Federal

  • February 02, 2024

    Google, H&R Block Ask Court To Toss Tax Data RICO Suit

    Google and H&R Block asked a California federal court to toss a suit accusing them of scheming to intercept the private data of a man who used H&R Block's tax preparation software, saying there was no evidence the companies conspired.

  • February 02, 2024

    Eaton Asks Court To Agree To Block IRS Summons

    Multinational power management company Eaton Corp. urged an Ohio federal court to adopt a magistrate judge's recommendation to allow the company to buck an IRS summons for confidential performance evaluations of its foreign employees, saying the government's objection underplays the documents' sensitivity.

  • February 02, 2024

    Texas Man Owes Tax On $307K After 'Frivolous' Claims Fail

    More than $307,000 of a Texas man's 2018 income is subject to tax, the U.S. Tax Court ruled Friday, calling his arguments against being taxed "frivolous."

  • February 02, 2024

    Filing Return Unnecessary For Govt. Trust, IRS Rules

    An unnamed trust is not required to file an income tax return because its income accrues to the government of a U.S. territory, the Internal Revenue Service said in a private letter ruling released Friday.

  • February 02, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin Friday, which included guidance on pension-linked emergency savings accounts.

  • February 02, 2024

    Taxation With Representation: Simpson, Wachtell Lipton

    In this week's Taxation With Representation, Rise Growth Partners receives a $250 million investment, a group of investors led by Carlyle Group co-founder David Rubenstein acquires a controlling stake in MLB's Baltimore Orioles, The Cigna Group sells multiple Medicare businesses to Health Care Service Corp., and WillScot Mobile buys McGrath RentCorp.

  • February 01, 2024

    GOP AGs Press Treasury To Halt IRS Direct File Program

    The U.S. Department of the Treasury should stop the Internal Revenue Service's direct file pilot program because it is unconstitutional and unnecessary, 13 Republican attorneys general told Treasury Secretary Janet Yellen in a letter.

  • February 01, 2024

    Kemp Klein Brings On Tax Attorney From Foster Swift

    Kemp Klein Law Firm said Thursday that it added a shareholder to its team who was formerly with Foster Swift Collins & Smith PC and counsels clients in tax planning.

  • February 01, 2024

    IRS Violated Rights In Coinbase Doc Seizure, 1st Circ. Told

    The IRS violated an investor's property rights when it seized his financial records from the cryptocurrency exchange Coinbase, he told the First Circuit on Thursday, saying the government defended the violation by wrongly focusing on what it claims are the investor's lack of privacy protections.

  • February 01, 2024

    Biden Names 3 Tax Court Nominees

    A senior staffer at the Joint Committee on Taxation and an Internal Revenue Service attorney are two of three public servants President Joe Biden picked as nominees to the U.S. Tax Court, the White House announced Thursday.

  • February 01, 2024

    Texas Couple Can't Deduct $1M In Premiums, Tax Court Rules

    A Texas couple who bought insurance policies from agencies controlled by themselves cannot deduct more than $1 million in premiums, the U.S. Tax Court ruled Thursday.

  • February 01, 2024

    Ex-Trump Org. CFO Faces Possible Perjury Charge, Mulls Plea

    Donald Trump's longtime top financial officer Allen Weisselberg is in plea negotiations related to potential perjury charges stemming from his testimony in the New York attorney general's civil fraud trial, according to a source familiar with the matter.

  • February 01, 2024

    US Won't Ask Justices To Review States' Win In ARPA Row

    The U.S. Treasury Department opted not to appeal an Eleventh Circuit ruling in favor of 13 states that challenged the American Rescue Plan Act's limitations on using federal pandemic aid to pay for tax cuts, the agency said in a letter disclosed Thursday.

  • February 01, 2024

    Justices Asked To Stop Trustee From Recovering Taxes

    The federal government asked the U.S. Supreme Court to stop the bankruptcy trustee of a Utah company from being allowed to recoup federal tax payments, saying the issue is the subject of a growing circuit split and stands to deplete the federal purse illegally.

  • February 01, 2024

    House Panel Readies 2023 SALT Cap Relief Bill

    Proposed legislation that would raise the cap on state and local tax deductions for 2023 for married couples with adjusted gross incomes below $500,000 advanced to the full House of Representatives on Thursday following a House panel vote.

  • February 01, 2024

    NYC Music Venue Gets 'Last Shot' At Ch. 11 Reorg

    A New York bankruptcy judge Thursday gave a New York City music venue what he said was one last chance to get caught up on its state and federal back taxes before it faces a conversion of its Chapter 11 reorganization to a liquidation.

