Federal

  • January 12, 2023

    US Insists It Properly Sued Liberty Global Over $283M In Taxes

    The federal government wasn't required to issue Liberty Global an administrative notice before suing the multinational telecommunications company over $283 million in taxes, the U.S. government told a Colorado federal court, rebutting claims that the lack of a notice kills the case.

  • January 12, 2023

    Tax Season To Start Jan. 23, IRS Says

    The Internal Revenue Service will begin accepting and processing 2022 tax year returns on Jan. 23, the agency said Thursday.

  • January 12, 2023

    Virtual Currency Broker Reporting Rules Pending OMB Review

    Proposed rules for virtual currency sales brokers' information reporting are pending review before a division of the Office of Management and Budget, the office said.

  • January 12, 2023

    IRS Seeks Feedback On Advance Insurance Payment Form

    The Internal Revenue Service said Thursday that it wanted feedback on a form for reporting advance insurance premium payments.

  • January 11, 2023

    Amount B Could Improve Pricing Status Quo, IRS Official Says

    An international agreement to streamline the process for pricing multinational companies' baseline marketing and distribution activities — an approach known as Amount B — could improve the application of the current transfer pricing method for these transactions, an IRS official said Wednesday.

  • January 11, 2023

    Cadwalader Adds Former Cravath Atty To NY Tax Group

    Cadwalader Wickersham & Taft LLP added an attorney from Cravath Swaine & Moore LLP to its tax group in New York, the firm announced.

  • January 11, 2023

    IRS Looks To Fend Off Challenge To Crypto Summons

    A New Hampshire federal court should dismiss a man's revived case challenging an IRS summons seeking information about his cryptocurrency transactions, the agency argued, saying it didn't trample on the man's constitutional privacy rights as he claimed.

  • January 11, 2023

    Developer's $2M Tax, Transfer Fraud Case Sent To Mediation

    A suit from the federal government accusing a real estate developer of owing $2 million in taxes and making fraudulent property transfers was referred to mediation by a Florida federal court.

  • January 11, 2023

    IRS Seeks Input On Employee Plan Filing Extension Form

    The Internal Revenue Service said Wednesday that it wanted comments on a form employers must use to put off the deadline for some plan returns.

  • January 11, 2023

    DC Atty Denies Role In Loss Of $19M From 'Captive' Insurance

    A veteran corporate tax lawyer in Washington, D.C., on Tuesday denied that he played a role in an alleged $19 million rip-off from a "captive" insurance strategy.

  • January 11, 2023

    Mass. Lobbyist Wants Redo In Kickback Case

    A Massachusetts lobbyist wants a new trial or outright acquittal after being convicted as part of a kickback scheme in November, saying there was no evidence to show the payments she made to the former head of the state police union were a quid pro quo.

  • January 11, 2023

    IRS Armed To Bolster Service In 2023, Taxpayer Advocate Says

    The Internal Revenue Service is in a better position to enhance its flagging taxpayer service in 2023 than it has been in recent years, National Taxpayer Advocate Erin Collins said in a report released Wednesday.

  • January 10, 2023

    Texas Oil Co. Calls Off $1.3B Tax Suit Similar To Exxon's

    A Texas oil company asked a federal court Tuesday to dismiss its $1.3 billion tax case, citing Exxon Mobil Corp.'s loss in a similar case in the Fifth Circuit last summer, which will stand because the Texas company says time has run out on an appeal.

  • January 10, 2023

    'Chrisley' Star Can't Kick Ex-Tax Investigator's Defamation Suit

    A Georgia federal judge won't dismiss a former state tax investigator's defamation case against a onetime star of reality TV show ''Chrisley Knows Best,'' saying serving the celebrity at a courthouse on a day he was attending his criminal sentencing was proper.

  • January 10, 2023

    IRS Extends Tax Deadlines For California Storm Victims

    The Internal Revenue Service announced extended deadlines Tuesday for people and businesses affected by the severe storms in California.

  • January 10, 2023

    Atty Gets Priority Over IRS To Legal Services Cash, Court Told

    A lawyer who represented a woman in her civil rights suit against the U.S. Department of Agriculture has priority to nearly $750,000 in legal services compensation over any potential tax claims the IRS might have to that money, the attorney told a Virginia federal court.

  • January 10, 2023

    Father-Son Contractors Get Prison Time For $6M Tax Fraud

    The father-son owners of two Florida construction companies who asked to avoid prison time after pleading guilty to illegally employing workers and failing to pay nearly $6 million in taxes were sentenced to nearly two and nearly three years in prison by a federal judge.

  • January 10, 2023

    Ex-Trump Org CFO Who Implicated Company Gets 5 Mos. Jail

    Longtime Trump Organization Chief Financial Officer Allen Weisselberg was sentenced Tuesday to five months in a New York City jail under the terms of a plea agreement that required him to implicate former President Donald Trump's companies in a tax fraud scheme.

  • January 10, 2023

    Chrisleys Denied Bond In $36M Bank Fraud Case

    Todd and Julie Chrisley of the reality television show "Chrisley Knows Best" must report to federal prison on Jan. 17 to start their sentences of 12 and seven years, respectively, over a $36 million bank fraud scheme and tax evasion, after a Georgia federal judge denied on Tuesday their request for bond pending appeal of their convictions.

  • January 09, 2023

    House GOP Votes To Rescind New IRS Enforcement Funding

    House Republicans voted to repeal some Inflation Reduction Act funding made available to the Internal Revenue Service for enforcement and other purposes late Monday in one of their first moves as the majority in the lower chamber.

  • January 09, 2023

    EV Tax Credit Rules Spell Confusion For Auto Industry

    Consumers scored major incentives under new electric-vehicle tax credits, but the boon for automakers that was forecast is less certain as the Biden administration has yet to clarify regulations governing where battery materials are sourced and where qualifying EVs are ultimately built, experts say.

