Federal

  • December 21, 2022

    From Jan. 6 To Taxes, 'Tis The Season For Trump Probes

    A House select committee's criminal referral of Donald Trump for his role in the Jan. 6 attack on the U.S. Capitol adds to a growing list of potential legal woes for the ex-president, whose tax returns will be laid bare as he faces investigations and potential liabilities on many different fronts as 2022 ends.

  • December 21, 2022

    Liberty Global Seeks Toss Of $283M Tax Avoidance Suit

    The federal government's $283 million tax suit against multinational telecommunications company Liberty Global is dead on arrival because the Internal Revenue Service never issued a required deficiency notice, the company told a Colorado federal court.

  • December 21, 2022

    Top International Tax Policies Of 2022

    Sweeping U.S. tax legislation enacted this year gave companies new compliance burdens in the form of an alternative minimum tax while failing to align what is arguably an existing minimum tax on offshore income with a broader international overhaul. Here, Law360 breaks down key tax policy developments that affected U.S. multinationals in 2022.

  • December 21, 2022

    K&L Gates Adds Longtime McDermott Tax Atty In DC

    K&L Gates LLP has added a former McDermott Will and Emery LLP tax and energy attorney who spent more than two decades at her former firm before joining K&L Gates, the firm announced Wednesday.

  • December 21, 2022

    Fla. Father Sentenced To 14 Years For $6M Tax Fraud Scheme

    A Florida father of six who pled guilty to helping his wife swindle nearly $6 million from the IRS by filing fake tax returns over the course of a decade was sentenced to 14 years in prison by a federal judge.

  • December 21, 2022

    Treasury Floats Relief For Foreign Partnership Transfers

    Brokers who engage in transfers of interest in publicly traded partnerships organized outside the U.S. may be able to presume that certain transactions won't require withholding tax obligations, according to guidance published Wednesday by the Internal Revenue Service.

  • December 20, 2022

    House Panel Votes To Make Trump's Tax Returns Public

    The House Ways and Means Committee voted Tuesday to publicly release former President Donald Trump's tax returns, ending a multiyear effort by congressional Democrats to shed light on Trump's business dealings just weeks before Republicans take over committee leadership in January.

  • December 20, 2022

    Tax Court Throws Out Farm Biz's Bad Debt Deduction

    The Internal Revenue Service properly disallowed an agriculture and horse-breeding business's roughly $227,000 bad debt deduction related to a loan it made to another company, the U.S. Tax Court said Tuesday, finding the debt wasn't valid.

  • December 20, 2022

    IRS Releases Figure For Surprise Health Care Bill Calculation

    The Internal Revenue Service released a notice Tuesday providing an increase percentage reflecting a rise in consumer prices for the purposes of calculating certain out-of-network health care coverage for 2023 under legislation that barred surprise medical bills.

  • December 20, 2022

    IRS Would Get $275M Cut Under $1.7T Spending Bill

    The Internal Revenue Service would receive $12.3 billion in funding for fiscal 2023, a $275 million reduction, and get more authority to crack down on potentially abusive conservation easement transactions under Congress' $1.7 trillion omnibus spending package unveiled Tuesday.

  • December 20, 2022

    Materials Co. Asks Treasury To Clarify Semiconductor Credit

    The U.S. Department of the Treasury should clarify that a 25% tax credit for facilities involved in semiconductor manufacturing includes those that produce components required for making semiconductors, a science materials company said in an email released Tuesday.

  • December 20, 2022

    National Grid Seeks Dismissal Of Solar Cos.' Tax Suits

    Electric giant National Grid asked federal courts in Massachusetts and New York on Tuesday to dismiss proposed class actions accusing it of illegally charging solar energy companies for taxes to connect to its grid, saying National Grid can't be held accountable for its subsidiaries.

  • December 20, 2022

    Ill. Revenue Dept. Head Named To National Tax Group's Board

    The Federation of Tax Administrators has elected the director of the Illinois Department of Revenue to the organization's board of trustees, the department announced Tuesday.

  • December 20, 2022

    Greenberg Adds State And Local Tax Pro From Eversheds

    Greenberg Traurig LLP has recruited a former Eversheds Sutherland partner experienced in state and local tax and government relations to work out of its offices in Portland, Oregon, and Sacramento, California, the firm announced.

