Federal

  • 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.

  • December 19, 2022

    Feds Tell Justices To Reject 'Supersized' Privilege Test

    Communications including both legal and nonlegal advice should not be shielded from grand jury subpoenas by a "supersized" attorney-client privilege unless their primary purpose is legal aid, the federal government told the U.S. Supreme Court.

  • December 19, 2022

    House Bill Floats Payroll Credit For COVID-Affected Eateries

    A bill introduced in the U.S. House of Representatives would establish a tax credit offsetting payroll taxes for restaurants affected by the COVID-19 pandemic.

  • December 19, 2022

    Man's Tax Offset Challenge Correctly Tossed, 9th Circ. Told

    A California federal court correctly dismissed a man's lawsuit challenging the U.S. Department of the Treasury's use of his tax overpayments to offset his past-due child support, the federal government told the Ninth Circuit.

  • December 19, 2022

    9th Circ. Backs Rejection Of Paralegal's Deductions

    The owner of a paralegal and notary business in Nevada cannot claim income deductions for charitable and business activities that she failed to substantiate with documentation, the Ninth Circuit said, upholding a U.S. Tax Court decision.

  • December 19, 2022

    9th Circ. Affirms Tax Court's $10K Frivolous-Lawsuit Fine

    A Montana man who has raised tax-protester arguments before the U.S. Tax Court 20 times since 1983 waived his right to challenge his tax bill because he did not address a $10,000 fine against him for filing a frivolous lawsuit, the Ninth Circuit said.

  • December 16, 2022

    US Official Says Global Min. Tax Guidance Must Address GILTI

    The OECD's upcoming guidance for an international minimum tax agreement must include coordination rules regarding the U.S. measure for global intangible low-taxed income, which doesn't share the global regime's country-by-country framework, a U.S. Treasury Department official said Friday.

  • December 16, 2022

    CPAs Call For Raising Reporting Threshold For Card Payments

    Congress should walk back new sales reporting requirements for online platforms dealing in credit and debit card payments before tax filing season starts, the American Institute of Certified Public Accountants said Friday, saying the new, lower threshold of $600 will create confusion among taxpayers.

  • December 16, 2022

    Departing Treasury Official Criticizes UN Steps On Int'l Tax

    Countries in the United Nations that recently took steps to consider a bigger role in shaping international tax policy should suspend their efforts and contribute to the ongoing project at the Organization for Economic Cooperation and Development, a departing U.S. Treasury Department official said Friday.

  • December 16, 2022

    Pension Plan Segment Rates Rise In Dec.

    Segment rates for calculating pension plan funding rose in December, the Internal Revenue Service said Wednesday.

  • December 16, 2022

    House Tax Committee To Meet On Trump's Tax Returns

    The House Ways and Means Committee is scheduled to meet next week to consider former President Donald Trump's tax returns, according to a notice Friday.

  • December 16, 2022

    Watchdog's Bid For Trump Tax Whistleblower Docs Tossed

    A D.C. federal court tossed a watchdog's lawsuit seeking Treasury records dealing with its response to an Internal Revenue Service whistleblower's allegation of interference in the agency's audit processes for former President Donald Trump's tax returns, saying the agency sufficiently searched for the documents.

  • December 16, 2022

    Chinese Investor Can't Halt Arbitration In $3M Fraud Dispute

    A California federal judge denied a Chinese investor's request to stop arbitration proceedings relating to his claims that he was the victim of a $3 million tax scheme, saying there are still questions about whether he participated willingly in a contract he claimed was fraudulent.

  • December 16, 2022

    IRS Backlogs Led To Poor Customer Service, GAO Says

    Backlogs and hiring challenges at the Internal Revenue Service led to poor customer service and delays in refunds, the U.S. Government Accountability Office said in a report released Friday.

  • December 16, 2022

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service on Friday released its weekly bulletin, which included guidance for employee retirement plans as well as new interest rates on underpayments and overpayments of taxes.

  • December 16, 2022

    Ex-Iowa Tax Director Named IRS Taxpayer Experience Officer

    The former director of the Iowa Department of Revenue has been named the deputy chief of the Taxpayer Experience Office at the Internal Revenue Service, the agency announced Friday.

  • December 16, 2022

    Taxation With Representation: Wachtell, Davis Polk, Cravath

    In this week's Taxation With Representation, M3-Brigade Acquisition III Corp. will merge with Greenfire, Southwest Gas will sell MountainWest Pipelines, and Weber will be taken private.

  • December 16, 2022

    Surveys, Awards & More: Law360's 2023 Editorial Calendar

    Law360 publishes several award series throughout the year, including ones that highlight top-performing attorneys and practice groups. Here, find all you need to know about our awards and surveys, including due dates, FAQs, and the questions we'll ask so you can prepare ahead of time.

  • December 15, 2022

    FinCEN To Propose Beneficial Owner Registry Access Rules

    The U.S. Treasury Department's financial crimes unit said Thursday it plans to propose rules spelling out when governments and financial institutions may be granted access to so-called beneficial ownership information, following related final rules the unit issued in September.

  • December 15, 2022

    IRS Urges Tax Court To Rethink Nixing Of Easement Notice

    The U.S. Tax Court should reconsider a decision striking down a notice requiring the disclosure of potentially abusive conservation easement transactions, the IRS said, saying the court overlooked the agency's arguments that Congress permitted it to issue such guidance without public feedback.

