Federal
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March 22, 2024
Married Doctors Owe Feds $2.9M In Taxes
A Connecticut physician couple must pay $2.9 million in back taxes, interest and penalties plus statutory additions after a federal court ruled they failed to produce enough evidence to challenge the accuracy of the U.S. government's tax assessments against them.
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March 22, 2024
Ariz. Says Federal Tax On Rebates Contradicts IRS Guidance
A decision by the Internal Revenue Service to impose federal income tax on rebates issued last year by Arizona violates the agency's own recent guidance, the state told a federal court, saying a preliminary injunction against the tax would not unduly burden the agency.
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March 22, 2024
Holland & Knight Hires Caplin & Drysdale Member In DC
Holland & Knight LLP has boosted its Washington-based tax team, hiring a Caplin & Drysdale Chtd. member who first joined his former firm 25 years ago from the U.S. Department of the Treasury.
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March 22, 2024
US Unlikely To Move On Hungary Tax Treaty, Official Says
Hungary's low corporate tax rate and other policies will likely prevent the U.S. government from resuming negotiations on a stalled 2010 tax treaty after terminating its existing Hungarian treaty in early 2023, an IRS official said Friday.
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March 22, 2024
IRS Steadily Returning To Pre-Covid Levels, TIGTA Says
Internal Revenue Service initiatives have reduced some — but not all — document processing back to pre-pandemic levels, the Treasury Inspector General for Tax Administration said in a report.
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March 22, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service issued its weekly bulletin Friday, which included rules for businesses substituting certain tax forms.
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March 21, 2024
Treasury Hoping Pillar 2 Guidance Favors R&D Tax Credits
The U.S. Treasury Department is looking for future administrative guidance on the international minimum tax agreement known as Pillar Two to give favorable treatment to U.S. research and development tax credits, but it will likely come with guardrails, a Treasury official said Thursday.
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March 21, 2024
Tax Court OKs Collection After Man Fails To Provide Records
A Georgia man cannot challenge a tax collection action after failing to provide financial records proving he cannot pay a liability, the U.S. Tax Court ruled Thursday.
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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.
Expert Analysis
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What's Unique — And What's Not — In Trump Protective Order
A Manhattan judge's recent protective order limiting former President Donald Trump's access to evidence included restrictions uniquely tailored to the defendant, which should remind defense attorneys that it's always a good idea to fight these seemingly standard orders, says Julia Jayne at Jayne Law.
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The Nuts And Bolts Of IRS Domestic Content Tax Credit
Recent IRS guidance provides specifics on how renewable energy projects can qualify for bonus tax credits by meeting U.S. domestic content rules, but also creates a qualification framework that will be complicated for project developers to navigate, say Scott Cockerham and Wolfram Pohl at Orrick.
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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.