Federal

  • November 22, 2022

    Judge Ends Confinement For Founder Of Tax Cheat Group

    The founder of an organization that helped thousands of people cheat on their taxes — and counted convicted actor Wesley Snipes among its members — was released early from home confinement Tuesday by a federal judge who said he was no longer a threat to society.

  • November 22, 2022

    Tax Court Suspends Practitioner After State Suspension

    The U.S. Tax Court suspended a tax practitioner from practice before the court after he was suspended by a state bar.

  • November 22, 2022

    Fox Rothschild Adds Tax And Wealth Partner In Seattle

    Fox Rothschild LLP added a partner from Foster Garvey PC to its taxation and wealth planning department who will be based out of the firm's Seattle office.

  • November 22, 2022

    Justices Won't Block Release Of Trump Tax Returns To House

    The U.S. Supreme Court on Tuesday said it won't block a Democratic-led House committee from seeing former President Donald Trump's tax returns, paving the way for the panel to see the filings before Republicans take over committee leadership in January.

  • November 22, 2022

    IRS Seeks Input On Departing Alien Tax Statement

    The Internal Revenue Service on Tuesday asked for comments on a form used to confirm that aliens departing the country have satisfied all American income tax requirements.

  • November 22, 2022

    Couple Appeal Bid To Clarify Taxation Of Crypto Staking

    A couple who created a unique form of cryptocurrency and lost their bid to clarify whether generating tokens through so-called staking creates taxable income plan to appeal to the Sixth Circuit, according to a notice they filed in a Tennessee federal court.

  • November 22, 2022

    Trump Bid To Toss AG Suit Rehashes Failed Args, Judge Says

    A New York state judge on Tuesday slammed Donald Trump's motion to dismiss the attorney general's $250 million fraud lawsuit as "deja vu all over again," asking defense attorneys for the ex-president and his companies why he should consider the same arguments he's already rejected.

  • November 21, 2022

    Manhattan DA Rests In Trump Organization Tax Fraud Case

    The Manhattan District Attorney's Office rested its tax fraud case against the Trump Organization Monday in New York state court after calling just five witnesses over eight days, building its case on testimony by two finance officers and a parade of tax documents.

  • November 21, 2022

    Judge Rightly Revised MoneyGram Report, Del. Tells Justices

    A U.S. Supreme Court-appointed special master was correct in changing his mind to reach a conclusion partially favoring Delaware in a dispute over abandoned MoneyGram checks, the state said in a brief that asked the justices to heed the revised opinion.

  • November 21, 2022

    Chrisleys Sentenced To Prison In $36M Bank Fraud Case

    Todd and Julie Chrisley of the reality television show "Chrisley Knows Best" were sentenced Monday evening by a federal judge in Atlanta to 12 and seven years in prison, respectively, and ordered to pay $17.2 million in restitution in relation to a $36 million bank fraud scheme and tax evasion.

  • November 21, 2022

    Calif. Federal Court Closes Summons In French Tax Probe

    A California federal court closed a summons Monday that U.S. officials had filed against an accountant to compel disclosure of financial documents about a French company under investigation in connection with tax fraud.

  • November 21, 2022

    DC Court Asked To Hold Opinion Due To Transition Tax Appeal

    An expatriate attorney asked a D.C. federal court to refrain from issuing an opinion on its dismissal of a suit accusing the Internal Revenue Service of improperly disclosing his tax information until a related appeal by him is decided.

  • November 21, 2022

    Man Owes Tax On Retaliation Settlement, Tax Court Says

    A former higher education employee has to pay tax on a nearly $231,000 settlement he received for claims that his employer retaliated against him after claiming the institution misused funds, the U.S. Tax Court said Monday.

  • November 21, 2022

    Tax Court Says Couple's Income Must Include Retirement Pay

    A Connecticut couple must include most of the railroad retirement benefits the husband received in 2015 in their income for that year, the U.S. Tax Court said Monday.

  • November 21, 2022

    Tax Court Fines Texas Couple For Frivolous Arguments

    A Tax Court judge pinned a Texas couple with a $5,000 fine for making frivolous arguments while challenging their $33,000 tax bill, saying they persisted in bringing "all-too-familiar tax protestor contentions," according to an opinion released Monday.

  • November 21, 2022

    IRS Issues New Required Retirement Plan Amendments List

    The Internal Revenue Service on Monday released the 2022 edition of an annual list of required amendments for qualifying individually designed retirement plans.

  • November 21, 2022

    $3B Easement Scheme Case Closed Pending Settlement

    A Georgia federal judge on Monday closed a long-running case alleging an investment group and an Alabama appraiser promoted a $3 billion conservation easement tax scheme, saying government review of their settlement offers could take too long to simply hit pause.

  • November 21, 2022

    Former CEO Cops To Tax Fraud, Agrees To $15.8M Restitution

    A former health care management firm CEO agreed to pay $15.8 million in restitution after pleading guilty in Pennsylvania federal court to skirting millions in personal and corporate income taxes by claiming improper business write-offs and funneling money through his various business entities.

  • November 21, 2022

    Supreme Court Won't Hear Whirlpool Tax Challenge

    The U.S. Supreme Court won't hear Whirlpool's challenge to a Sixth Circuit ruling that the company owes taxes on about $45 million of foreign income, according to an order list from the top court published Monday.

  • November 18, 2022

    Biden Asks Justices To Reinstate Student Debt Relief Program

    The Biden administration asked the U.S. Supreme Court on Friday to let it move forward with a plan to forgive student loan debt after the Eighth Circuit halted the program, saying the delay "leaves millions of economically vulnerable borrowers in limbo."

  • November 18, 2022

    6th Circ. Blocks ARPA Clawback Enforcement Against Tenn.

    The federal government can't enforce a provision barring Tennessee from using federal coronavirus relief funds to offset revenue reductions such as tax cuts, but Kentucky lacked standing to challenge the provision, the Sixth Circuit said Friday.

  • November 18, 2022

    Foreigners Barred From Tax Treaty Aid On Some Distributions

    Foreign taxpayers cannot claim treaty benefits on the distribution of stock in a domestic international sales corporation on the grounds that the distribution is not attributable to a U.S. permanent establishment, according to an IRS legal memo published Friday.

  • November 18, 2022

    States Seek IRS Liaison For Sharing Of Charities' Tax Info

    An IRS liaison is necessary to help state regulators access nonprofits' federal tax information following the release of final rules that broaden the agency's authority to share that data with states, an official from the New York attorney general's office said Friday.

  • November 18, 2022

    6th Circ. Tosses Ohio's Challenge To ARPA Tax Cut Limit

    The Sixth Circuit on Friday threw out Ohio's challenge to an American Rescue Plan Act provision that requires states to return pandemic aid used to offset tax cuts, finding that no federal recoupment of state funds was imminent.

  • November 18, 2022

    The Tax Angle: New Ways And Means Members, House Rules

    From a look at possible changes to the House Ways and Means Committee's membership to the GOP's new rules for House legislation, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

Expert Analysis

  • 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.

  • Digital Taxation Is Necessary, But Tough To Manage

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    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

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    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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