Federal
-
March 05, 2024
Treasury Finalizes Direct Pay Rules For Energy Tax Credits
The U.S. Department of the Treasury on Tuesday finalized regulations governing direct payments of several clean energy tax credits provided by the Inflation Reduction Act but said it was still mulling how to address so-called chaining of payments and co-ownership arrangements.
-
March 04, 2024
Former DOJ Assistant Chief Joins Bird Marella
The assistant chief in the fraud section of the Department of Justice's Criminal Division joined Bird Marella Rhow Lincenberg Drooks & Nessim LLP, the firm announced Tuesday.
-
March 04, 2024
Corporate Transparency Act Unconstitutional, Ala. Judge Says
An Alabama federal judge has found that the Corporate Transparency Act is unconstitutional, dealing a blow to proponents of the anti-money laundering law, who anticipate the ruling will be appealed to the Eleventh Circuit.
-
March 04, 2024
TCJA To Reduce Corporate Tax Revenue By 40%, Study Says
The 2017 Tax Cuts and Jobs Act is expected to reduce corporate tax revenue by about 40% over a decade after increased investment in the U.S. is accounted for, according to a study published Monday by the National Bureau of Economic Research.
-
March 04, 2024
Former IRS Commissioner Joins Chamberlain Hrdlicka
Former IRS Commissioner Charles "Chuck" Rettig joined Chamberlain Hrdlicka White Williams & Aughtry as a shareholder in Los Angeles, following in the footsteps of his former acting chief of staff, whom the firm hired last year.
-
March 04, 2024
Justices Won't Review $10M Tax On Gulfstream Heirs
The U.S. Supreme Court declined Monday to review the Internal Revenue Service's imposition of personal liability for $10 million in unpaid estate taxes on the survivors of Gulfstream Aerospace Corp.'s founder, letting stand a Ninth Circuit ruling.
-
March 04, 2024
1st Circ. Grapples With Crypto Exchange Tax Docs Seizure
First Circuit judges grappled Monday with an investor's claim that the IRS violated his privacy and property rights when it seized his account records from cryptocurrency exchange Coinbase, trying to establish during oral arguments to what extent the exchange was different from a traditional bank.
-
March 04, 2024
Trump's Former Finance Chief Pleads Guilty To Perjury
Allen Weisselberg, the longtime former financial chief of Donald Trump's real estate business empire, admitted Monday to lying under oath in the New York attorney general's civil fraud case as part of a plea deal to serve five months in jail.
-
March 01, 2024
IRS Turning To Experts, AI For Complex Returns, Werfel Says
The Internal Revenue Service is using a blend of newly hired subject-matter experts and artificial intelligence technology to increase scrutiny of complex tax returns filed by wealthy corporations and individuals, agency Commissioner Daniel Werfel said Friday.
-
March 01, 2024
Tax Break Bill Could Still Pass After Tax Season, Aide Says
If Senate lawmakers haven't voted on the bipartisan House-passed tax bill by the end of the 2024 tax filing season, that doesn't necessarily mean the bill won't get to President Joe Biden's desk this year, an aide to Democrats on the House Ways and Means Committee said Friday.
-
March 01, 2024
Exec's Captive Insurance Case Headed To Trial
Whether an insurance executive knowingly lied to clients by telling them they could take illegal tax deductions in connection with captive insurance arrangements should be decided by a jury, a Florida federal judge ruled, saying material facts in the case are disputed.
-
March 01, 2024
Commission Eyes Sweeping Changes To US Olympic Model
An independent commission called for an overhaul of the U.S. Olympic system Friday, rebuking leaders for failing to keep athletes safe from sexual abuse and calling on Congress to take a more active role in administrating youth sports.
-
March 01, 2024
Major Cos. Paying Well Below 21% TCJA Tax Rate, Study Says
Major corporations such as Netflix and T-Mobile are on average paying well below the 21% corporate tax rate established by the 2017 Tax Cuts and Jobs Act, a study by the Institute on Taxation and Economic Policy of more than 340 major corporations showed.
