Federal

  • November 04, 2022

    Appeals Office Bringing Back Workers Who Eased Backlogs

    Some employees in the IRS Independent Office of Appeals who joined an agencywide effort to address amended return and correspondence backlogs caused by COVID-19 will return to the department in the 2023 fiscal year, according to the office's focus guide released Friday.

  • November 04, 2022

    IRS Seeks Feedback On Settlement Fund Reporting Rules

    The Internal Revenue Service asked for comments Friday on a regulation that governs reporting for funds created for settlements.

  • November 03, 2022

    GOP Urges Treasury To Reverse Hungary Tax Treaty Withdrawal

    The U.S. Treasury Department should reconsider its decision to withdraw from a bilateral tax treaty with Hungary because it appears retaliatory for the country's opposition to the OECD's corporate global minimum tax, according to a letter sent Thursday by top congressional Republicans.

  • November 03, 2022

    Midterms Unlikely To Revive Debate Over Int'l Taxes In US

    The midterm elections are unlikely to jump-start Congress into considering changes needed to align the U.S. international tax regime with an OECD minimum tax, but the outcome will influence how lawmakers prepare for a debate involving global reforms and expiring tax cuts in the years to come.

  • November 03, 2022

    IRS Criminal Investigation Head Plans Big Hiring Boost

    The Internal Revenue Service's criminal investigation arm aims to hire more than 500 workers in the 2023 fiscal year, including 360 special agents, its chief said Thursday.

  • November 03, 2022

    3rd Circ. Affirms Convictions For False Tax Return Prep

    The Third Circuit on Thursday affirmed a man's convictions for assisting in preparing false tax returns, rejecting his argument that a lower court lacked jurisdiction because he had renounced his U.S. citizenship.

  • November 03, 2022

    IRS Seeks Comments On Debt Instrument Reporting Rules

    The Internal Revenue Service said on Thursday that it wants comments on rules for reporting contingent payment debt instruments.

  • November 03, 2022

    IRS Tax-Exempt Arm Focused On Rolling Out Direct Pay Rules

    The Internal Revenue Service Tax-Exempt and Government Entities Division is "vigorously focused" on developing a new regime for public utilities and other tax-exempt entities to directly receive payment of clean energy tax credits under the Democrats' new climate law, the division commissioner said Thursday.

  • November 03, 2022

    Treasury Seeking Input On Tax, Climate Bill Energy Provisions

    The U.S. Treasury is seeking public input on clean energy tax provisions of the Inflation Reduction Act, including on the new credit for clean commercial vehicles, the updated carbon capture credit and an extended incentive for electric vehicle charging stations, the department said Thursday. 

  • November 03, 2022

    Treasury Pressed On $1B In Improper Child Tax Credits

    Treasury should provide details on how it plans to recoup over $1 billion in advance child tax credits paid to people who weren't eligible for them, Republican leaders of the House Ways and Means and Budget committees said Thursday.

  • November 03, 2022

    US Urges Nix Of $638K Investment Tax Refund Suit

    The U.S. government asked a California federal court to dismiss a man's request for a $638,000 net investment income tax refund, saying he wrongly believed foreign tax credits should offset his bill.

  • November 03, 2022

    Court Orders Trump Org. Monitor During NY AG's Fraud Case

    A New York judge ordered the Trump Organization to install an independent monitor Thursday, ruling in favor of the state attorney general amid her $250 million fraud lawsuit against former President Donald Trump, his companies and its officers.

  • November 03, 2022

    Ex-Mass. Police Union Head, Lobbyist Guilty In Kickback Trial

    The former head of the Massachusetts state police union was convicted by a Boston federal jury Thursday of steering business to a Beacon Hill lobbyist in exchange for kickbacks, an across-the-board win for prosecutors in the public corruption case.

  • November 03, 2022

    Rep. Tells IRS To Review Conservative Nonprofit's Exempt Status

    The Internal Revenue Service should investigate potential tax status violations by a conservative nonprofit that sent out anti-transgender political mailers, a Democratic member of the House of Representatives told IRS Commissioner Charles Rettig.

  • November 02, 2022

    Trump Wants To Block NY AG From Seeing Revocable Trust

    Former President Donald Trump sued New York Attorney General Letitia James in Florida on Wednesday, asking for an injunction barring her from exercising any authority over the revocable trust that was named as a defendant in James' $250 million fraud suit against the former president.

  • November 02, 2022

    Former Execs Sue Bra Co., Alleging Harassment, Tax Evasion

    Two former executives of sports bra company Shefit Operating Co. have sued the company in Michigan federal court, claiming they were fired after reporting sexual harassment and raising the alarm about possible tax evasion by Shefit's owners. 

