Federal

  • December 16, 2022

    Taxation With Representation: Wachtell, Davis Polk, Cravath

    In this week's Taxation With Representation, M3-Brigade Acquisition III Corp. will merge with Greenfire, Southwest Gas will sell MountainWest Pipelines, and Weber will be taken private.

  • December 16, 2022

    Surveys, Awards & More: Law360's 2023 Editorial Calendar

    Law360 publishes several award series throughout the year, including ones that highlight top-performing attorneys and practice groups. Here, find all you need to know about our awards and surveys, including due dates, FAQs, and the questions we'll ask so you can prepare ahead of time.

  • December 15, 2022

    FinCEN To Propose Beneficial Owner Registry Access Rules

    The U.S. Treasury Department's financial crimes unit said Thursday it plans to propose rules spelling out when governments and financial institutions may be granted access to so-called beneficial ownership information, following related final rules the unit issued in September.

  • December 15, 2022

    IRS Urges Tax Court To Rethink Nixing Of Easement Notice

    The U.S. Tax Court should reconsider a decision striking down a notice requiring the disclosure of potentially abusive conservation easement transactions, the IRS said, saying the court overlooked the agency's arguments that Congress permitted it to issue such guidance without public feedback.

  • December 15, 2022

    Corp. AMT Guidance May Arrive This Year, Official Says

    The U.S. Treasury Department may issue guidance for the new 15% corporate alternative minimum tax this year, an official said Thursday, noting that the department is trying to prioritize issues that will help more taxpayers sooner.

  • December 15, 2022

    US Asks 5th Circ. To Lift Block On ARPA Tax Cut Limit

    The Fifth Circuit should throw out an injunction that blocks a provision in federal law preventing Texas, Louisiana and Mississippi from using COVID-19 aid to fund tax cuts, the U.S. Department of the Treasury said Thursday.

  • December 15, 2022

    Global Min. Tax Violates Treaties, GOP Lawmakers Say

    Congressional Republicans criticized President Joe Biden's administration for acceding to a backstop to the 15% minimum tax under an international agreement to overhaul the global tax system, telling Treasury that the provision violates current treaties and hurts U.S. companies.

  • December 15, 2022

    Hiring A Priority As IRS Solidifies Funding Plans, Official Says

    The Internal Revenue Service is working to solidify details regarding how it will spend its nearly $80 billion funding boost, and a significant portion will be used for hiring, the agency's acting commissioner said Thursday.

  • December 15, 2022

    IRS Collected $4.9T In Taxes In Fiscal 2022, Report Says

    The Internal Revenue Service collected $4.9 trillion in taxes and remitted $642 billion in refunds in the 2022 fiscal year, according to a report released by the agency Thursday.

  • December 15, 2022

    Holland & Knight Adds Tax Pro From Eversheds Sutherland

    Holland & Knight LLP has added a longtime Eversheds Sutherland tax attorney, who will split his time between its Washington, D.C., and Orange County, California, offices.

  • December 15, 2022

    IRS, DOL Extend Pact To Stop Violations Of Worker Laws

    Aiming to stop businesses from shirking employment taxes and illegally withholding benefits by wrongly classifying workers as independent contractors, the IRS and the U.S. Department of Labor updated their agreement to share information about investigations into labor law violations, the government announced Thursday.

  • December 15, 2022

    OECD May Issue Min. Tax Guidance By Year-End, Official Says

    It's possible the Organization for Economic Cooperation and Development could release guidance before the end of the year that addresses certain administrative aspects of the new international minimum tax rules, including safe harbors, an OECD official said Thursday.

  • December 15, 2022

    Gov't Can't Prove ACA Fines Are Taxes, Retailer Tells DC Circ.

    In its bid to overturn $1.1 million in penalties for failing to offer health insurance to employees, a phone retailer told the D.C. Circuit that the U.S. government failed to prove Congress considered the penalties to be taxes.

  • December 15, 2022

    Partnership Reporting Exception Guidance Set To Be Finalized

    Updates to draft instructions for a domestic filing exception for broad reporting requirements in the form of tax schedules for businesses with foreign interests should be finalized sometime in January, an IRS official said Thursday at a conference in Washington, D.C.

  • December 15, 2022

    Applicable Federal Rates To Drop In January

    Applicable federal rates for income tax purposes will fall to start the new year, the Internal Revenue Service said Thursday.

  • December 15, 2022

    Norton Rose Adds Ex-Dorsey & Whitney Tax Atty In Houston

    A tax attorney with in-house experience at Amazon has joined Norton Rose Fulbright as a partner in Houston after more than a year at Dorsey & Whitney LLP.

  • December 14, 2022

    Mo. Can't Challenge ARPA Tax Offset, Treasury Tells Justices

    Missouri has no Article III standing to challenge the tax offset provision in the American Rescue Plan Act, the U.S. Treasury Department told the U.S. Supreme Court on Wednesday, asking the justices to deny the state's petition for certiorari.