-
March 01, 2024
Easement Cases To Put IRS-Hired Appraisers Under Scrutiny
Some partnerships challenging the denial of tax deductions for conservation easement donations are mounting a new attack on the IRS' push to enforce the transactions with claims that the agency's multimillion-dollar contracts with third-party appraisal firms compel them to be biased toward the government.
-
March 01, 2024
House Tax Panel To Prep Members On OECD Pillar 1
Neither Republicans nor Democrats on the House Ways and Means Committee have opined much about the OECD profit reallocation plan known as Pillar One, but they will gain valuable information during an upcoming subcommittee meeting, a tax staffer for the panel said Friday.
-
March 01, 2024
Menendez Associate Pleads Guilty In Bribe Case
A New Jersey insurance broker pled guilty Friday to bribing Sen. Bob Menendez and his wife, Nadine, by buying her a Mercedes-Benz convertible, under an agreement to cooperate with federal prosecutors.
-
March 01, 2024
Taxation With Representation: Pillsbury, Cleary Gottlieb
In this week's Taxation with Representation, First Advantage Corp. acquires Sterling Check Corp., International Game Technology spins off two subsidiaries, Disney merges its media operations in India with Reliance Industries, and Atlas Energy Solutions purchases Hi-Crush.
-
March 01, 2024
IRS Amends Language In Clean Hydrogen Proposal
The Internal Revenue Service issued a correction notice Friday to change the language of a proposal relating to clean hydrogen production and whether such facilities are treated as energy property.
-
March 01, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service issued its weekly bulletin Friday, and it included notice of a variety of rate updates.
-
February 29, 2024
Logger Failed To Report $3M In Foreign Banks, Judge Rules
A logger failed to report more than $3 million he kept in foreign accounts, then fraudulently transferred the bulk of it to his wife when he learned he was being audited by the IRS, a Colorado federal judge said in upholding $1.7 million in penalties.
-
February 29, 2024
House Approves Aviation Excise Tax Extensions
The U.S. House voted Thursday to extend excise taxes funding the Airport and Airway Trust Fund for two months at their current rates, clearing the path for the legislation to be considered by the Senate.
-
February 29, 2024
Biz Owner's $2.4M FBAR Dispute Paused For Mediation
The U.S. government and a retired plumbing business owner mutually agreed to a 90-day stay of their $2.4 million tax dispute over foreign bank account reporting while they try to mediate a solution, a Georgia federal judge said Thursday.
-
February 29, 2024
IRS Funding Cuts Would Raise Deficit $24B, CBO Says
A congressional agreement to rescind $20 billion in appropriated funding for the Internal Revenue Service this year would add $24 billion to the federal deficit through the next 10 years, according to Congressional Budget Office projections published Thursday.
-
February 29, 2024
Ga. Man Convicted In $11M PPP Fraud Case Wants New Trial
An Atlanta man convicted on dozens of charges stemming from an $11 million pandemic loan fraud scheme has asked a Georgia federal judge for a new trial.
-
February 29, 2024
IRS Amends Treatment Of Public Utility Debt
The Internal Revenue Service will not define certain public utilities as not recognizing gross income until the public utility receives the proceeds of a debt issued by the qualifying state financing entity, the agency said Thursday.
Expert Analysis
-
Global Tax Chiefs Should Look To US Whistleblower Programs
As the Joint Chiefs of Global Tax Enforcement develops its international whistleblower program to address tax evasion and money laundering schemes in new areas like cryptocurrency, it should take lessons from highly successful U.S. programs on which features to include and pitfalls to avoid, say Neil Getnick and Nico Gurian at Getnick & Getnick.
