Federal
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April 11, 2024
Swiss Bank Probe May Prompt IRS To Revive Disclosure Effort
Senate Finance Committee Chairman Ron Wyden's latest investigation into the Swiss banking industry may apply further pressure to federal law enforcement officials to revive a program designed to encourage taxpayers' voluntary compliance in disclosing income held overseas to the IRS.
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April 11, 2024
IRS Schedules 6 Taxpayer Advisory Panel Meetings For May
The Internal Revenue Service announced the schedule Thursday for six Taxpayer Advocacy Panel committee meetings to be held in May.
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April 10, 2024
House Panel Leaders Say Tax Bill Delay Hurts Small Biz
The chairman and the ranking member of the House Small Business Committee both urged the Senate on Wednesday to pass the tax bill held up by Republican senators, saying continuing to delay the proposal's package would further burden small businesses.
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April 10, 2024
Plastic Surgeon Owes $7.7M From Offshore Scheme, US Says
A now-retired plastic surgeon owes the Internal Revenue Service more than $7.7 million after he ran an offshore employee leasing scheme and he and his wife transferred nearly all their assets to their then-11-year-old daughter, who is now a lawyer, the government told an Ohio federal court.
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April 10, 2024
8th Circ. Skeptical Of Bid To Reveal IRS Fraud Detection Docs
Eighth Circuit judges seemed skeptical Wednesday of a retired Harvard law professor's efforts to force the IRS to reveal its techniques for questioning fraud suspects, as two of three judges on a panel highlighted the potential to prevent identity theft by keeping the techniques hidden.
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April 10, 2024
Pension Plan Segment Rates Increase In April
Segment rates for calculating pension plan funding rose in April, the Internal Revenue Service said Wednesday.
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April 10, 2024
Family's $25M Settlement Is Income, Tax Court Says
A $25 million settlement received by a family was not tied to personal injury damages, making it taxable, the U.S. Tax Court ruled Wednesday.
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April 10, 2024
Fla. Atty Gets 8 Years For Fraudulent Tax Shelter Scheme
A Florida attorney was sentenced Wednesday to eight years in prison after pleading guilty in federal court to tax evasion and defrauding the U.S. government through a tax shelter scheme he pitched to clients that involved making purported charitable contributions so his clients could claim millions of dollars in tax deductions they weren't qualified to receive.
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April 10, 2024
IRS' DOJ Referral Rules 'A Disaster,' Sen. Whitehouse Says
The IRS protocols for referring cases to the U.S. Department of Justice are "a disaster" for enforcing laws against bankers and other actors who help U.S. taxpayers evade taxes, Sen. Sheldon Whitehouse said Wednesday during a hearing on offshore tax evasion before the Senate Budget Committee.
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April 10, 2024
Feds Cleared To Use Undercover Recording In Atty's Tax Trial
Federal prosecutors trying an attorney next week on charges he orchestrated a tax fraud scheme that spanned seven states will be allowed to play for the jury an audio recording made by an undercover agent, a North Carolina federal judge ruled.
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April 10, 2024
IRS Floats Alternative For Hydrogen Credit Emissions Value
The Internal Revenue Service released guidance Wednesday that would allow hydrogen producers to pursue another method to value their emissions output — which is critical in qualifying for the clean hydrogen production tax credit — if they can't get the information using the Argonne National Laboratory model.
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April 10, 2024
Senate Finance Panel Schedules Hearing On IRS Budget
The Senate Finance Committee will convene next week to discuss the Internal Revenue Service's budget for 2025, the committee said Wednesday.
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April 10, 2024
IRS Fixes Heading For Apprenticeship Credits, Deductions
The Internal Revenue Service issued a correction notice Wednesday to fix a heading related to increased tax relief for meeting certain wage and apprenticeship requirements.
