Federal

  • January 20, 2023

    Tax Group Of The Year: Latham

    Latham & Watkins LLP's tax practice guided medical records giant Cerner in its $28.3 billion acquisition by Oracle and helped secure a U.S. Supreme Court win in a law firm's day-late challenge to an Internal Revenue Service levy, exemplifying its strengths in both transactional tax and tax controversy, and earning it a spot on Law360's 2022 Tax Groups of the Year.

  • January 20, 2023

    IRS Seeks Comments On Split Interest Trust Reporting Form

    The Internal Revenue Service said Friday that it is seeking comments on a form for reporting a split interest trust's financial activities.

  • January 20, 2023

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin, which included proposed rules for the witnessing of spousal consent elections which allow it to be done remotely.

  • January 19, 2023

    11th Circ. Affirms 18 Years For Bank Fraud, False Tax Return

    The Eleventh Circuit affirmed the reduced 18-year prison sentence of a man who claimed to be a Hindu priest and was convicted of dozens of crimes including filing a false tax return, saying Thursday that a lower court correctly followed its remand instructions.

  • January 19, 2023

    4th Circ. Says ACA Payment Is Tax For Bankruptcy Purposes

    The Affordable Care Act's charge levied on people who lacked minimum health coverage counts as a tax that takes priority over other claims in the bankruptcy process, a split Fourth Circuit panel said Thursday, reversing a decision by a North Carolina federal court.

  • January 19, 2023

    Taiwan Continues To Press For Tax Treaty With US

    The president of Taiwan reiterated the self-governing island's desire for a tax treaty with the U.S. at a meeting with U.S. lawmakers, according to her office.

  • January 19, 2023

    US Asks Full 6th Circ. To Rethink Barring ARPA Tax Restraints

    The entire Sixth Circuit should rehear a case in which a panel ruled that the federal government can't enforce a provision barring Tennessee from using federal coronavirus relief funds to offset revenue reductions such as tax cuts, the Treasury Department said.

  • January 19, 2023

    IRS Beats Microsoft's FOIA Suit Over 15-Year Audit

    The IRS adequately searched for documents on its 15-year audit of Microsoft while justifying exemptions to disclosure requirements for withheld files, a Washington federal judge ruled, tossing the tech giant's case seeking records under the Freedom of Information Act.

  • January 19, 2023

    Firm's Bid To Nix $1.5M Alter Ego Levy Is Too Early, Feds Say

    A Maryland federal court should reject a law firm's premature bid for summary judgment in its suit challenging an IRS levy that froze $1.5 million of its funds to collect taxes owed by what the government claims is the firm's alter ego, the U.S. government argued.

  • January 19, 2023

    10th Circ. Revives Fraud Penalty For Tax Evasion Convict

    An ex-prisoner who was visited by an IRS agent while serving time for tax evasion in Colorado cannot avoid fraud penalties on the grounds that the agent's penalty proposal lacked the required supervisory approval, the Tenth Circuit said Thursday, reversing a U.S. Tax Court decision. 

  • January 19, 2023

    Tax Group Of The Year: Eversheds Sutherland

    Eversheds Sutherland secured several significant tax victories in 2022, including convincing a judge to side with Comcast and Verizon to invalidate Maryland's first-in-the-nation digital advertising tax and winning Sirius XM a $2.5 million Texas franchise tax refund, earning it a spot on Law360's 2022 Tax Groups of the Year.

  • January 19, 2023

    IRS Grants Extensions To Storm Victims In Ga., Ala.

    Taxpayers impacted by storms in some counties in Georgia and Alabama now have until May 15 to submit some returns and payments, the Internal Revenue Service said Thursday.

  • January 19, 2023

    FinCEN To Raise Bank Secrecy Penalties

    The U.S. Treasury Department Financial Crimes Enforcement Network announced final rules that will increase civil monetary penalties for violating the Bank Secrecy Act to account for inflation.

  • January 18, 2023

    Accountant Agrees To Pay $3.5M In Easement Case Plea Deal

    A Florida accountant pled guilty Wednesday to illegally selling tax deductions to his clients in the form of conservation easements and agreed to pay nearly $3.5 million in restitution to the Internal Revenue Service in a New Jersey federal court.

  • January 18, 2023

    Groups Tell Biden Not To Back Down To EU Trade Threats

    Five groups sent a letter to the Biden administration on Wednesday saying it shouldn't back down to European Union trade threats and should implement the Inflation Reduction Act of 2022 as intended and without delays or changes that could undermine historic clean energy investments.