-
Crypto Investors May Face Increasing State FCA Tax Liability
Cryptocurrency investors who fail to report the state tax consequences of transactions are poised to encounter increased civil or criminal legal exposure as a growing number of states bring tax fraud under the purview of their whistleblower statutes, say attorneys at Brownstein Hyatt.
-
Justices' Boechler Ruling May Spell Tax Exceptionalism's End
By basing its decision on cases outside the tax arena, the U.S. Supreme Court treated Boechler v. Commissioner as an administrative law case rather than a tax case and stripped away the traditional lines of tax exceptionalism, says James Creech at Baker Tilly.
-
MORE Act's Possible Impact On State-Licensed Cannabis Cos.
The Marijuana Opportunity Reinvestment and Expungement Act, recently passed in the U.S. House of Representatives, would dramatically alter the federal legal landscape for state-licensed cannabis businesses in both positive and negative ways — from opening new marketing avenues to compounding tax burdens, say attorneys at the Law Offices of Omar Figueroa.
-
3 Contract Considerations For Renewable Fuels Trade
As renewable fuels continue to develop and contracts for their sale and purchase become more common in the energy industry, companies should think about negotiating several key issues when entering into offtake agreements for feedstock purchase transactions, says Nneka Obiokoye at Holland & Knight.
-
What Microcaptive Reporting Ruling May Mean For The IRS
In CIC v. Internal Revenue Service, a Tennessee federal court’s decision to set aside an IRS requirement to disclose microcaptive insurance arrangements may be a step toward evidentiary standards to show that the potential for abuse in a lawful transaction is sufficient to support heightened disclosure requirements, says Samuel Lauricia at Weston Hurd.
-
Avoiding Surprise Taxation Of Employment Settlements
Excerpt from Practical Guidance
Sandra Cohen at Cohen & Buckmann discusses how to avoid unwelcome tax-related payments in connection with settling an employment claim, as the extra cost can significantly decrease the perceived value of an offer and push the parties further apart.
-
US Should Leverage Tax Rules To Deter Business With Russia
The U.S. should further restrict the flow of resources available for the Putin regime's war in Ukraine by denying U.S. businesses that operate in Russia or Belarus foreign tax credits and global intangible low-taxed income preferences, and by terminating its tax treaty with Russia, says Reuven Avi-Yonah at University of Michigan Law School.
-
Justices Must Apply Law Evenly In Shadow Docket Rulings
In recent shadow docket decisions, the U.S. Supreme Court has inconsistently applied the requirement that parties demonstrate irreparable harm to obtain injunctive relief, which is problematic for two separate but related reasons, says David Hopkins at Benesch.
-
Federal Cannabis Bill Needs A Regulatory Plan To Succeed
The Marijuana Opportunity Reinvestment and Expungement Act, which was passed by the U.S. House of Representatives on Friday, is laudable but fundamentally flawed because it lacks a robust regulatory plan that would allow for bipartisan support, says Andrew Kline at Perkins Coie.
-
To Capture All Digital Transactions, Tax Rules Must Keep Up
Legislative efforts to capture revenue from digital-transaction income can do better than the American Rescue Plan Act, which recently went into effect but employs definitions that have already been surpassed by technology, says Matthew Agramonte at Shutts & Bowen.
-
Lessons From Recent PPP Loan And COVID Fraud Cases
Following President Joe Biden's recent pledge to expand enforcement efforts against pandemic and Paycheck Protection Program loan fraud, a look at the U.S. Department of Justice's recent criminal and civil enforcement actions sheds light on its evolving priorities, say Sara Lord and Aaron Danzig at Arnall Golden.
-
Ampersand Clarifies Power Project Placed-In-Service Analysis
The Federal Circuit's recent ruling in Ampersand Chowchilla Biomass v. U.S. affirms a lower court's decision regarding when power generation projects were placed in service for federal income tax purposes, but also highlights that the placed-in-service analysis is not one size fits all, say David Burton and Viktoria Vozarova at Norton Rose.