Federal

  • November 16, 2022

    Proof Shows Atty Helped CEO Evade Taxes On $225M, US Says

    A tax attorney helped a private equity executive evade taxes on $225 million in capital gains, the U.S. government told a California federal court, saying it will present evidence at trial from undercover agents and other sources proving he knowingly promoted an offshore evasion scheme.

  • November 16, 2022

    Real Estate Funds Seek Block Of IRS Easement Notice

    Three real estate investment funds sued the U.S. government in Ohio federal court, seeking to block the IRS from forcing their compliance with a notice requiring the disclosure of syndicated conservation easement transactions that the court set aside in a different case.

  • November 16, 2022

    Senate GOP Bill Seeks Oversight Of IRS Funding Boost

    Congress would be given a direct say in how the Inflation Reduction Act's nearly $80 billion funding boost for the Internal Revenue Service will be spent under legislation introduced Wednesday by a pair of veteran Senate Finance Committee Republicans.

  • November 16, 2022

    IRS Told To Make Taxpayers Central To Modernization Pitch

    The Internal Revenue Service should use personal examples and other taxpayer-centered framing to communicate challenges it faces to drive home the importance of modernizing, the IRS Advisory Council said Wednesday in its annual report.

  • November 16, 2022

    Pension Plan Segment Rates Rise In Nov.

    Segment rates for calculating pension plan funding rose in November, the Internal Revenue Service said Wednesday.

  • November 16, 2022

    IRS Issues Procedures For Disclosing Big Biz Tax Errors

    Certain large corporate taxpayers can file a new form with the Internal Revenue Service to disclose errors or omissions on their original returns in order to avoid accuracy-related and understatement penalties, the IRS said Wednesday.

  • November 16, 2022

    IRS Corrects Cooperative Income Deduction Rules

    The Internal Revenue Service issued corrections Wednesday to final rules for qualified income deductions for agricultural and horticultural cooperatives.

  • November 16, 2022

    IRS Seeking Comments On Penalty Reporting Form

    The Internal Revenue Service asked for feedback Wednesday on a form that government entities use to report fines and other payments they receive.

  • November 15, 2022

    I Feel Good (I Own James Brown's Songs), Financier Says

    The music industry financier behind the famous "Bowie Bonds" investment vehicle filed suit Tuesday in a New York federal court against the estate of James Brown, claiming the late soul singer sold off his catalog of hit records for $26 million to pay off tax debts decades before Brown's estate sold the songs for $90 million to someone else.

  • November 15, 2022

    House Dem Seeks Criminal Probe Of Trump IRS Targeting Claim

    The U.S. Department of Justice should investigate allegations that former President Donald Trump pushed for the Internal Revenue Service to audit some of his critics while he was in office, a House Democratic lawmaker said Tuesday.

  • November 15, 2022

    Ex-CFO Weisselberg Says Trump Org. Gained From His Fraud

    Longtime Trump Organization finance chief and confessed tax cheat Allen Weisselberg took the stand Tuesday in the Manhattan district attorney's criminal fraud case against former President Donald Trump's company, testifying both he and the company benefited from his fraud.

  • November 15, 2022

    IRS Looking To Employ Economic Substance Test, Official Says

    The Internal Revenue Service is exploring how to raise the so-called economic substance doctrine in transfer pricing disputes after an internal protocol change this year lowered the requirements for approval, an agency official said Tuesday.

  • November 15, 2022

    Law Firm Gives Up Docs To Satisfy Gov't In IRS Summons Suit

    A law firm challenging an IRS summons for client records in an offshore tax dodging probe likely provided all documents sought by the agency, the U.S. told a Texas federal court, saying it "does not intend to seek further orders of enforcement at this time."

  • November 15, 2022

    Mo. Man Relieved Of Joint Tax Liability Due To Inability To Work

    A Missouri man who cannot work does not have to pay the Internal Revenue Service taxes he owed jointly with his ex-wife because the payments would create financial hardship and he made a good faith effort to follow the law, the Tax Court said Tuesday.

