Federal

  • March 03, 2023

    Water Rights Count As Real Property, IRS Says

    Several ranch owners' rights to divert river water during a certain time of year constitutes real property for the purposes of a tax code statute on like-kind exchanges, the Internal Revenue Service said in a private letter ruling released Friday.

  • March 03, 2023

    IRS To Accept Applications For Low-Income Tax Clinic Grants

    The Internal Revenue Service will start accepting applications for supplemental low-income taxpayer clinic grants for 2023 on Tuesday, the agency said Friday.

  • March 02, 2023

    Senate's Tax Whistleblower Bill Would Secure Rewards

    Whistleblowers who report tax cheats to the Internal Revenue Service would see expanded protections, including a presumption of anonymity in court and guaranteed reward amounts, under a bill introduced in the U.S. Senate on Thursday by Sen. Chuck Grassley, R-Iowa.

  • March 02, 2023

    GOP Reps. Press IRS For Details On Tax Info Disclosure

    Two House of Representatives lawmakers pressed the Internal Revenue Service for answers Thursday on a pair of 2022 disclosures of confidential taxpayer data from business income tax returns that nonprofits use, including names and business contact details.

  • March 02, 2023

    Treasury Urged To Toss 'Look-Through' Ownership Proposal

    Treasury should scrap proposed rules that would, in a manner of speaking, look through ownership structures to determine whether real estate investment entities are domestically controlled — a status that includes certain tax exemptions for foreign shareholders, the American Bar Association's Tax Section recommended.

  • March 02, 2023

    IRS Can't Review Most Penalties Imposed In $2.2M FBAR Case

    The Internal Revenue Service cannot review the bulk of penalties it assessed in a $2.2 million case against a taxpayer for failing to report his foreign bank accounts, an Arizona federal court has ruled.

  • March 02, 2023

    Calif. Man's Education Credit Claim Denied By Tax Court

    A California man isn't entitled to tax credits for educational expenses for 2016 because he didn't satisfy the court that he paid the expenses for which the credits were taken, the U.S. Tax Court said Thursday.

  • March 02, 2023

    Belize Co. Not Entitled To US Exemption, Tax Court Says

    A Belize-based seller of annuity contracts doesn't qualify for a U.S. tax exemption because its gross receipts exceeded the $600,000 statutory threshold for life insurance companies seeking exemption, the U.S. Tax Court said Thursday.

  • March 02, 2023

    Sens. Urge White House To Pursue Tax Treaty With Taiwan

    A bipartisan group of U.S. senators announced legislation Thursday pushing for the administration of President Joe Biden to negotiate a tax treaty with Taiwan, an agreement they said would strengthen economic ties with the self-governing island.

  • March 02, 2023

    Calif. Man Owes $3K Deficiency For 2017, Tax Court Says

    A California man owes a tax deficiency of just more than $3,000 for 2017 because just under $34,000 he received was taxable income, the U.S. Tax Court said Thursday.

  • March 02, 2023

    Senate Tax Panel Approves Biden's IRS Commissioner Pick

    The Senate Finance Committee on Thursday approved President Joe Biden's nomination of former acting IRS Commissioner Daniel Werfel to lead the agency, clearing the path for a full Senate vote.

  • March 02, 2023

    Justices Urged To Review Full Payment Rule For Tax Suits

    The U.S. Supreme Court should revisit a rule it endorsed in 1960 requiring that people pay the full amount of their taxes owed before they challenge the liability in federal district court, a Florida man told the justices.

  • March 02, 2023

    JCT Got $24B In Refund Cases To Review In 2021, 2022

    The Joint Committee On Taxation was tasked with reviewing refunds cumulatively worth over $24 billion in 2021 and 2022, the committee said in a report released Thursday.

  • March 02, 2023

    Ex-IBM Worker Drops $265M Whistleblower Suit Over IRS Deal

    A former IBM employee who accused the software giant of tricking the IRS into buying $265 million of its products dropped his case after a decade of litigation aimed at whistleblowing, according to documents filed in D.C. federal court.

  • March 02, 2023

    New Easement Law May Render IRS Reporting Rule Unneeded

    A new law authorizing the IRS to limit deductions for so-called syndicated conservation easements may undercut the usefulness of a proposed regulation that would mandate reporting for such transactions, some experts said, while others said the measures may work well in tandem.

  • March 02, 2023

    US Auto Cos. Look To Clear Obstacles To Fully Electric Future

    As Michigan’s automakers pledge to invest billions into domestic battery factories, industry lawyers say there are still plenty of compliance hurdles to overcome before the country can fully embrace an electrification renaissance.

  • March 02, 2023

    IRS Taxpayer Advocacy Panel Gets 8 More Members

    The Internal Revenue Service's Taxpayer Advocacy Panel has another eight new members for 2023 to advise the agency on its customer service and satisfaction, the IRS said Thursday.

  • April 01, 2022

    IRS Adds New Members To Taxpayer Advocacy Panel

    The Internal Revenue Service's Taxpayer Advocacy Panel will welcome 25 new members in 2022 to advise the agency on its customer service and satisfaction, the IRS said Friday.

  • March 01, 2023

    3 Takeaways From The Supreme Court's Opinion In Del. v. Pa.

    The U.S. Supreme Court's unanimous decision awarding jurisdiction of more than $300 million in abandoned MoneyGram checks to states challenging Delaware offered guidelines about which financial instruments are governed by a 1974 federal unclaimed property law, but still left key questions unanswered. Here, Law360 offers three key takeaways from the decision in Delaware v. Pennsylvania.

