Federal

  • January 24, 2023

    9th Circ. Affirms Tax Court Can't Grant Refund In IRS Offer

    The Ninth Circuit affirmed a U.S. Tax Court ruling that the specialty court lacked authority to refund a business owner's $80,000 payment to the IRS, saying its jurisdiction over the particular kind of payment was limited.

  • January 24, 2023

    Liberty Global Doubles Down On Bid To Toss $283M Tax Suit

    Multinational telecommunications company Liberty Global Inc. is proceeding with its bid to get the government's $283 million tax suit against it tossed, despite warnings from a Colorado federal court that such a dismissal request would likely be rejected and "builds unnecessary delay into the case."

  • January 24, 2023

    Retired Atty Must Pay IRS $1.7M For Gambling Tax Scam

    A retired Canadian lawyer who admitted he had a gambling addiction owes $1.7 million in restitution to the IRS after he pled guilty to submitting false U.S. tax returns that inflated the withholdings on his jackpot winnings, allowing him to pocket unearned refunds.

  • January 23, 2023

    US Seeks OK For Revised FBAR Fine Against Vineyard Owner

    A California federal court should hold a vineyard owner liable for more than $343,000 in penalties for failing to disclose her overseas bank accounts, the U.S. said, after the IRS recalculated the penalties following a court order.

  • January 23, 2023

    IRS Going To 7th Circ. In Tax Battle Over Tribune's Cubs Sale

    The federal government is pursuing a Seventh Circuit appeal of a U.S. Tax Court decision finding Tribune Media Co. didn't owe tax for 2009 after the IRS sought to increase its liability by nearly $182 million in connection with its sale of the Chicago Cubs.

  • January 23, 2023

    Tax Court Sustains Salesman's Decade Of Deficiencies

    A Maryland insurance salesman failed to prove that income he received from a client over nearly a decade was a loan, the U.S. Tax Court said Monday, sustaining the deficiencies determined by the Internal Revenue Service.

  • January 23, 2023

    Shop Owner Can't Take Mortgage Deduction, Tax Court Says

    The co-owner of jewelry and auto shops cannot deduct mortgage interest of $66,000 for 2012 for Arizona condominiums he claimed to own with his brother because he didn't present evidence he owned the property, the U.S. Tax Court decided Monday.

  • January 23, 2023

    Floridian Urges Court To Deny Gov'ts $18M Repatriation Bid

    A Floridian should be allowed to keep about $18 million overseas while the Eleventh Circuit weighs his appeal against the IRS' penalty calculation for undisclosed Swiss bank accounts, he told a Florida federal court, arguing against the U.S. government's repatriation bid.

  • January 23, 2023

    Appraisal Behind $1.6M Deduction Improper, Tax Court Says

    The appraisal backing up a California couple's $1.6 million deduction for a donation of company units to a charity doesn't meet a statutory requirement for claiming charitable contribution deductions, the U.S. Tax Court said Monday.

  • January 23, 2023

    Court Dismisses Oil Co.'s $1.3B Tax Suit At Co.'s Request

    A Texas federal court dismissed a $1.3 billion tax dispute at the request of the oil company that brought it after ExxonMobil lost a similar case in the Fifth Circuit last year.

  • January 23, 2023

    Tax Court Says Ex-Spouse's Fiscal Control Excuses Woman

    The U.S. Tax Court decided Monday to grant a Californian partial relief from tax debt she incurred with her ex-husband, saying she was entitled to innocent spouse relief because he exerted control over their finances.

  • January 23, 2023

    Unions Urge Biden To Defy EU Threats On EV Tax Credit

    Several unions and nonprofits have urged President Joe Biden to defy the European Union's threats over the Inflation Reduction Act's electric vehicle tax credit by strictly interpreting provisions favoring domestically sourced batteries.

  • January 23, 2023

    IRS Gives Intermediaries Another Month To Renew Agreements

    Qualified intermediaries that want to renew their agreements for 2023 have until May, rather than April, to do so, the Internal Revenue Service said.