  • December 14, 2022

    Estate Owes Tax On $3M Insurance Proceeds, 8th Circ. Told

    The U.S. government defended a $1 million tax bill assessed against a man's estate, arguing Wednesday in the Eighth Circuit that $3 million in insurance proceeds used to purchase shares in a family business should be included in the company's value. 

  • December 15, 2022

    CORRECTED: House GOP Tax Writers Have Access To Trump Tax Returns

    House Ways and Means Committee Republicans have requested and been granted access to former President Donald Trump's tax returns, the committee's top Republican told reporters Wednesday.

  • December 14, 2022

    Judge Now Partly Favors Del. In High Court MoneyGram Fight

    Some of the abandoned MoneyGram checks at issue in an interstate dispute before the U.S. Supreme Court are considered bank checks and thus Delaware can lay claim to them, a special master said in a partial reversal of a previous opinion.

  • December 14, 2022

    Judge Delays Trial Of Tax Pros Charged In $1B Shell Scheme

    A federal judge delayed the criminal trial of a Dallas tax attorney and three members of an accounting firm accused of using shell companies to hide $1 billion from the IRS for wealthy clients, declaring the case "complex" and saying prosecutors needed more time to prepare.

  • December 14, 2022

    Immigrant's Spouse Asks 4th Circ. To Revive Stimulus Check Row

    An Ohio mother who claimed she was wrongly denied a stimulus check because her husband lacks a Social Security number urged the Fourth Circuit to overturn a decision tossing the case, saying a lower court mistakenly ruled she was trying to stop the collection of taxes.

  • December 14, 2022

    Comments Sought On IRS Deduction, Capitalization Guidance

    The Internal Revenue Service asked for feedback Wednesday on record retention guidance for taxpayers claiming deductions or capitalizations of expenses.

  • December 14, 2022

    Former IRS LB&I Atty Selected As Appeals Office Deputy Chief

    A former attorney in the Internal Revenue Service's Large Business & International Division is taking over as the deputy chief of the agency's appeals office, according to a news release Wednesday.

  • December 13, 2022

    9th Circ. Probes Tax Filings' Validity In $35M Partnership Row

    A Ninth Circuit judge on Tuesday questioned a partnership's arguments that it properly filed its tax returns in a dispute involving a $35.5 million tax shelter-related deduction, saying the partnership relied on IRS guidance lacking the force of law to make its case.

Expert Analysis

  • US Must Boost Solar Industry To Protect Human Rights, Jobs

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    Recent revelations that many solar panels are made using polysilicon from the Xinjiang province of China, allegedly the site of mass forced labor and other abuses, make it all the more urgent that Congress and the Biden administration enact policies that promote American solar manufacturing in place of dumped and artificially cheap Chinese products, says Tim Brightbill at Wiley Rein.

  • What Crypto Holders Can Learn From Early-2000s Tax Scandal

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    The Internal Revenue Service’s recent push to gather information about cryptocurrency accounts is similar to its Swiss bank account investigations of the early 2000s, which should prompt taxpayers to consider voluntarily disclosing transactions before they are individually targeted for enforcement, say Timothy Wagner and Thomas Barnard at Baker Donelson.

  • Bipartisan Support Shows Bright Future For Carbon Capture

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    Recent policy proposals — from the Biden administration as well as members of Congress from both parties — promoting carbon capture, utilization and sequestration suggest that this technology has a key role to play in reducing carbon dioxide emissions, says Kevin Poloncarz at Covington.

  • International Tax Reform's Implications For Transfer Pricing

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    As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.

  • Justices' Preemptive Tax Challenge Ruling Shows Divisions

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    The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service reveals divisions among the justices about when potentially burdensome tax regulations can be challenged, making the holding less clear and less valuable, say George Isaacson and David Swetnam-Burland at Brann & Isaacson.

  • Takeaways From 2 New FBAR Rulings

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    In light of two recent California federal court decisions, capping penalties for nonwillful violations of foreign bank account reporting but broadening the willfulness standard, U.S. taxpayers must be vigilant about understanding their reporting obligations, and prepare for the Internal Revenue Service to target willful conduct, which yields much higher penalties, say Friedemann Thomma and Marianna Felshtiner at Venable.

  • How Biden Tax Plans Would Boost Renewable Energy

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    The Biden administration's recently released revenue proposals for fiscal year 2022 include major enhancements and extensions to various green energy tax credits, and show that the administration is aligned with Congress in supporting renewable development, even if they differ on details, say attorneys at Eversheds Sutherland.

  • What Tax Court's Mylan Legal Fee Ruling Means For IP Suits

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    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

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    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

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    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

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    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

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    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

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    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.

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