  • March 01, 2023

    Calif. Man Owes $1.7M In FBAR Penalties, US Says

    A California man owes approximately $1.7 million in penalties for willfully failing to file reports of his foreign bank accounts, the U.S. government said in a complaint filed Wednesday in federal court.

  • March 01, 2023

    Former DOJ Atty Tells 9th Circ. He Deserves IRS Court Costs

    A former U.S. Department of Justice attorney is entitled to $536,000 in attorney fees for successfully challenging a U.S. Tax Court decision denying him litigation costs after the Internal Revenue Service conceded in court over his tax bill, he told the Ninth Circuit.

  • March 01, 2023

    GAO Urges Mulling More 3rd-Party Reporting To Fight Tax Gap

    The Internal Revenue Service should consider putting together recommendations for increased third-party reporting to cut down on the tax gap, the Government Accountability Office said.

  • March 01, 2023

    Tax Court Nixes Biz Deductions For Patent Attorney, Wife

    A California patent attorney and his wife must pay $10,400 in additional taxes because they couldn't back up business expenses they took as deductions and failed to prove they claimed the deductions in good faith, the U.S. Tax Court said Wednesday.

  • March 01, 2023

    House Bill Floats Raising SALT Deduction Limit To $50,000

    A bill introduced in the U.S. House of Representatives would raise the federal limit for an individual to deduct state and local taxes to $50,000, or $25,000 for married individuals filing separately. 

  • March 01, 2023

    Easement Rule Shouldn't Penalize Nonprofits, IRS Told

    Tax-exempt organizations, such as land trusts, should not be penalized under an IRS-proposed rule that lists so-called syndicated conservation easement transactions as possible abusive tax avoidance schemes, groups warned the agency Wednesday at a hearing on the pending rule.

Expert Analysis

  • Pandora Papers Reveal Need For Greater Tax Enforcement

    Author Photo

    The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.

  • Telehealth Providers Must Beware Of Fraud As Industry Grows

    Author Photo

    A recent fraud charge against a telehealth executive highlights the rise we're seeing in telefraud scams during the industry's pandemic growth, and there are some steps that all health providers should take to stay clear of potentially illegal arrangements, says LaTawnda Moore at Dinsmore.

  • Parsing New Int'l Tax Reporting Rules For Pass-Throughs

    Author Photo

    Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.

  • A Look At Global Tax Enforcement Developments: Part 2

    Excerpt from Practical Guidance
    Author Photo

    Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.

  • A Look At Global Tax Enforcement Developments: Part 1

    Excerpt from Practical Guidance
    Author Photo

    Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.

  • What The Judiciary's Font Recommendations Can Teach Us

    Author Photo

    The D.C. Circuit's recent soft prohibition on Garamond and the ensuing debates about courts' font preferences should serve as a helpful reminder of a larger point — every departure from convention in legal writing carries some level of risk, says Spencer Short at Stradley Ronon.

  • 2 Income Tax Loopholes Congress Should Close

    Author Photo

    To raise revenue for proposed infrastructure improvements and make the tax law fairer, the Biden administration and Congress should close an income tax loophole that allows an asset owner to bypass capital gains tax upon death and another that essentially allows taxpayers to make tax‑free gifts to grantor trusts, says Richard Kinyon at Shartsis Friese.

  • High Points Of IRS' New Employee Retention Credit Guidance

    Author Photo

    Dana Fried at CohnReznick examines recent IRS guidance on the employee retention credit, which includes a helpful new rule enabling more employers to qualify for the credit by allowing them to exclude some pandemic relief from gross receipts, but its exclusion of related individuals' wages from qualified wages for certain corporate owners is disappointing.

  • Prepare For More Audits Of Tax Info And Withholding Filings

    Author Photo

    Financial institutions and other corporate taxpayers should focus compliance efforts on tax information reporting and withholding, given recent indications from the Biden administration that the IRS will increase enforcement, and the administration's need to fund its infrastructure plan and other costly initiatives, say attorneys at Mayer Brown.

  • 9th Circ. Adds Pressure To Reject Substance Over Form

    Author Photo

    The Ninth Circuit’s recent decision rejecting taxes on a family's Roth IRA payments that were made through a foreign sales corporation represents a refreshing trend among federal appeals courts to reject substance-over-form principles and instead look to congressional intent, say Lawrence Hill and Caitlin Tharp at Steptoe & Johnson.

  • How Tax Code Changes Affect State AG Settlement Talks

    Author Photo

    Meghan Stoppel and Gianna Puccinelli at Cozen O'Connor discuss how newly implemented tax code regulations that allow companies to deduct some payments made to resolve a government investigation or prosecution will change settlement negotiations with state attorneys general.

  • NFTs May Come With Rewards, But Also Legal Risks

    Author Photo

    While some buyers of nonfungible tokens are experiencing enormous returns on their investments, those just entering the market should proceed with caution, and be sure to understand the risks related to contracts, taxation, intellectual property and money laundering regulations, says Anne-Laure Alléhaut at Patterson Belknap.

  • Problems To Avoid When Forming Your 2nd Real Estate Fund

    Author Photo

    There are a number of considerations when moving from your first real estate fund to subsequent funds during post-pandemic growth, particularly if the aggregate regulatory assets under management of the funds exceed $110 million or if additional country jurisdictions will be involved, say Matt Ertman and Max Brunner at Allen Matkins.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.