  • January 23, 2023

    Gorsuch Dissents Over Justices' Nix Of $3M FBAR Challenge

    The U.S. Supreme Court declined Monday to review a Boston woman's challenge to $3 million in penalties for failing to report her Swiss bank account, but Justice Neil Gorsuch disagreed, saying the U.S. government may have violated the woman's constitutional protection against excessive fines.

  • January 23, 2023

    High Court Won't Take On Texas Atty's Tax Fraud Suit

    The U.S. Supreme Court refused to hear a Texas attorney's fight to escape a conspiracy conviction connected to a client's $1.1 million in unpaid taxes despite his claims that the federal jury didn't receive instructions on how the Internal Revenue Service goes about collections, according to a denial issued Monday.

  • January 23, 2023

    Tax Group Of The Year: Mayer Brown

    Mayer Brown LLP's successful appeal for Fidelity Investments in a closely watched $26 million tax credit dispute was one of several high-profile wins over the past year that earned the firm a spot among Law360's 2022 Tax Groups of the Year.

  • January 23, 2023

    High Court Drops Tax Law Firm's Privilege Case

    The U.S. Supreme Court on Monday dismissed an unnamed law firm's bid for the court to adopt a broad approach in determining whether dual-purpose client communications containing both legal and nonlegal advice are protected under attorney-client privilege.

  • January 20, 2023

    New GOP House Rules Would Make Raising Taxes Harder

    New rules from House Republicans that govern floor debate on tax bills, such as restricting measures that raise income tax rates or requiring more specific cost estimates, reflect new GOP priorities intended to clamp down on spending hikes, tax increases and IRS audits.

  • January 20, 2023

    11th Circ. Affirms Limit On State Tax Cuts Is Unconstitutional

    Thirteen states challenging a provision barring them from using federal coronavirus relief funds to offset revenue reductions such as tax cuts have standing and are correct in claiming the provision is unconstitutional, the Eleventh Circuit said Friday, upholding a district court decision.

  • January 20, 2023

    Court Tosses Microcaptive Summons Suit After IRS Gets Docs

    A Florida federal court dismissed a case Friday seeking to enforce an IRS request for documents from corporate officers for several insurance businesses relating to an agency investigation into microcaptive insurance arrangements after the individuals provided the requested records and emails.

  • January 20, 2023

    Nutrition Co. Drops $10M Accounting Negligence Suit

    A Maryland federal judge approved the dismissal Friday of a nutritional supplements company's lawsuit against its former accounting firm, a complaint the company dropped after having accused the firm of bungling its taxes and causing it to overpay taxes to South Carolina by $10 million.

  • January 20, 2023

    Plumbing Co. Asks Court To Block IRS Microcaptive Notice

    A 2016 IRS notice that requires the disclosure of microcaptive insurance arrangements to the agency should be invalidated because its implementation failed to follow the federal rulemaking process, the owner of a Utah-based plumbing company and several related entities told a federal court.

  • January 20, 2023

    Court Strikes IRS Benefit Guidance Over Admin. Law Violation

    A Michigan federal judge invalidated IRS guidance that required the disclosure of certain potentially abusive employee benefit plans, saying that setting aside the guidance was justified given the Sixth Circuit's decision that found the agency hadn't complied with public comment requirements in issuing it.

  • January 20, 2023

    7th Circ. Judges Scrutinize $11M Tax Ruling In NBA Team Sale

    Seventh Circuit judges questioned a U.S. Tax Court decision blocking a company's $10.6 million ordinary business deduction for the sale of the NBA's Memphis Grizzlies, saying reclassifying the break as a deferred compensation deduction risks eliminating the company's ability to ever claim it.

  • January 20, 2023

    Taxation With Representation: Slaughter and May, Shearman

    In this week's Taxation With Representation, INEOS said it will buy MBCC Group's chemical admixtures business, Spectaire said it agreed to go public by merging with Perception Capital Corp. II, and Shell reached an agreement to acquire Volta.

