Big Hydrogen Push
To realize its ambitious renewable energy goals, the Biden administration, along with Congress, must promote the growth of the hydrogen industry using every available tool, including regulations, grants, tax incentives and direct purchases, say Abdon Rangel at Andersen Tax and John Taylor at King & Spalding.
-
IRS Summons Ruling Isn't A Total Loss For Investors
A California federal court’s recent order allowing an IRS information summons on cryptocurrency exchange Kraken paradoxically provides hope for investors concerned about their privacy by limiting the scope of the agency’s inquiry, says Joshua Smeltzer at Gray Reed.
-
Justices' Nod To Preemptive Tax Challenges May Caution IRS
The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service, allowing pre-enforcement challenges of tax reporting rules despite the Anti-Injunction Act, is likely to make the U.S. Department of the Treasury more careful about its own compliance obligations under the Administrative Procedure Act, says Robert Carney at Caplin & Drysdale.
-
Let's End The Offshoring Of US Patents
Congress should work toward removing the loophole that allows companies to avoid U.S. taxes by moving their patents offshore, and ensure profits are taxed where the sales take place, says Sen. Patrick Leahy, D-Vt.
-
How Biden's First 100 Days Will Affect Gov't Contractors
Joseph Berger and Thomas Mason at Thompson Hine examine the significant opportunities for government contractors arising from actions during the first 100 days of the Biden administration, which set the stage for unprecedented investment in national infrastructure, domestic manufacturing, research and development, clean energy, pandemic response and economic recovery.
-
Addressing New COBRA Duties Under Virus Relief Law
Following the issuance of fully subsidized COBRA premiums for certain workers under the recently passed American Rescue Plan Act, employers should take steps to determine who is eligible, ensure additional notice requirements are satisfied, and train human resources on communicating with qualified individuals, say Randi May and Dustin Grant at Hoguet Newman.
-
Long Road Ahead For Biden's Individual Tax Hike Proposal
Dustin Stamper at Grant Thornton provides insight into President Joe Biden's recently proposed individual tax increases to pay for his American Families Plan, and explains how competing interests among congressional Democrats and Republicans may shape the final provisions and prolong their implementation.
-
What Value-Added Tax Might Look Like In The US
Christiaan Van Der Valk and Charles Maniace at Sovos consider the value-added tax, a primary source of revenue for many countries, and what it might mean for the U.S. were it implemented to raise funds for large-scale federal initiatives such as President Joe Biden's infrastructure plan.
-
New Markets Credit Will Aid Recovery In Low-Income Areas
The recently extended New Markets Tax Credit is a critical tool for economic development in low-income communities, which have been hit especially hard by the pandemic, so public finance attorneys should consider its benefits when advising clients on projects, says Julia Fendler at Butler Snow.
-
The International Outlook For US Border Carbon Adjustments
The Biden administration may see enacting a border carbon adjustment system as a good way to advance climate goals and protect domestic industries and jobs, but any such plan must take into account the need to respect existing international trade agreements, say attorneys at Akin Gump.
-
The Domestic Landscape For US Border Carbon Adjustments
With the Biden administration possibly eyeing border carbon adjustments on imported goods as a means to mitigate climate change, attorneys at Akin Gump discuss such policies' potential benefits to domestic businesses, and the political and technical challenges to their enactment in the U.S.
-
Prepare For Global Collaboration In Crypto Tax Enforcement
Recent Internal Revenue Service victories involving John Doe summonses served on cryptocurrency exchanges — and statements by the Joint Chiefs of Global Tax Enforcement about global collaboration in cryptocurrency-related tax investigations — should prompt assessment of prior virtual currency transactions and remediation before an enforcement agency shows up at the door, say attorneys at McDermott.