Federal

  • January 04, 2023

    Florida Woman, US Propose $818K FBAR Settlement

    A Florida woman would pay nearly $818,000 to end a case seeking penalties against her for failing to file reports of her foreign bank accounts under the proposal she and the U.S. government submitted in federal court.

  • January 03, 2023

    Israeli Law Firm Takes GILTI Regs Challenge To DC Circ.

    An Israeli law firm and its sole shareholder will continue fighting the global intangible low-taxed income regulations set forth in the Tax Cuts and Jobs Act by taking their case to the D.C. Circuit.

  • January 03, 2023

    Atty Lied During Tax Fraud Trial, Investment Adviser Says

    An investment adviser's former attorney gave false testimony during a tax fraud case that the U.S. government is now using to seek $2.2 million in civil penalties for unreported offshore accounts, the adviser said in a lawsuit in Arizona federal court.

  • January 03, 2023

    IRS Won't Flag FATCA Filings That Don't Have ID Numbers

    Foreign financial institutions that report information on U.S. account holders to the Internal Revenue Service without including the taxpayer identification numbers associated with those accounts won't be flagged for noncompliance, the agency announced.

  • January 03, 2023

    Chrisleys Can't Extend Prison Report Date In Bank Fraud Case

    A Georgia federal judge denied a request by Todd and Julie Chrisley, stars of reality TV show "Chrisley Knows Best," to delay their prison report date, but did order the government to respond to their motions for bond pending an appeal of their bank fraud and tax evasion convictions.

  • January 03, 2023

    IRS Defines Terms For Clean Vehicle Credit

    The clean vehicle tax credit can apply to a consumer who took possession of a qualified electric vehicle on Jan. 1 or later, the IRS said in a notice defining the incentive's "placed in service" term that can unlock the incentive.

  • January 03, 2023

    Ex-Pharma CEO Asks Justices To Review $1M In Tax Penalties

    A former pharmaceutical CEO asked the U.S. Supreme Court to review a Third Circuit decision upholding $1 million in Internal Revenue Service penalties against him for failing to report a Swiss bank account, saying the circuit wrongly considered his actions reckless.

  • January 03, 2023

    Riding Circuit: January's Notable Appellate Arguments

    Circuit courts will kick off 2023 with oral arguments by parties questioning the authority given to the Centers for Disease Control and Prevention, pushing back against U.S. Patent and Trademark Office policy on patent reviews and claiming Chinese nationals were wrongly targeted for alleged economic espionage.

  • January 03, 2023

    GoDaddy Parent Asks Tax Court For $16M In R&D Credits

    The parent company of web hosting platform GoDaddy petitioned the U.S. Tax Court for help securing $16.3 million in research and development tax credits, saying its software and product development expenses qualified for a now-expired tax break.

  • January 03, 2023

    IRS Increases Standard Mileage Rate By 3 Cents

    The Internal Revenue Service raised its standard mileage rate for business use to 65.5 cents per mile in the new year, a three-cent increase.

  • January 02, 2023

    Federal Tax Cases To Watch In 2023

    In the coming year, the U.S. Supreme Court will hear multiple high-profile tax cases involving attorney-client privilege and foreign bank account penalties, while lower courts will continue to grapple with the legitimacy of IRS rulemaking. Here, Law360 reviews the top federal tax cases to watch in 2023.

  • January 02, 2023

    International Tax Policy To Watch In 2023

    As global policymakers continue to develop an international tax overhaul, it will be up to governments around the world to determine whether and how much of the plan to enact in 2023. Here, Law360 runs down international tax policies to watch for in the coming year.

  • January 02, 2023

    Federal Tax Policy To Watch In 2023

    A divided Congress will return to Capitol Hill in late January with little hope of eking out a comprehensive bipartisan tax agenda that can reach President Joe Biden's desk during the last two years of his presidency.

  • January 02, 2023

    7 Supreme Court Cases To Watch In 2023

    The new year brings a host of hot-button cases for the U.S. Supreme Court justices, who will tackle everything from President Joe Biden's student debt relief plan to Section 230 immunity for Big Tech companies over the next six months before the summer recess. Here, Law360 highlights the big-ticket items.

  • December 29, 2022

    Brokers Can Wait For Regs To Report Digital Assets

    Brokers won't be required to report additional information about sales of digital assets as required by a new law until Treasury and the IRS issue final regulations clarifying which digital assets qualify and giving instructions for reporting, according to an IRS announcement.

  • December 28, 2022

    Treasury Issues Interim AMT Guidance Including Safe Harbor

    The U.S. Treasury Department has issued interim guidance for the new 15% corporate alternative minimum tax, including a safe harbor method for determining whether the levy applies to companies for the upcoming year.

  • December 27, 2022

    Treasury Clarifies Fair Market Price For Stock Buyback Tax

    The new excise tax on stock buybacks will use the price of the stock on the date it was repurchased as the fair market value to assess the levy that will take effect Jan. 1, the U.S. Department of the Treasury said Tuesday.

  • December 23, 2022

    Judge Awards La. Doctors' Cos. $70M In Arbitration 'Mess'

    A federal judge in Texas has cleaned up what she described as a "post-arbitration mess," awarding over $70 million, plus $18 million in attorney fees, to a group of Louisiana medical companies suing a Houston law office for malpractice.