  • December 15, 2022

    Corp. AMT Guidance May Arrive This Year, Official Says

    The U.S. Treasury Department may issue guidance for the new 15% corporate alternative minimum tax this year, an official said Thursday, noting that the department is trying to prioritize issues that will help more taxpayers sooner.

  • December 15, 2022

    US Asks 5th Circ. To Lift Block On ARPA Tax Cut Limit

    The Fifth Circuit should throw out an injunction that blocks a provision in federal law preventing Texas, Louisiana and Mississippi from using COVID-19 aid to fund tax cuts, the U.S. Department of the Treasury said Thursday.

  • December 15, 2022

    Global Min. Tax Violates Treaties, GOP Lawmakers Say

    Congressional Republicans criticized President Joe Biden's administration for acceding to a backstop to the 15% minimum tax under an international agreement to overhaul the global tax system, telling Treasury that the provision violates current treaties and hurts U.S. companies.

  • December 15, 2022

    Hiring A Priority As IRS Solidifies Funding Plans, Official Says

    The Internal Revenue Service is working to solidify details regarding how it will spend its nearly $80 billion funding boost, and a significant portion will be used for hiring, the agency's acting commissioner said Thursday.

Expert Analysis

  • Justices' Nod To Preemptive Tax Challenges May Caution IRS

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    The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service, allowing pre-enforcement challenges of tax reporting rules despite the Anti-Injunction Act, is likely to make the U.S. Department of the Treasury more careful about its own compliance obligations under the Administrative Procedure Act, says Robert Carney at Caplin & Drysdale.

  • Let's End The Offshoring Of US Patents

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    Congress should work toward removing the loophole that allows companies to avoid U.S. taxes by moving their patents offshore, and ensure profits are taxed where the sales take place, says Sen. Patrick Leahy, D-Vt.

  • How Biden's First 100 Days Will Affect Gov't Contractors

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    Joseph Berger and Thomas Mason at Thompson Hine examine the significant opportunities for government contractors arising from actions during the first 100 days of the Biden administration, which set the stage for unprecedented investment in national infrastructure, domestic manufacturing, research and development, clean energy, pandemic response and economic recovery.

  • Addressing New COBRA Duties Under Virus Relief Law

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    Following the issuance of fully subsidized COBRA premiums for certain workers under the recently passed American Rescue Plan Act, employers should take steps to determine who is eligible, ensure additional notice requirements are satisfied, and train human resources on communicating with qualified individuals, say Randi May and Dustin Grant at Hoguet Newman.

  • Long Road Ahead For Biden's Individual Tax Hike Proposal

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    Dustin Stamper at Grant Thornton provides insight into President Joe Biden's recently proposed individual tax increases to pay for his American Families Plan, and explains how competing interests among congressional Democrats and Republicans may shape the final provisions and prolong their implementation.

  • What Value-Added Tax Might Look Like In The US

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    Christiaan Van Der Valk and Charles Maniace at Sovos consider the value-added tax, a primary source of revenue for many countries, and what it might mean for the U.S. were it implemented to raise funds for large-scale federal initiatives such as President Joe Biden's infrastructure plan.

  • New Markets Credit Will Aid Recovery In Low-Income Areas

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    The recently extended New Markets Tax Credit is a critical tool for economic development in low-income communities, which have been hit especially hard by the pandemic, so public finance attorneys should consider its benefits when advising clients on projects, says Julia Fendler at Butler Snow.

  • The International Outlook For US Border Carbon Adjustments

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    The Biden administration may see enacting a border carbon adjustment system as a good way to advance climate goals and protect domestic industries and jobs, but any such plan must take into account the need to respect existing international trade agreements, say attorneys at Akin Gump.

  • The Domestic Landscape For US Border Carbon Adjustments

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    With the Biden administration possibly eyeing border carbon adjustments on imported goods as a means to mitigate climate change, attorneys at Akin Gump discuss such policies' potential benefits to domestic businesses, and the political and technical challenges to their enactment in the U.S.

  • Prepare For Global Collaboration In Crypto Tax Enforcement

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    Recent Internal Revenue Service victories involving John Doe summonses served on cryptocurrency exchanges — and statements by the Joint Chiefs of Global Tax Enforcement about global collaboration in cryptocurrency-related tax investigations — should prompt assessment of prior virtual currency transactions and remediation before an enforcement agency shows up at the door, say attorneys at McDermott.

  • 10 Things to Know About US Competent Authority Assistance

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    Taxpayers should consider seeking U.S. competent authority assistance to help eliminate double taxation from a transfer pricing adjustment, especially now that the competent authorities are resolving cases virtually and more quickly, say attorneys at Thompson & Knight.

  • Lessons From Tax Court's Nixing Of Investor's Energy Credits

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    The U.S. Tax Court's recent ruling in Olsen v. Commissioner, the first of 200 cases involving individual taxpayers who invested in a tax shelter involving solar equipment, is a case study in how not to structure an energy tax credit investment, says David Burton at Norton Rose.

  • Partial Repeal Could Resolve Biden's SALT Cap Dilemma

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    Lawmakers' calls to repeal the cap on federal deductions for state and local taxes are controversial because doing so could cost over $600 billion, but a partial repeal could be accomplished on a revenue-neutral basis, providing relief to some, if not most, affected taxpayers, says Joseph Mandarino at Smith Gambrell.

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