Federal

  • November 21, 2022

    Man Owes Tax On Retaliation Settlement, Tax Court Says

    A former higher education employee has to pay tax on a nearly $231,000 settlement he received for claims that his employer retaliated against him after claiming the institution misused funds, the U.S. Tax Court said Monday.

  • November 21, 2022

    Tax Court Says Couple's Income Must Include Retirement Pay

    A Connecticut couple must include most of the railroad retirement benefits the husband received in 2015 in their income for that year, the U.S. Tax Court said Monday.

  • November 21, 2022

    Tax Court Fines Texas Couple For Frivolous Arguments

    A Tax Court judge pinned a Texas couple with a $5,000 fine for making frivolous arguments while challenging their $33,000 tax bill, saying they persisted in bringing "all-too-familiar tax protestor contentions," according to an opinion released Monday.

  • November 21, 2022

    IRS Issues New Required Retirement Plan Amendments List

    The Internal Revenue Service on Monday released the 2022 edition of an annual list of required amendments for qualifying individually designed retirement plans.

  • November 21, 2022

    $3B Easement Scheme Case Closed Pending Settlement

    A Georgia federal judge on Monday closed a long-running case alleging an investment group and an Alabama appraiser promoted a $3 billion conservation easement tax scheme, saying government review of their settlement offers could take too long to simply hit pause.

  • November 21, 2022

    Former CEO Cops To Tax Fraud, Agrees To $15.8M Restitution

    A former health care management firm CEO agreed to pay $15.8 million in restitution after pleading guilty in Pennsylvania federal court to skirting millions in personal and corporate income taxes by claiming improper business write-offs and funneling money through his various business entities.

  • November 21, 2022

    Supreme Court Won't Hear Whirlpool Tax Challenge

    The U.S. Supreme Court won't hear Whirlpool's challenge to a Sixth Circuit ruling that the company owes taxes on about $45 million of foreign income, according to an order list from the top court published Monday.

  • November 18, 2022

    Biden Asks Justices To Reinstate Student Debt Relief Program

    The Biden administration asked the U.S. Supreme Court on Friday to let it move forward with a plan to forgive student loan debt after the Eighth Circuit halted the program, saying the delay "leaves millions of economically vulnerable borrowers in limbo."

  • November 18, 2022

    6th Circ. Blocks ARPA Clawback Enforcement Against Tenn.

    The federal government can't enforce a provision barring Tennessee from using federal coronavirus relief funds to offset revenue reductions such as tax cuts, but Kentucky lacked standing to challenge the provision, the Sixth Circuit said Friday.

  • November 18, 2022

    Foreigners Barred From Tax Treaty Aid On Some Distributions

    Foreign taxpayers cannot claim treaty benefits on the distribution of stock in a domestic international sales corporation on the grounds that the distribution is not attributable to a U.S. permanent establishment, according to an IRS legal memo published Friday.

  • November 18, 2022

    States Seek IRS Liaison For Sharing Of Charities' Tax Info

    An IRS liaison is necessary to help state regulators access nonprofits' federal tax information following the release of final rules that broaden the agency's authority to share that data with states, an official from the New York attorney general's office said Friday.

  • November 18, 2022

    6th Circ. Tosses Ohio's Challenge To ARPA Tax Cut Limit

    The Sixth Circuit on Friday threw out Ohio's challenge to an American Rescue Plan Act provision that requires states to return pandemic aid used to offset tax cuts, finding that no federal recoupment of state funds was imminent.

  • November 18, 2022

    The Tax Angle: New Ways And Means Members, House Rules

    From a look at possible changes to the House Ways and Means Committee's membership to the GOP's new rules for House legislation, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • November 18, 2022

    1st Circ. Tosses Aegerion Rep's Drug Fraud Convictions

    A former Aegerion Pharmaceuticals Inc. salesman saw his convictions in a drug fraud scheme wiped away by the First Circuit on Friday when a panel found that a judge improperly highlighted the government's evidence on the jury's verdict form.

  • November 18, 2022

    IP Attys Urge Justices To Adopt Broad Atty-Client Privilege

    An intellectual property group urged the U.S. Supreme Court to endorse a broad application of attorney-client privilege to mixed-use client communications, arguing it shouldn't adopt a more stringent privilege standard in a case involving a firm's efforts to shield tax advice from subpoenas.

  • November 18, 2022

    Senate, House Bills Seek Education Credit For Drug Offenders

    A bill reintroduced in both chambers of Congress would allow students with felony drug convictions to qualify for the American Opportunity Tax Credit.

  • November 18, 2022

    Weisselberg's Loyalties Scrutinized At Trump Org. Fraud Trial

    Longtime Trump Organization Chief Financial Officer Allen Weisselberg faced questions about where his loyalties lie — as he continues to cash company checks but also needs prosecutors' approval of his truthfulness — in finishing up his testimony Friday in the Manhattan district attorney's fraud case against ex-President Donald Trump's business.