  • November 02, 2022

    3rd Circ. Backs Feds' Win In Tax Collection Timeliness Fight

    The Internal Revenue Service appropriately went after a man's nearly $833,000 tax liability in 2019 because his petition to the U.S. Supreme Court a year earlier extended the agency's remaining statute of limitations, the Third Circuit said Wednesday.

  • November 02, 2022

    Making Child Tax Credit's Changes Permanent Could Cost $1.4T

    Making the American Rescue Plan Act's changes to the child tax credit permanent would lower federal revenues by nearly $1.4 trillion over the next decade compared to current law, the Joint Committee on Taxation's chief said in a letter released Wednesday.

  • November 02, 2022

    Trump Can't Halt AG's $250M Fraud Suit Or Swap Judges

    On the eve of a hearing that could install a monitor over the Trump Organization and freeze its assets, former President Donald Trump lost a bid for a temporary restraining order Wednesday to halt the New York attorney general's case and transfer it to a new judge.

  • November 02, 2022

    Whirlpool Pushes Justices To Review $45M Foreign Sales Row

    The Sixth Circuit turned "ordinary administrative-law principles on their head" in ignoring regulations to conclude that Whirlpool owes tax on more than $45 million in income from a foreign affiliate, the company told the U.S. Supreme Court on Wednesday, urging it to consider the case.

  • November 02, 2022

    Administrator Liable For Hospital's Taxes, US Tells 5th Circ.

    The Fifth Circuit should uphold a Tax Court decision finding a former Houston hospital administrator personally responsible for the health provider's failure to pay employment taxes, the government argued Wednesday, saying the administrator recklessly disregarded the risk of not paying.

  • November 02, 2022

    Attys Deny Selling Mattel Stockholders Short In $7M Del. Deal

    Stockholder attorneys seeking a Delaware Court of Chancery nod for a $7 million, multicase settlement for derivative claims targeting a $109 million Mattel Inc. tax reporting error denied claims Wednesday that the deal "settles around" and scuttles an objecting team's complaint seeking far more.

  • November 02, 2022

    Exec Convicted In Tax Prep Fraud Asks To Avoid Prison

    An executive at a once-sprawling national tax-preparation business who pled guilty to participating in a massive scheme to defraud clients and the Internal Revenue Service asked an Ohio federal judge to spare him a prison sentence, saying it would potentially destroy his family's life.

  • November 02, 2022

    2 GOP Sens. Propose Greater Oversight Of IRS Funding Boost

    Two Republican members of the Senate Finance Subcommittee on Taxation and Internal Revenue Service Oversight said they want to introduce legislation to penalize the IRS unless it submits yearly plans for the $80 billion funding boost recently provided by Congress.

  • November 02, 2022

    Woman Owes $2M In Tax Over Disallowed Labor Costs, US Says

    A Florida woman owes nearly $2 million in back taxes after she and her deceased husband failed to substantiate contract labor expenses, the government said in a complaint filed in federal court.

Expert Analysis

  • The Infrastructure Bill Should Not Target Cryptocurrency

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    Congress should excise a provision in the pending infrastructure bill that would require anyone who accepts $10,000 in cryptocurrency for goods or services to report the transferring party's personal information to the Internal Revenue Service — this would be unnecessary, ill-advised and possibly unconstitutional, says James Burnham at Jones Day.

  • Opportunity Zone Regulations Require More Fine Tuning

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    Problems with the latest revisions to the qualified opportunity zone investment rules reinforce a recurring theme of regulatory hiccups that may prevent investors and communities from actualizing the program's potential benefits, unless we have more guidance, says Mitchell Goldberg at Berger Singerman.

  • Preserving Disgorgement Tax Deductibility In SEC Settlements

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    The U.S. Securities and Exchange Commission recently added language to its enforcement orders that could affect a settling party's ability to deduct certain disgorgement payments, but proper planning can help them satisfy Internal Revenue Service prerequisites, say attorneys at Sidley.

  • How The Global Tax Agreement Could Backfire For Biden

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    If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.

  • Tax-Exempt Orgs, Beware This 403(b) Plan Compliance Pitfall

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    A recent Internal Revenue Service publication puts 403(b) retirement plan sponsors on notice about a contribution aggregation compliance failure often identified in audits of government and tax-exempt entities, but risk can be minimized by ensuring plan documents and communications address the issue directly, say Greg Needles and Michael Gorman at Morgan Lewis.

  • Pandora Papers Reveal Need For Greater Tax Enforcement

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    The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.

  • Telehealth Providers Must Beware Of Fraud As Industry Grows

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    A recent fraud charge against a telehealth executive highlights the rise we're seeing in telefraud scams during the industry's pandemic growth, and there are some steps that all health providers should take to stay clear of potentially illegal arrangements, says LaTawnda Moore at Dinsmore.

  • 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.

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