Federal
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March 21, 2024
Quintairos Prieto Taps Atlanta Atty To Lead New Tax Group
Quintairos Prieto Wood & Boyer PA said it had created a tax division that will be led by an Atlanta-based partner who has guided clients on civil and criminal tax law, reinforcing its national expertise in litigation, regulatory and corporate law matters.
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March 21, 2024
H&R Block Challenges FTC Judges In False Ad Battle
H&R Block asked a Missouri federal court to stop administrative law judges from overseeing a Federal Trade Commission proceeding that accuses the tax preparation company of deceptive advertising, claiming the judges have job protections that unconstitutionally shield them from presidential oversight.
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March 21, 2024
Senate Bill Seeks To End Tax-Free Merger Treatment
A bill introduced Thursday in the U.S. Senate would end manipulation of the Internal Revenue Code that allows certain corporate mergers to be tax-free.
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March 21, 2024
IRS Tweaks Proposed Partnership Treatment Rules
The Internal Revenue Service issued a correction notice Thursday fixing a reference in proposed regulations about the treatment of related people within partnerships.
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March 21, 2024
IRS Issues Fixes In Safe Harbor Regulations
The Internal Revenue Service issued two correction notices Thursday to amend final regulations focused on certain safe harbor exceptions.
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March 20, 2024
Endo Plan To Trim $5B In Debt Confirmed By NY Judge
Drugmaker Endo International got a New York bankruptcy judge's approval for its Chapter 11 plan that aims to cut more than $5 billion in debt and hand over ownership to its lenders, roughly a month after it finalized a $465 million deal to resolve criminal and civil opioid claims.
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March 20, 2024
Wyden Bill Would Target Abuse Of Annuity Trusts
A bill introduced Wednesday by the Senate Finance Committee chairman, Sen. Ron Wyden, D-Ore., would attempt to limit the abuse of a type of annuity trusts by the wealthy, in part by imposing a requirement that the instruments have a minimum term of at least 15 years.
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March 20, 2024
IRS Releases Foreign Housing Expense Limits For 2024
The Internal Revenue Service released adjustments to the limitation on foreign housing expense deductions and exclusions for 2024 on Wednesday.
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March 20, 2024
IRS Asks Justices To Scrap Couple's Late-Filed Tax Court Suit
The IRS asked the U.S. Supreme Court to consider reversing the Third Circuit's revival of a couple's challenge to their tax bill, saying the appeals court incorrectly concluded that a 90-day deadline for petitioning the U.S. Tax Court need not always be met.
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March 20, 2024
RI Ex-Broker Gets 8 Years In Ponzi Scheme
A Rhode Island man was sentenced to eight years in prison for running a decade-long Ponzi scheme to defraud investors and to evade his taxes.
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March 20, 2024
How The Supreme Court Could Narrow Chevron
After hours of oral argument in a closely watched administrative law case, it appeared that some U.S. Supreme Court justices could be open to limiting the opportunities for lower courts to defer to federal agencies' legal interpretations in disputes over rulemaking — and legal experts said there are a number of ways they could do it.
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March 20, 2024
IRS Withholding Docs On Partnership Audits, Baker Atty Says
The Internal Revenue Service has not responded to a request for documents pertaining to the agency's scrutiny of large partnerships and should be forced to disclose them, an attorney with Baker McKenzie told a D.C. federal court.
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March 20, 2024
IRS Grants Income Exclusion To Those Fleeing 6 Countries
Individuals who fled conditions in Ukraine, Belarus, Sudan, Haiti, Niger and Iraq after specific dates in 2023 can exclude foreign earned income, and can exclude or deduct housing costs, from gross income that year because of adverse conditions in the countries, the IRS said.
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March 20, 2024
Law360 Announces The Members Of Its 2024 Editorial Boards
Law360 is pleased to announce the formation of its 2024 Editorial Advisory Boards.
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March 20, 2024
King & Spalding Adds Ex-PwC Tax Pro As Partner In NY
An experienced tax attorney has joined King & Spalding LLP in New York after working at PricewaterhouseCoopers LLP for six years.
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March 19, 2024
US Climate Law's Clean Energy Credit Requests Reach 45K
About 500 entities have requested registration numbers for more than 45,500 projects that aim to use the Inflation Reduction Act's clean energy tax credits, the Internal Revenue Service and U.S. Department of the Treasury said Tuesday.
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March 19, 2024
ABA Tax Section Seeks Revised Donor-Advised Fund Rules
The U.S. Treasury Department should revise excise tax rules for certain distributions from donor-advised funds in a manner that is consistent with regulations governing similar funds and that doesn't duplicate existing tax penalties, the American Bar Association Tax Section said.
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March 19, 2024
Staffing Co. Owner Gets 4 Years For Hiring Untaxed Labor
The owner of a staffing company in Key West, Florida, that hired untaxed and unauthorized workers was sentenced by a Florida federal judge to four years in prison and ordered to pay $3.5 million in restitution to the U.S. government, according to court documents.
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March 19, 2024
GILTI Figures Into CFC Applicability Project, Official Says
The U.S. global intangible low-taxed income system is factoring into continuing Internal Revenue Service work on whether a tax code provision limiting corporations from offsetting income with net operating or other tax losses after ownership changes applies to controlled foreign corporations, an agency official said Tuesday.