  • November 18, 2022

    Former Tax-Prep Exec Gets 3 Months For Fraud Scheme

    A former pastor who pled guilty to participating in a national scheme to defraud the Internal Revenue Service and the mostly poor clients of a shuttered tax-preparation business was sentenced Friday to three months in prison, short of the three years prosecutors had asked for.

  • November 18, 2022

    Taxation With Representation: Gibson Dunn, Ropes & Gray

    In this week's Taxation With Representation, Estée Lauder Cos. Inc. will acquire Tom Ford, United Rentals Inc. is acquiring Ahern Rentals Inc., Indivior PLC is offering to buy Opiant Pharmaceuticals Inc., and PTC reached an agreement to acquire ServiceMax.

  • November 18, 2022

    Trump Org. Trial Firms Paid By Conservative PACs

    More than $500,000 in recent payments from political organizations connected to former President Donald Trump were made to law firms involved with the ongoing criminal trial of the Trump Organization, according to Federal Election Commission records.

  • November 18, 2022

    Feds Seek $2.4M In FBAR Penalties From Plumbing Co. Owner

    The owner of a plumbing business who failed to report real estate income held in bank accounts in Barbados should pay $2.4 million in penalties, despite his initial willingness to cooperate with the IRS, the government told a Georgia federal court.

  • November 18, 2022

    IRS Seeks Comments On LIFO Relief Rules

    The Internal Revenue Service asked for comments Friday on rules that allow vehicle dealers to keep using the last-in, first-out inventory method after violating some conformity requirements.

  • November 18, 2022

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin, which included guidance that amends rules for seeking determinations on certain retirement plans.

  • November 18, 2022

    Treasury Floats New Foreign Tax Credit Rules

    The U.S. Treasury Department proposed regulations Friday that include a few narrow exceptions to 2021 final foreign tax credit regulations, which generally require offshore measures to align with U.S. laws to qualify for a credit back home.

  • November 17, 2022

    NY Court Sets Guidelines For Trump Org. Monitorship

    A New York state court on Thursday laid out additional guidelines for a court-ordered monitorship of the Trump Organization in the state attorney general's $250 million fraud case, giving the company about two weeks to hand over information about its corporate structure.

Expert Analysis

  • How High Court Could Change FBAR Penalty Landscape

    Author Photo

    On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.

  • IRS Memo May Change IP Royalty Tax Prepayment Planning

    Author Photo

    A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.

  • What IRS Funding Increase Means For Taxpayers

    Author Photo

    The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.

  • 6 Tax Considerations For Life Sciences Collaboration Deals

    Author Photo

    Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.

  • Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess

    Author Photo

    Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.

  • Post-Litigation Refund Strategies To Defeat Class Certification

    Author Photo

    The Third Circuit's recent revival of the Duncan v. Governor of the Virgin Islands class action shows that defendants should strongly consider tendering refunds to class representatives — even after they file suit — to create a substantial obstacle to certification, say attorneys at Covington.

  • Key Considerations For Seeking Relief From Double Taxation

    Author Photo

    Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.

  • High Court Could Resolve Thorny Atty-Client Privilege Issue

    Author Photo

    The U.S. Supreme Court recently granted review in a federal grand jury proceeding that presents a rare opportunity to clarify — and possibly significantly expand — the scope of the attorney-client privilege for complex mixed-purpose communications with counsel, says David Greenwald at Jenner & Block.

  • 2 Tax Decisions Hold Key Transfer Pricing Takeaways

    Author Photo

    Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.

  • Patagonia's Succession Plan Is A Blueprint For Biz Owners

    Author Photo

    While not every business owner is interested in giving their company away to a charitable purpose like Patagonia's founder recently did, the outdoor apparel company's unique situation highlights the considerations that should go into any succession plan, says Abosede Odunsi at Freeborn & Peters.

  • The CHIPS Act: Key Takeaways For Semiconductor Industry

    Author Photo

    The Biden administration’s recently signed CHIPS Act signals that the U.S. is making progress toward bolstering the domestic semiconductor industry, and manufacturers must prepare by understanding the requirements of the act and associated Department of Commerce guidance, say attorneys at Miller & Chevalier.

  • Digital Taxation Is Necessary, But Tough To Manage

    Author Photo

    The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.

  • 5 Considerations When Seeking Federal EV Funding

    Author Photo

    A recent White House fact sheet shows how federal efforts to support the full scope of the electric vehicle industry have moved the needle, but some details about how to use those funds are still being ironed out, and there are a few issues to watch, say attorneys at Morgan Lewis.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.