  • December 20, 2022

    Arnold & Porter To Promote 12 Partners, 9 Counsel In 2023

    Arnold & Porter will promote 12 attorneys to partner and a range of other attorneys to new roles in 2023, the firm announced Monday.

  • December 20, 2022

    3rd Circ. Rehearing Sought In Fight Over $833K Tax Bill

    A taxpayer who the Internal Revenue Service says owes $833,000 in nearly three decades' worth of unpaid taxes asked the Third Circuit to rehear his case, saying the panel wrongly decided his Supreme Court petition extended the government's time to collect.

  • December 20, 2022

    Retirement Bill Included In Sweeping $1.7T Spending Package

    Congress tucked a major retirement policy overhaul into the $1.7 trillion omnibus spending package introduced Tuesday, meaning the legislative package known as Secure 2.0 could get signed into law this week as part of the framework for funding the government.

  • December 19, 2022

    Initial Corp. AMT Guidance Due By Year-End, Treasury Says

    Initial guidance for significant tax provisions created or modified under the Inflation Reduction Act — including the corporate alternative minimum tax — will be released by the end of the year, the U.S. Department of the Treasury announced Monday.

  • December 19, 2022

    US Chamber Says Regs May Block Credits For Brazil's Taxes

    New federal regulations could keep U.S. companies from being credited for income taxes paid to Brazil due to discrepancies in the countries' transfer pricing practices, the U.S. Chamber of Commerce warned.

  • December 19, 2022

    IRS Provides Safe Harbor For Green Jet Fuel Tax Credit

    The IRS provided a safe harbor Monday for claiming a green jet fuel tax credit, allowing the use of calculations based on guidance from a global air transportation organization to determine the greenhouse gas offsets achieved for purposes of qualifying for the credit.

  • December 19, 2022

    Calif. Car Dealer Can't Deduct Hotel Stays, Tax Court Says

    A California car dealership manager who earned nearly $300,000 in 2017 cannot deduct commuting and business expenses, including $40,000 worth of hotel stays, as though he were a business owner, the U.S. Tax Court said Monday.

  • December 19, 2022

    IRS Supervisor Timely Approves Penalties, Tax Court Says

    An Internal Revenue Service supervisor timely approved accuracy penalties against a California couple despite later changes to the penalties, the U.S. Tax Court said Monday.

  • December 19, 2022

    Tax Court Says NY Man Missed Chance To Fight $44K Liability

    A New York man owes more than $44,000 in tax deficiencies for 2015 and 2016 because he missed his chance to challenge them, the U.S. Tax Court said Monday.

  • December 19, 2022

    Tax Court Rejects Couple's $2.1M Conservation Deduction

    A couple who donated 41 acres of conservation land to a Georgia county government cannot deduct $2.1 million in carryover charitable contributions for 2007 because the deed sealing the deal lacked a provision certifying the agreement, the U.S. Tax Court said Monday.

  • December 19, 2022

    Top International Tax Cases Of 2022

    This year, courts weighed in on key transfer pricing topics, including a decision that confirmed the application of contract law to advance pricing agreements and another ruling that took a unique path in finding an arm’s-length division of intercompany profits. Here, Law360 breaks down major international tax decisions issued in 2022.

Expert Analysis

  • Justices Open The Door Wider For Donor Info Law Challenges

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    The U.S. Supreme Court’s recent decision in Americans for Prosperity Foundation v. Bonta, striking down California's requirement that charities disclose the identity of major donors, will make similar state and federal statutes more vulnerable to constitutional challenge, says Lloyd Mayer at Notre Dame Law School.

  • IRS Extension Is Partial Relief For Renewable Energy Projects

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    The Internal Revenue Service’s recent extension of the start-of-construction safe harbor for renewable-energy projects is welcome relief for solar companies unable to benefit from previous extensions, but it is still unclear whether a project that exceeds the deemed continuity period qualifies for a tax credit if it cannot prove continuous work, says David Burton at Norton Rose.

  • Justices Should Find California Donor Law Unconstitutional

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    The U.S. Supreme Court's decision in Americans for Prosperity Foundation v. Bonta should strike down a California law requiring charities to disclose their donors because the state’s interest in this information is not sufficiently compelling to overcome constitutional rights to free speech and peaceful assembly, says James Skyles at Skyles Law Group and M2M Legal.

  • 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.

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