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April 10, 2024
Ex-Trump Finance Chief Weisselberg Jailed For Perjury
A New York state judge on Wednesday sentenced former Trump Organization Chief Financial Officer Allen Weisselberg to five months in jail for lying under oath in the attorney general's civil fraud case against Donald Trump and his business associates, imprisoning a close ally of the former president on the eve of his hush-money trial.
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April 09, 2024
Treasury Proposes Long-Awaited Stock Buyback Tax Rules
The U.S. Treasury Department proposed a pair of long-awaited rules Tuesday that detail the calculation and reporting of a new excise tax assessed to publicly traded corporations that recently bought back their own shares of stock on the open market.
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April 09, 2024
Healthcare Co. Can't Sue Ex-Exec For Causing Canada Tax Hit
A Colorado federal judge shot down a pharmacy automation company's suit alleging its former chief commercial officer cost it nearly CA$1.2 million ($907,000) in Canadian taxes by not telling his employer he had moved out of the country, saying the company hasn't shown it suffered any damage as a result.
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April 09, 2024
10th Circ. Won't Allow Church To Skirt IRS Summons
The Tenth Circuit rejected a Kansas church's request to quash an Internal Revenue Service's third-party summons into the organization's bank records because the church does not hold the financial information and therefore is not subject to church tax inquiry restrictions, according to an opinion released Tuesday.
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April 09, 2024
Man's Unusual Filing Methods Led To Liability, 4th Circ. Told
The Fourth Circuit should uphold a U.S. Tax Court decision allowing the IRS to collect the tax liability of a technology consultant who for years used unusual filing methods, the government argued Tuesday, saying the court correctly noted he contributed to any confusion over his bill.
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April 09, 2024
Tax Court Rejects Pa. Man's Worked-For-Free Claim
A Pennsylvania man who claimed he worked for free is liable to pay more than $15,000 in unpaid income taxes, according to a ruling transcript published Tuesday by the U.S. Tax Court.
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April 09, 2024
Fund Managers Want Ga. Attys' Tax Shelter Fraud Suit Tossed
A fund manager accused of misleading investors into an illegal tax shelter want a Georgia federal court to throw out the proposed class action against them, claiming the facts alleged in an updated complaint still aren't specific enough for court.
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April 08, 2024
Tax Court Upholds $11M In Foreign Reporting Penalties
The U.S. Tax Court on Monday mostly upheld $11 million in foreign reporting penalties against a man who admitted he hid money overseas, but the court declined to overturn its ruling that the IRS lacks authority to assess certain foreign reporting penalties.
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April 08, 2024
Tax Court OKs Accuracy Penalties After 11th Circ. Reversal
A Florida man found to owe more than $9 million in taxes is liable to pay accuracy-related penalties, the U.S. Tax Court ruled Monday, after the Eleventh Circuit reversed a previous decision shielding him from the fines.
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April 08, 2024
CPAs Want Treasury To Delay Beneficial Ownership Registry
The U.S. Department of the Treasury should delay enforcement of beneficial ownership information reporting requirements while courts hear cases challenging the Corporate Transparency Act, the American Institute of Certified Public Accountants and 54 state CPA societies said.
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April 08, 2024
IRS Aptly Denied Man's Payment Proposal, Tax Court Says
The U.S. Tax Court sided with the Internal Revenue Service on Monday in finding there had been no abuse of discretion when the agency rejected a "partial pay" installment agreement from a Pennsylvania man.
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April 08, 2024
Tax Court Declines To Stop Clock For Woman's Petition
A Virginia woman who failed to timely dispute a collection action could not prove she was entitled to equitable tolling, the U.S. Tax Court ruled Monday.
Expert Analysis
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Health Issues To Watch In Inflation Act, Other Policy Initiatives
The newly signed Inflation Reduction Act includes a number of significant drug pricing reforms, and the future holds a wider array of health issues that may be addressed in pending legislation when Congress returns in September, says Miranda Franco at Holland & Knight.