  • January 31, 2024

    House Sends Bipartisan Tax Break Package To Senate

    The House of Representatives passed a bipartisan bill Wednesday night that would extend the full tax break for research and development costs and expand the child tax credit for multiple years, sending the deal to the Senate for consideration.

  • January 31, 2024

    Estate, Wife Owe Gift Tax On Sale To Son, Tax Court Says

    The estate of the former president of an aerospace parts company, and his wife, owe gift taxes in connection with the couple's sale of company shares to their son, the U.S. Tax Court ruled Wednesday.

  • January 31, 2024

    Serbian Dual Citizen Must Pay $5.3M FBAR Penalty

    A man with dual citizenship in the U.S. and Serbia will have to pay $5.3 million in penalties and interest for willful failure to report a Swiss bank account, according to a judgment a New York federal judge issued Wednesday.

  • January 31, 2024

    Feds Urged To Adopt EV Battery Tracing For Tax Credit Rules

    A mechanism to trace the source of battery materials in electric vehicles would help enforce manufacturers' compliance with the domestic content requirements that are now linked to the EV consumer tax credit, stakeholders told U.S. Treasury Department and IRS officials Wednesday.

  • January 31, 2024

    Ex-Ga. Tech Prof Gets Home Confinement For Tax Fraud

    A former Georgia Institute of Technology professor was sentenced to a year of home confinement and three years' probation on Wednesday for shirking hundreds of thousands of dollars in federal taxes by inflating his charitable deductions through a scheme involving Chinese nationals' donations to the university.

  • January 31, 2024

    GILTI Succeeds While FDII, BEAT Struggle, Think Tank Says

    The three main international tax provisions of 2017's Tax Cuts and Jobs Act — GILTI, FDII and the BEAT — have had mixed success, but lawmakers should be careful to retain the beneficial parts while considering any changes to better fit into the global tax structure, the Tax Foundation said Wednesday.

  • January 31, 2024

    Eyewear Seller Owes For Unreported Income, Tax Court Says

    An eyewear seller must pay nearly $85,000 after failing to dispute claims of unreported gross income, the U.S. Tax Court ruled Wednesday.

  • January 31, 2024

    Senate Tax Panel Approves Biden's IRS Chief Counsel Pick

    The Senate Finance Committee approved President Joe Biden's pick for chief counsel of the Internal Revenue Service on Wednesday, sending her nomination to the full Senate for consideration.

  • January 31, 2024

    Calif. Says FDIC Owes Signature Bank's Unpaid Taxes

    California's state tax collection agency asked a New York federal court to force the Federal Deposit Insurance Corp. to pay five years' worth of unpaid taxes on behalf of the shuttered Signature Bank, saying the FDIC is responsible for the debt as the bank's receiver.

Expert Analysis

  • Cases Show Real-World Laws Likely Apply In Metaverse

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    Although much has been written about the so-called unprecedented legal issues raised by the metaverse, recent federal cases demonstrate that companies can expect metaverse activities to be policed and enforced much like they would be in the physical world, say attorneys at Crowell & Moring.

  • Justices Poised To Reject Narrowing Unclaimed Property Law

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    After U.S. Supreme Court oral arguments in the so-called MoneyGram case — a dispute between Delaware and several other states over which has the right to about $300 million in unclaimed property — the court seems ready to rule against Delaware, but nuances of the court's reasoning will have a broader sweep, say attorneys at Alston & Bird.

  • How High Court Could Change FBAR Penalty Landscape

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    On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.

  • IRS Memo May Change IP Royalty Tax Prepayment Planning

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    A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.

  • What IRS Funding Increase Means For Taxpayers

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    The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.

  • 6 Tax Considerations For Life Sciences Collaboration Deals

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    Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.

  • Rushed Multilateral Negotiations Caused Two-Pillar Tax Mess

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    Cracks appearing in the two pillars of the 2021 global tax plan stem from a multilateral tax policy process that rushed to issue rules without first resolving fundamental differences between countries or ensuring that the U.S., a key player, could implement them, says Jefferson VanderWolk at Squire Patton.

  • Post-Litigation Refund Strategies To Defeat Class Certification

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    The Third Circuit's recent revival of the Duncan v. Governor of the Virgin Islands class action shows that defendants should strongly consider tendering refunds to class representatives — even after they file suit — to create a substantial obstacle to certification, say attorneys at Covington.

  • Key Considerations For Seeking Relief From Double Taxation

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    Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.

  • High Court Could Resolve Thorny Atty-Client Privilege Issue

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    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

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    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

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    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

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    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.

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