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March 19, 2024
Pension Plan Segment Rates Increase In March
Segment rates for calculating pension plan funding rose in March, the Internal Revenue Service said Tuesday.
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March 19, 2024
Exxon Wants Closed Court In $1.8B Tax Trial
Exxon Mobil plans to seek courtroom closures for parts of an upcoming trial in its $1.8 billion suit challenging denied tax deductions for payments it made to Qatar, telling a Texas federal court that certain testimony, if made public, would damage its relationship with the foreign partner.
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March 18, 2024
Ariz. Rebates Trigger Federal Tax, IRS Tells Court
Arizona's one-time 2023 payments to taxpayers are subject to federal taxation because they do not qualify for exclusions for general welfare or disaster relief payments, the Internal Revenue Service told a federal court.
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March 18, 2024
Justices Won't Review Dead Film Exec's IRS Summons
The U.S. Supreme Court on Monday denied a request from the daughter of a dead film executive to consider invalidating an IRS summons for her father's financial records, letting stand a Ninth Circuit decision that found the agency sought the records in good faith.
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March 18, 2024
Werfel Calls Online Biz Account Authentication A Challenge
Establishing an effective user authentication method for companies using online business tax accounts is a challenge for the Internal Revenue Service and the agency wants suggestions on how to do it, commissioner Daniel Werfel said Monday.
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March 18, 2024
Treasury Mulling Whether To Keep Foreign Tax Credit Regime
The U.S. Treasury Department is considering whether the best way to provide administrable foreign tax credit rules and address related policy concerns is to retain the framework from paused final regulations or develop a new one, a Treasury official said Monday.
Expert Analysis
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Avoiding Negative Tax Consequences In Loan Modifications
Borrowers who may be caught in the dramatic uptick in nonperforming commercial real estate loans should consider strategies to avoid income and capital gains tax that may be triggered by loan modifications, says Aman Badyal at Glaser Weil.
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Benefits And Beyond: Fixing Employee Contribution Failures
Employers must address employee contribution failures promptly in order to avoid losing significant tax benefits of 401(k) or 403(b) plans, but the exact correction procedures vary depending on whether contributions were less than or greater than intended, say attorneys at Seyfarth Shaw.
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Now Is The Time For State And Local Sales Tax Simplification
In the five years since the U.S. Supreme Court’s landmark decision in South Dakota v. Wayfair, state and local governments increasingly rely on sales tax, but simple changes are needed to make compliance more manageable for taxpayers, wherever located, without unduly burdening interstate commerce, says Charles Maniace at Sovos.
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Recent Bills Show Congress' Growing Maturity On Cannabis
Though two recently introduced cannabis reform bills, the Prepare Act and the Small Business Tax Equity Act, are unlikely to pass in this Congress, they demonstrate a new level of focus and sophistication on the part of lawmakers as it relates to cannabis at the federal level, says Irina Dashevsky at Greenspoon Marder.
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What To Make Of IRS' New Advance Pricing Guidance
Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.
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Compliance Obligations Still Murky For Superfund Excise Tax
Comments on the IRS' reinstatement of the Superfund chemicals excise tax show that, given taxpayers' lack of institutional knowledge and the government's previous failure to finalize clarifying guidance, further regulatory action is needed to help taxpayers understand their obligations, say Nicole Elliott and Mary Kate Nicholson at Holland & Knight.
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The Reciprocal Tax Bill Is A Warning Shot At Pillar 2
A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.
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3 Developments That May Usher In A Nuclear Energy Revival
A recent advancement in nuclear energy technology, targeted provisions in the Inflation Reduction Act and a new G7 agreement on nuclear fuel supply chains may give nuclear power a seat at the table as a viable, zero-carbon energy source, say attorneys at Vinson & Elkins.
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What Tax-Exempt Orgs. Need From Energy Credit Guidance
Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.
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Unconventional Profits Interest Structures Find New Support
A recent U.S. Tax Court ruling should provide comfort that less-than-plain-vanilla profits interest structures, created to achieve complicated economic arrangements, can succeed in generating more optimal tax outcomes, provided the terms are properly drafted, says Daren Shaver at Hanson Bridgett.
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Roadblocks For Cannabis Employers Setting Up 401(k) Plans
Though the Internal Revenue Code and the Employee Retirement Income Security Act generally allow cannabis businesses to establish 401(k) plans for their employees, companies must still pick their way through uncertainties around tax deductions and recruiting reliable vendors, say attorneys at Shipman & Goodwin.
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How Foreign Info Return Penalty Case May Benefit Taxpayers
The U.S. Tax Court's recent decision that the Internal Revenue Service cannot penalize taxpayers for failing to file foreign corporation information returns may give similarly situated taxpayers an opportunity to also avoid penalties, provided they protect their rights before the decision is overturned or mooted by legislation, say attorneys at Arnold & Porter.
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What's Unique — And What's Not — In Trump Protective Order
A Manhattan judge's recent protective order limiting former President Donald Trump's access to evidence included restrictions uniquely tailored to the defendant, which should remind defense attorneys that it's always a good idea to fight these seemingly standard orders, says Julia Jayne at Jayne Law.