  • January 09, 2023

    Roberts Warns Narrow Privilege Test Could Strain Courts

    Federal district courts could be strained if the U.S. Supreme Court adopts a narrow test for determining if dual-purpose client communications containing both legal and nonlegal advice are protected under attorney-client privilege, Chief Justice John Roberts said Monday.

  • January 09, 2023

    IRS Launches New YouTube Videos To Help Tribes With Taxes

    The IRS' office of Indian Tribal Governments said it has created three new YouTube videos that can help ITG customers search for online resources available from the IRS, avoid employment tax penalties and know who to phone for information.

  • January 09, 2023

    Republicans Pick Rep. Jason Smith To Lead House Tax Panel

    House Republicans on Monday named Missouri Rep. Jason Smith as the next chairman of the House Ways and Means Committee, elevating a longtime representative to lead the powerful tax-writing panel in the 118th Congress.

  • January 09, 2023

    Couple Can't Claim Real Estate Theft Losses, US Says

    A South Carolina federal court should reject a couple's bid to recoup taxes based on their claims for theft loss deductions, the U.S. government argued, saying there wasn't a theft of their real estate investments as they have alleged.

Expert Analysis

  • 3 Contract Considerations For Renewable Fuels Trade

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    As renewable fuels continue to develop and contracts for their sale and purchase become more common in the energy industry, companies should think about negotiating several key issues when entering into offtake agreements for feedstock purchase transactions, says Nneka Obiokoye at Holland & Knight.

  • What Microcaptive Reporting Ruling May Mean For The IRS

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    In CIC v. Internal Revenue Service, a Tennessee federal court’s decision to set aside an IRS requirement to disclose microcaptive insurance arrangements may be a step toward evidentiary standards to show that the potential for abuse in a lawful transaction is sufficient to support heightened disclosure requirements, says Samuel Lauricia at Weston Hurd.

  • Avoiding Surprise Taxation Of Employment Settlements

    Excerpt from Practical Guidance
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    Sandra Cohen at Cohen & Buckmann discusses how to avoid unwelcome tax-related payments in connection with settling an employment claim, as the extra cost can significantly decrease the perceived value of an offer and push the parties further apart.

  • US Should Leverage Tax Rules To Deter Business With Russia

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    The U.S. should further restrict the flow of resources available for the Putin regime's war in Ukraine by denying U.S. businesses that operate in Russia or Belarus foreign tax credits and global intangible low-taxed income preferences, and by terminating its tax treaty with Russia, says Reuven Avi-Yonah at University of Michigan Law School.

  • Justices Must Apply Law Evenly In Shadow Docket Rulings

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    In recent shadow docket decisions, the U.S. Supreme Court has inconsistently applied the requirement that parties demonstrate irreparable harm to obtain injunctive relief, which is problematic for two separate but related reasons, says David Hopkins at Benesch.

  • Federal Cannabis Bill Needs A Regulatory Plan To Succeed

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    The Marijuana Opportunity Reinvestment and Expungement Act, which was passed by the U.S. House of Representatives on Friday, is laudable but fundamentally flawed because it lacks a robust regulatory plan that would allow for bipartisan support, says Andrew Kline at Perkins Coie.

  • To Capture All Digital Transactions, Tax Rules Must Keep Up

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    Legislative efforts to capture revenue from digital-transaction income can do better than the American Rescue Plan Act, which recently went into effect but employs definitions that have already been surpassed by technology, says Matthew Agramonte at Shutts & Bowen.

  • Lessons From Recent PPP Loan And COVID Fraud Cases

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    Following President Joe Biden's recent pledge to expand enforcement efforts against pandemic and Paycheck Protection Program loan fraud, a look at the U.S. Department of Justice's recent criminal and civil enforcement actions sheds light on its evolving priorities, say Sara Lord and Aaron Danzig at Arnall Golden.

  • Ampersand Clarifies Power Project Placed-In-Service Analysis

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    The Federal Circuit's recent ruling in Ampersand Chowchilla Biomass v. U.S. affirms a lower court's decision regarding when power generation projects were placed in service for federal income tax purposes, but also highlights that the placed-in-service analysis is not one size fits all, say David Burton and Viktoria Vozarova at Norton Rose.

  • Simplifying Tax Issues For Nonresident Athletes In Canada

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    Tax compliance can be particularly challenging for nonresident professional athletes playing in Canada, but as NHL contract negotiations approach a close, it's worth looking at some ways the tax burden can be mitigated, say Marie-France Dompierre and Marc Pietro Allard at Davies Ward.

  • Steps For Universities As DOJ Shifts Foreign Influence Policy

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    Notwithstanding Wednesday's U.S. Department of Justice announcement terminating the initiative targeting Chinese influence and raising the bar for criminal prosecutions, universities should ensure their compliance controls meet new disclosure standards and that they can efficiently respond to inquiries about employees' foreign connections, say attorneys at Covington.

  • How Gold Coin Tax Ruling May Apply To IRA Crypto Holdings

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    The U.S. Tax Court’s recent decision in McNulty v. Commissioner, affirming that a self-directed individual retirement account owner received taxable distributions in taking possession of her IRA’s gold coins, may have troublesome applications for retirement accounts with cryptocurrency holdings, says Luke Bailey at Clark Hill.

  • Why I'll Miss Arguing Before Justice Breyer

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    Carter Phillips at Sidley shares some of his fondest memories of retiring Justice Stephen Breyer both inside and out of the courtroom, and explains why he thinks the justice’s multipronged questions during U.S. Supreme Court oral arguments were everything an advocate could ask for.

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