Expert Analysis

  • High Court Could Resolve Thorny Atty-Client Privilege Issue

    Author Photo

    The U.S. Supreme Court recently granted review in a federal grand jury proceeding that presents a rare opportunity to clarify — and possibly significantly expand — the scope of the attorney-client privilege for complex mixed-purpose communications with counsel, says David Greenwald at Jenner & Block.

  • 2 Tax Decisions Hold Key Transfer Pricing Takeaways

    Author Photo

    Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.

  • Patagonia's Succession Plan Is A Blueprint For Biz Owners

    Author Photo

    While not every business owner is interested in giving their company away to a charitable purpose like Patagonia's founder recently did, the outdoor apparel company's unique situation highlights the considerations that should go into any succession plan, says Abosede Odunsi at Freeborn & Peters.

  • The CHIPS Act: Key Takeaways For Semiconductor Industry

    Author Photo

    The Biden administration’s recently signed CHIPS Act signals that the U.S. is making progress toward bolstering the domestic semiconductor industry, and manufacturers must prepare by understanding the requirements of the act and associated Department of Commerce guidance, say attorneys at Miller & Chevalier.

  • Digital Taxation Is Necessary, But Tough To Manage

    Author Photo

    The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.

  • 5 Considerations When Seeking Federal EV Funding

    Author Photo

    A recent White House fact sheet shows how federal efforts to support the full scope of the electric vehicle industry have moved the needle, but some details about how to use those funds are still being ironed out, and there are a few issues to watch, say attorneys at Morgan Lewis.

  • Unpacking The Inflation Reduction Act's Energy Tax Credits

    Author Photo

    Provisions in the recently enacted Inflation Reduction Act that affect how taxpayers can monetize clean energy tax credits will change how clean energy projects are financed, but taxpayers that may not be allowed multiple credits need to determine which type of credit will be the most advantageous, say attorneys at BakerHostetler.

  • How COVID Has Changed Project Development And Finance

    Author Photo

    Two and a half years into the pandemic, some COVID-19-specific provisions are now common in the project development and finance markets, while others are still undergoing negotiation, say Nate Galer and Katy McNeil at Mayer Brown.

  • Unpacking The Shift In DOJ Corporate Enforcement Policy

    Author Photo

    Attorneys at Paul Hastings provide takeaways for companies seeking to mitigate increased enforcement risks from the U.S. Department of Justice's recent corporate prosecution policy changes, including greater focus on individuals, requirements for cooperation credits, evaluations of prior misconduct, expectations for compliance programs and factors for determining whether to impose a monitor.

  • What AML Bill Could Mean For Firms, Funds And FinCEN

    Author Photo

    If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.

  • How Inflation Reduction Act Will Lift Offshore Wind Projects

    Author Photo

    The Inflation Reduction Act should promote the development of offshore wind energy in multiple ways — including by improving the planning and permitting process for transmission infrastructure, expanding potential lease areas and making beneficial changes to the tax credits available for renewable energy developers, say attorneys at Day Pitney.

  • CORRECTED: New Tax Credits For Renewables Should Offer Investors Relief

    Author Photo

    The Inflation Reduction Act's changes to tax credits for renewable energy projects should finally liberate tax equity investors from the restraints of the complex and onerous federal anti-abuse regime, says Kay Hobart at Parker Poe. Correction: Because of an editing error, a previous version of this article incorrectly characterized tax enforcement regimes in North Carolina and other states. This error has been corrected.

  • Inflation Reduction Act A Boon To Hydrogen, Carbon Capture

    Author Photo

    The Inflation Reduction Act's tax credits and direct payments, extension of existing renewable electricity subsidies, and other benefits will accelerate hydrogen and carbon capture projects across the U.S. — and will likely draw capital into the country that would otherwise have gone to projects elsewhere, say attorneys at Shearman.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.