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How New Markets Tax Credit Can Help Pandemic Recovery
The New Markets Tax Credit program, designed to spur private investment in low-income, nonmetropolitan and distressed communities, is one potential remedy that can help alleviate the pandemic's negative impact on especially vulnerable areas, says Julia Fendler at Butler Snow.
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Senate Cannabis Bill May Give Some Cos. A Competitive Edge
Though the recently introduced Cannabis Administration and Opportunity Act is unlikely to pass, it provides a bellwether for federal legalization, with a robust regulatory framework that would offer large food and beverage companies a structural advantage and poise multistate cannabis operators for further growth, say attorneys at Perkins Coie.
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Lessons For Federal Lawmakers As Calif. Alters Cannabis Tax
California recently eliminated a cultivation tax that had for years burdened the state’s licensed cannabis market, providing important lessons for federal lawmakers on cumbersome regulations and unduly high taxes as they debate legalization, says Raza Lawrence at Zuber Lawler.
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Tips On Qualified Small Business Stock Exclusions
While awaiting more Internal Revenue Service guidance on the maze of requirements a taxpayer must satisfy for the qualified small business stock exclusion, there are steps proactive taxpayers can take to ensure their ability to establish their qualifications if they are audited, says Stephen Josey at Kostelanetz & Fink.
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Inside The OECD Transfer Pricing Documentation Guidance
Excerpt from Practical Guidance
The Organization for Economic Cooperation and Development's recently modified documentation guidelines can assist tax administrations in developing requirements for transfer pricing risk assessments and evaluations, and help multinational entity taxpayers demonstrate satisfaction of the arm's-length principle, says Neil Aragones at Lexis Tax.
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Superfund Tax Is Back: Implications For Chemical Industry
In light of the Internal Revenue Service's recently issued guidance on the reinstated Superfund tax, manufacturers, producers and importers should review their existing agreements that involve taxable chemicals and substances to determine who will be commercially responsible for the tax, say attorneys at Eversheds Sutherland.
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Tech Co.'s Suit May Create Hurdles For Research Tax Credits
The recently filed U.S. Tax Court case Perficient v. Commissioner — challenging standards under research credit regulations that determine whether research is funded by any grant or contract — could make it difficult to substantiate research tax credits, say Dennis St. Martin and Kevin Benton at Grant Thornton.
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Expected Retirement Law Changes May Spark ERISA Suits
As Congress is poised to pass bipartisan retirement legislation that could bring collective investment trusts and 403(b) plans together and may form a new wave of litigation under the Employee Retirement Security Act, it is helpful to review the important roles that they have played in prior waves of ERISA excessive fee cases, say attorneys at King & Spalding.
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A Close Look At The Decentralized Effort To Tax Digital Assets
Clarity on taxation is one of the biggest hurdles to mass adoption of cryptocurrency, and although digital asset innovation has consistently outpaced worldwide government regulation, recent efforts in the U.S. and elsewhere hint at an emerging standard, says Joshua Smeltzer at Gray Reed.
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Lessons From The SEC's Largest-Ever Audit Firm Penalty
The U.S. Securities and Exchange Commission's recent $100 million settlement over professional test cheating with Ernst & Young — the largest ever in an audit firm case — points to important ramifications for any entity responding to an SEC inquiry, say attorneys at Cleary.
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Navigating The IRS Pre-Audit Retirement Plan Pilot Program
The Internal Revenue Service launched a Pre-Examination Compliance Pilot program for retirement plans last month that gives sponsors and administrators 90 days to self-correct errors and avoid audits, and while several details are unclear, there are important steps to take at this time, say attorneys at Ice Miller.
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Key Takeaways From IRS Reversal On FDII Stance
The Internal Revenue Service's recent memo regarding allocation of deferred compensation expenses for purposes of foreign-derived intangible income is a departure from the agency's previous position and may have implications beyond the context of deferred compensation, say attorneys at Miller & Chevalier.