Federal
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March 01, 2024
Major Cos. Paying Well Below 21% TCJA Tax Rate, Study Says
Major corporations such as Netflix and T-Mobile are on average paying well below the 21% corporate tax rate established by the 2017 Tax Cuts and Jobs Act, a study by the Institute on Taxation and Economic Policy of more than 340 major corporations showed.
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March 01, 2024
Easement Cases To Put IRS-Hired Appraisers Under Scrutiny
Some partnerships challenging the denial of tax deductions for conservation easement donations are mounting a new attack on the IRS' push to enforce the transactions with claims that the agency's multimillion-dollar contracts with third-party appraisal firms compel them to be biased toward the government.
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March 01, 2024
House Tax Panel To Prep Members On OECD Pillar 1
Neither Republicans nor Democrats on the House Ways and Means Committee have opined much about the OECD profit reallocation plan known as Pillar One, but they will gain valuable information during an upcoming subcommittee meeting, a tax staffer for the panel said Friday.
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March 01, 2024
Menendez Associate Pleads Guilty In Bribe Case
A New Jersey insurance broker pled guilty Friday to bribing Sen. Bob Menendez and his wife, Nadine, by buying her a Mercedes-Benz convertible, under an agreement to cooperate with federal prosecutors.
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March 01, 2024
Taxation With Representation: Pillsbury, Cleary Gottlieb
In this week's Taxation with Representation, First Advantage Corp. acquires Sterling Check Corp., International Game Technology spins off two subsidiaries, Disney merges its media operations in India with Reliance Industries, and Atlas Energy Solutions purchases Hi-Crush.
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March 01, 2024
IRS Amends Language In Clean Hydrogen Proposal
The Internal Revenue Service issued a correction notice Friday to change the language of a proposal relating to clean hydrogen production and whether such facilities are treated as energy property.
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March 01, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service issued its weekly bulletin Friday, and it included notice of a variety of rate updates.
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February 29, 2024
Logger Failed To Report $3M In Foreign Banks, Judge Rules
A logger failed to report more than $3 million he kept in foreign accounts, then fraudulently transferred the bulk of it to his wife when he learned he was being audited by the IRS, a Colorado federal judge said in upholding $1.7 million in penalties.
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February 29, 2024
House Approves Aviation Excise Tax Extensions
The U.S. House voted Thursday to extend excise taxes funding the Airport and Airway Trust Fund for two months at their current rates, clearing the path for the legislation to be considered by the Senate.
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February 29, 2024
Biz Owner's $2.4M FBAR Dispute Paused For Mediation
The U.S. government and a retired plumbing business owner mutually agreed to a 90-day stay of their $2.4 million tax dispute over foreign bank account reporting while they try to mediate a solution, a Georgia federal judge said Thursday.
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February 29, 2024
IRS Funding Cuts Would Raise Deficit $24B, CBO Says
A congressional agreement to rescind $20 billion in appropriated funding for the Internal Revenue Service this year would add $24 billion to the federal deficit through the next 10 years, according to Congressional Budget Office projections published Thursday.
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February 29, 2024
Ga. Man Convicted In $11M PPP Fraud Case Wants New Trial
An Atlanta man convicted on dozens of charges stemming from an $11 million pandemic loan fraud scheme has asked a Georgia federal judge for a new trial.
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February 29, 2024
IRS Amends Treatment Of Public Utility Debt
The Internal Revenue Service will not define certain public utilities as not recognizing gross income until the public utility receives the proceeds of a debt issued by the qualifying state financing entity, the agency said Thursday.
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February 29, 2024
NJ Towns Can't Sue Netflix, Hulu For Fees, 3rd Circ. Says
Two New Jersey municipalities cannot sue Netflix and Hulu for franchise fees under the state's Cable Television Act, the Third Circuit held Thursday in a precedential opinion, saying the state statute reserves enforcement of the law to the state Board of Public Utilities.
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February 29, 2024
IRS Enforcement Push Will Target 125K Wealthy Nonfilers
The Internal Revenue Service is ramping up enforcement against 125,000 high-income taxpayers who haven't filed returns since 2017 as a part of its ongoing efforts to increase tax compliance, the agency's chief told reporters Thursday.