  • January 18, 2023

    Full Business Meal Deduction Expired In 2022, JCT Says

    Several tax provisions expired at the end of last year, including the full deduction for business meals provided by a restaurant, according to a report released Wednesday by the Joint Committee on Taxation.

  • January 18, 2023

    IRS Seeks Input On Superfund Tax List Addition

    The Internal Revenue Service on Wednesday announced a requested addition to the list of taxable substances for purposes of the Superfund chemical tax and asked for feedback on the addition.

  • January 18, 2023

    Any US Plans For Global Minimum Tax On Ice, For Now

    Legislative opportunities for the U.S. to conform with new international minimum tax rules aren't likely to emerge for a few years, when the expiration of domestic tax cuts may coincide with the foreign taxation of U.S. multinationals under the global regime.

  • January 18, 2023

    Youth Nonprofit's Ex-CEO Admits Stealing, Lying On Taxes

    The ousted CEO of a shuttered Hollywood nonprofit that aimed to alleviate child poverty in hard-pressed Los Angeles neighborhoods pled guilty to embezzling from the organization, misusing $600,000 in federal grants, and hiding income by lying on his tax returns.

  • January 18, 2023

    11th Circ. Rejects Virus Defense, Upholds Ban On Tax Preparer

    A Georgia tax return preparer can't get around an injunction barring him from the industry after the Eleventh Circuit found that the pandemic wasn't a sufficient excuse for his months-late response to a suit from the federal government.

  • January 18, 2023

    Court Warns Liberty Global It Won't Dismiss $283M Tax Suit

    Multinational telecommunications company Liberty Global is likely to fail in its effort seeking dismissal of a $283 million suit by the federal government alleging that the company tried to avoid paying U.S. tax on income, a Colorado federal court said.

  • January 18, 2023

    Tax Group Of The Year: Akerman

    Akerman LLP's tax practice group has been involved in major decisions across the country over the past year, including successfully arguing that Massachusetts couldn't tax the capital gains of a company domiciled in another state and that a Target subsidiary isn't liable for Florida income tax, earning the firm a spot among Law360's 2022 Tax Groups of the Year.

  • January 18, 2023

    IRS Sets 2023 First-Year Vehicle Deduction Limit At $20.2K

    The depreciation deduction limit for passenger vehicles eligible for an additional deduction and placed in service in 2023 is $20,200 for the first tax year, the Internal Revenue Service said Wednesday.

  • January 18, 2023

    IRS Appoints 9 Members To Advisory Council

    The Internal Revenue Service appointed nine members to its advisory council to serve three-year terms starting this month, the agency said Wednesday.

  • January 17, 2023

    9th Circ. Won't Revive Fired IRS Worker's Bias Suit

    The Ninth Circuit refused Tuesday to reinstate a former Internal Revenue Service employee's age and national origin bias suit, saying she failed to persuade the court that discrimination played a role when she was fired for violating internal policy.

Expert Analysis

  • What The Inflation Reduction Act Has To Do With Crypto

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    The recently enacted Inflation Reduction Act’s $80 billion supplemental funding allotment for the IRS could have unexpectedly significant implications for the cryptocurrency market, which may find itself the target of ramped-up tax audits and enforcement, says cybersecurity consultant John Reed Stark.

  • Unpacking The New Stock Buyback Tax And Its Exceptions

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    Xenia Garofalo and Kyle Colonna at Eversheds Sutherland discuss provisions of the recently enacted tax on corporate stock repurchases, how its exceptions may be applied and what companies should consider when evaluating the cost of new or existing programs.

  • Health Issues To Watch In Inflation Act, Other Policy Initiatives

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    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.

  • How New Markets Tax Credit Can Help Pandemic Recovery

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    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.

  • Senate Cannabis Bill May Give Some Cos. A Competitive Edge

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    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.

  • Lessons For Federal Lawmakers As Calif. Alters Cannabis Tax

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    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.

  • Tips On Qualified Small Business Stock Exclusions

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    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.

  • Inside The OECD Transfer Pricing Documentation Guidance

    Excerpt from Practical Guidance
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    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.

  • Superfund Tax Is Back: Implications For Chemical Industry

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    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.

  • Tech Co.'s Suit May Create Hurdles For Research Tax Credits

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    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.

  • Expected Retirement Law Changes May Spark ERISA Suits

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    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.

  • A Close Look At The Decentralized Effort To Tax Digital Assets

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    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.

  • Lessons From The SEC's Largest-Ever Audit Firm Penalty

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    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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