  • December 23, 2022

    Congress Sends $1.7T Spending Deal To Biden

    The U.S. House of Representatives voted 225-201 on Friday to pass a $1.7 trillion spending package funding the government through September and approving a number of last-minute policy agreements at the end of the congressional session.

  • December 23, 2022

    IRS Delays $600 Payment Reporting Requirement For 1 Year

    The IRS will push back for one year its implementation of a law requiring peer-to-peer payment platforms such as Venmo and PayPal to report aggregate payments of $600 or more, the agency announced Friday, saying the delay will "help reduce confusion" over the new requirements.

  • December 23, 2022

    IRS Clarifies Rule For Clean Commercial Building Deduction

    An updated reference standard applies to property constructed after 2022 and placed in service after 2026 for the purposes of determining an energy-efficient commercial building property deduction, the Internal Revenue Service said Dec. 23.

  • December 22, 2022

    Ill. Court Affirms Morgan Lewis Win In BDO Tax Shelter Case

    An Illinois appellate panel has affirmed Morgan Lewis & Bockius LLP's win over claims the firm conspired to help cover up illegal tax shelters that landed some former executives at accounting firm BDO in prison, saying the former BDO clients who brought the suit knew about their injury roughly a decade prior.

  • December 22, 2022

    House Backs Mandatory IRS Audits Of Presidents' Tax Returns

    The House of Representatives approved a bill Thursday that would require the Internal Revenue Service to conduct mandatory audits of presidential tax returns within 90 days of when the president takes the oath of office.

  • December 22, 2022

    Scoreboard Co. Daktronics Faces Investor's Fraud Claims

    Scoreboard maker Daktronics Inc. and two of its executives face investors' claims they failed to properly apprise investors of the company's financial circumstances when it disclosed it was facing supply chain disruptions, labor shortages and a facility shutdown in China.

  • December 22, 2022

    Int'l Program May Pick Up Slack If IRS Restricts APAs

    If the Internal Revenue Service decides to make advance pricing agreements harder to get, as an official's recent comment suggests, an international compliance program may offer some level of comfort for companies seeking certainty about their transfer pricing.

Expert Analysis

  • Parsing New Int'l Tax Reporting Rules For Pass-Throughs

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    Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.

  • A Look At Global Tax Enforcement Developments: Part 2

    Excerpt from Practical Guidance
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    Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.

  • A Look At Global Tax Enforcement Developments: Part 1

    Excerpt from Practical Guidance
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    Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.

  • What The Judiciary's Font Recommendations Can Teach Us

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    The D.C. Circuit's recent soft prohibition on Garamond and the ensuing debates about courts' font preferences should serve as a helpful reminder of a larger point — every departure from convention in legal writing carries some level of risk, says Spencer Short at Stradley Ronon.

  • 2 Income Tax Loopholes Congress Should Close

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    To raise revenue for proposed infrastructure improvements and make the tax law fairer, the Biden administration and Congress should close an income tax loophole that allows an asset owner to bypass capital gains tax upon death and another that essentially allows taxpayers to make tax‑free gifts to grantor trusts, says Richard Kinyon at Shartsis Friese.

  • High Points Of IRS' New Employee Retention Credit Guidance

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    Dana Fried at CohnReznick examines recent IRS guidance on the employee retention credit, which includes a helpful new rule enabling more employers to qualify for the credit by allowing them to exclude some pandemic relief from gross receipts, but its exclusion of related individuals' wages from qualified wages for certain corporate owners is disappointing.

  • Prepare For More Audits Of Tax Info And Withholding Filings

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    Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.

  • 9th Circ. Adds Pressure To Reject Substance Over Form

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    The Ninth Circuit’s recent decision rejecting taxes on a family's Roth IRA payments that were made through a foreign sales corporation represents a refreshing trend among federal appeals courts to reject substance-over-form principles and instead look to congressional intent, say Lawrence Hill and Caitlin Tharp at Steptoe & Johnson.

  • How Tax Code Changes Affect State AG Settlement Talks

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    Meghan Stoppel and Gianna Puccinelli at Cozen O'Connor discuss how newly implemented tax code regulations that allow companies to deduct some payments made to resolve a government investigation or prosecution will change settlement negotiations with state attorneys general.

  • NFTs May Come With Rewards, But Also Legal Risks

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    While some buyers of nonfungible tokens are experiencing enormous returns on their investments, those just entering the market should proceed with caution, and be sure to understand the risks related to contracts, taxation, intellectual property and money laundering regulations, says Anne-Laure Alléhaut at Patterson Belknap.

  • Problems To Avoid When Forming Your 2nd Real Estate Fund

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    There are a number of considerations when moving from your first real estate fund to subsequent funds during post-pandemic growth, particularly if the aggregate regulatory assets under management of the funds exceed $110 million or if additional country jurisdictions will be involved, say Matt Ertman and Max Brunner at Allen Matkins.

  • IRS Ruling Opens Runway For Stalled Carbon Capture Deals

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    A recent Internal Revenue Service ruling that clarifies how multiparty ownership affects eligibility for the carbon sequestration tax credit should accelerate the pace of project financing transactions that were held up by lingering uncertainty, and should increase the pool of projects into which tax equity will consider investing, say attorneys at Orrick.

  • What Biden's Tax Proposals May Mean For Int'l Private Clients

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    Jennifer Wioncek and Paul D’Alessandro at Bilzin Sumberg discuss the U.S. Department of the Treasury's recently released explanation of the Biden administration's tax proposals and how the changes would affect income and wealth transfer planning for international private clients.

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