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February 29, 2024
Senate Confirms First Woman To Top IRS Attorney Post
The U.S. Senate on Thursday confirmed a former director at EY who previously served as associate chief counsel, international, at the Internal Revenue Service to be the agency's chief counsel, making her the first woman to be confirmed for the role.
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February 29, 2024
Medtronic Says 3 Years Of Tax Returns Under IRS Audit
Three years of medical device company Medtronic's federal income tax returns are being audited by the Internal Revenue Service, the company said in a U.S. Securities and Exchange Commission filing.
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February 29, 2024
Bankrupt Endo To Pay $465M To Resolve Opioid Claims
Drugmaker Endo International has agreed to pay as much as $465 million to resolve criminal and civil claims stemming from its sale and marketing of a powerful opioid, and will turn over its assets to a group of secured lenders who will operate the company under a new corporate structure.
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February 28, 2024
Crapo Seeks Changes To Child Tax Credit Provisions In Bill
The top-ranking Republican on the Senate Finance Committee said Wednesday that he cannot support the bipartisan tax bill pending in the Senate as long as a provision that allows taxpayers to receive a refundable child tax credit based on their prior year's earnings is included.
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February 28, 2024
Amgen Seeks Dismissal Of Investor Action Over $11B Tax Bill
Amgen had no obligation to disclose specific amounts of proposed adjustments to its taxes, the company told a New York federal court as it again demanded dismissal of a proposed class action alleging the company hid a $10.7 billion tax bill from investors.
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February 28, 2024
Embattled Philly Loan Biz Principals Hit With RICO Charges
Legal troubles for the principals of Philadelphia's Par Funding cash advance company are mounting as federal prosecutors hit them with a new indictment adding Racketeer Influenced and Corrupt Organizations Act allegations on top of existing charges that the principals bilked investors out of hundreds of millions of dollars and threatened violence against borrowers.
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February 28, 2024
COVID Fraud Jury Can't Hear Of Gov't's Loan Error, Feds Say
A jury shouldn't be shown evidence of the U.S. government's error in approving a Michigan business owner's application for a Paycheck Protection Program loan while he was under indictment, federal prosecutors have argued.
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February 28, 2024
Timeline Rule For Assessing Tax Not Retroactive, Court Says
A former corporate executive who received a $26 million buyout and then rolled the proceeds over to a retirement account incorrectly claimed that an amended statute of limitations exempted him from paying a penalty, the U.S. Tax Court ruled Wednesday.
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February 28, 2024
GOP Reps. Press IRS On Backdating Forms In Easement Case
Two House Republican tax writers pressed the Internal Revenue Service for details on how it would prevent agency employees from inappropriately backdating official tax documents after the agency admitted last year to doing so in a high-profiled suit involving conservation easement penalty forms.
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February 28, 2024
Divorced Woman Can Get Spousal Relief, Tax Court Says
A divorced woman has satisfied the requirements for innocent spousal relief despite an attempt by her ex-husband to refute her claim, the U.S. Tax Court ruled Wednesday.
Expert Analysis
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2 Tax Decisions Hold Key Transfer Pricing Takeaways
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.
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Patagonia's Succession Plan Is A Blueprint For Biz Owners
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.
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The CHIPS Act: Key Takeaways For Semiconductor Industry
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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Digital Taxation Is Necessary, But Tough To Manage
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.
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5 Considerations When Seeking Federal EV Funding
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.
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Unpacking The Inflation Reduction Act's Energy Tax Credits
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.
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How COVID Has Changed Project Development And Finance
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.
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Unpacking The Shift In DOJ Corporate Enforcement Policy
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.
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What AML Bill Could Mean For Firms, Funds And FinCEN
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.
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How Inflation Reduction Act Will Lift Offshore Wind Projects
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.
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CORRECTED: New Tax Credits For Renewables Should Offer Investors Relief
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.
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Inflation Reduction Act A Boon To Hydrogen, Carbon Capture
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.
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What The Inflation Reduction Act Has To Do With Crypto
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.