  • November 15, 2022

    Wyden Wants Child Tax Credit, R&D Tax Breaks In Funding Bill

    Senate Finance Committee Chair Ron Wyden wants Congress' year-end funding package to include provisions that would extend child tax credit changes and expired tax breaks for research and development costs, he told reporters Tuesday.

  • November 15, 2022

    Applicable Federal Rates To Rise In December

    Applicable federal rates for income tax purposes will rise in December, the Internal Revenue Service said Tuesday.

  • November 15, 2022

    Tax Group Throws Support Behind Mo. In ARPA Appeal

    Missouri has standing to challenge the "incoherent" tax cut clawback rule in the federal coronavirus funding law because the state is already suffering harm, a business group told the U.S. Supreme Court, urging it to review an appeals court decision.

  • November 15, 2022

    Suit Accuses Intuit Of Sharing Watch Histories With Facebook

    An Illinois TurboTax user hit the tax prep software company's parent company, Intuit Inc., with a proposed class action accusing it of violating federal privacy law by telling Facebook which videos hundreds of thousands of subscribers have watched on Intuit's websites.

  • November 15, 2022

    IRS Seeks Input On Rules For Residence Seller Assurances

    The Internal Revenue Service asked for comments Tuesday on rules for the assurances that principal residence sellers must provide so certain reporting requirements don't apply to the transactions.

  • November 14, 2022

    Ex-SDNY Judge, Bracewell Atty Appointed Trump Org Monitor

    Former Southern District of New York judge and current Bracewell LLP partner Barbara S. Jones will be the independent monitor overseeing the Trump Organization, according to an order issued Monday in New York state court.

  • November 14, 2022

    8th Circ. Blocks Biden's Student Debt Relief Program

    The Eighth Circuit has halted President Joe Biden's student loan debt relief program while it considers the merits of a six-state effort to block the plan, finding that the plan's "irreversible impact" weighs in favor of hitting pause on the matter for now.

  • November 14, 2022

    Trump Controller Branded 'Hostile Witness,' Admits Crimes

    The Trump Organization's controller was branded a hostile witness for evasive testimony on Monday even as he admitted committing tax fraud on behalf of two executives and said Donald Trump himself was aware of at least some aspects of the alleged fraud.

  • November 14, 2022

    Pick To Lead IRS Shows Biden's Eye On Budget Management

    President Joe Biden's announcement that he will nominate former acting IRS Commissioner Daniel Werfel to lead the agency shows the administration is keen to nominate someone with budgetary management experience to implement the IRS' $80 billion funding boost.

  • November 14, 2022

    Lawmakers Seek Probes After Claims Of Trump IRS Targeting

    The IRS and its federal watchdog should investigate whether former presidential candidate Hillary Clinton and Washington Post owner Jeff Bezos were picked for intensive audits during Donald Trump's presidency, Democratic House tax writers said Monday.

  • November 14, 2022

    Trump Tells Justices House Lacks Time To Review Tax Docs

    The U.S. Supreme Court should stop the IRS from handing former President Donald Trump's tax returns to House Democrats, he told the justices Monday, arguing Congress doesn't have time to act on the documents before its current session ends.

Expert Analysis

  • 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.

  • Corporate Reporting Considerations As Tax Meets ESG

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    With the U.S. Securities and Exchange Commission filing season upon us amid increasing pressure for greater transparency around effective tax rates and tax strategies, multinational companies must decide how they will approach voluntary tax reporting and prepare their responses if they want to control the narrative, say Michael Lebovitz and Jenny Austin at Mayer Brown.

  • How To Navigate Equity Rollovers In A Tight M&A Market

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    As heavy competition for acquisition targets allows buyers to be more flexible in fulfilling their desire for management to roll equity and invest with them, businesses should be mindful that equity rollover transactions, which take many forms, also require thorough review as part of the overall transaction assessment, says Joshua Klein at Neal Gerber.

  • 11th Circ. Ruling Moves Circuits Closer To Tax Procedure Split

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    The Eleventh Circuit's recent decision in the conservation easement case Hewitt v. Commissioner of Internal Revenue, holding a long-standing tax regulation procedurally flawed under the Administrative Procedure Act, is unusual and may presage a circuit split over the APA's applicability in tax cases, say Maria Jones and Samuel Lapin at Miller & Chevalier.

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