Federal

  • April 28, 2023

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin, which included an announcement of disciplinary sanctions.

  • April 28, 2023

    IRS Set To Resume In-Person Public Hearings

    The Internal Revenue Service will resume in-person public hearings on notices of proposed rulemaking following the government's termination of the national emergency caused by COVID-19, the agency said Friday.

  • April 28, 2023

    5 Taxpayer Advocacy Committees To Meet In May

    Five committees under the Internal Revenue Service's Taxpayer Advocacy Panel are scheduled to meet in May, the agency said Friday.

  • April 28, 2023

    Taxation With Representation: Latham, Shearman, Kirkland

    In this week's Taxation With Representation, Glencore will acquire stakes in two Brazilian metal companies, OpSec will merge with Investcorp Europe, and Eli Lilly will sell a medication to Amphastar.

  • April 27, 2023

    Coca-Cola Can't Escape Brazil Income Allocations, IRS Says

    The Internal Revenue Service urged the U.S. Tax Court to uphold the agency's income allocations from Coca-Cola's Brazilian affiliate, contending that the beverage giant has failed to show that underlying trademark license agreements predate current transfer pricing legislation and regulations.

  • April 27, 2023

    Israeli Bank Pays $214M To Close Tax Evasion Settlement

    Israel-based Bank Hapoalim paid $214 million to the U.S. government, wrapping up its monetary penalties for helping U.S. taxpayers hide more than $7.6 billion, according to a joint status report filed Thursday in New York federal court.

  • April 27, 2023

    Cos. Belong To Ore. Tax Evaders Who Owe $4M, 9th Circ. Says

    An Oregon couple convicted of tax evasion are the true owners of two companies they claimed not to control, the Ninth Circuit ruled Thursday in part of a federal case against the couple seeking to foreclose on properties to satisfy a $4 million tax debt.

  • April 27, 2023

    IRS Chief Defends Higher Staff Funding To Audit Wealthy

    The IRS needs the additional funding promised in August under the Democrats' Inflation Reduction Act to hire more accountants, data scientists and economists to examine the nearly 400,000 tax filings made each year by wealthy individuals, partnerships and corporations, IRS Commissioner Daniel Werfel told a House committee Thursday.

  • April 27, 2023

    Small Exempt Orgs' Form Fuels IRS Unit's Work, Official Says

    A compliance project targeting a yearly notice filed by small tax-exempt organizations has been a key driver of work performed by the Internal Revenue Service's exempt organizations exam unit, its supervisor said Thursday.

  • April 27, 2023

    US Says $2.3M Claim Against Tax Shelter Promoter Is Valid

    An Illinois federal court should reject a tax shelter promoter's bid to escape a $2.3 million penalty against him, the U.S. argued in a response to the man's lawsuit, saying the Internal Revenue Service erroneously abated the penalty and the man is raising arguments for the first time on appeal.

  • April 27, 2023

    US Drops Case Seeking Retirement Funds For $1M Tax Debt

    The federal government dropped a case seeking to require a Fidelity company to fork over a man's retirement funds to help chip away at his $1.1 million tax debt, according to a filing.

  • April 27, 2023

    Tax Court OKs IRS' Pursuit Of Man's $112K Debt

    The Internal Revenue Service did nothing wrong in sustaining collection actions against a Washington state man on the hook for more than $112,000, the U.S. Tax Court said Thursday.

  • April 27, 2023

    Jackson Walker Adds Tax Pro In Dallas From Gallagher

    Jackson Walker LLP added a former Gallagher Evelius & Jones attorney who has represented a diverse range of industries in federal income tax matters as a tax partner in its Dallas office, the firm announced.

  • April 27, 2023

    Perrigo Says IRS Dropped $843M Tax Assessment

    The Internal Revenue Service told Perrigo Co. that it won't have to pay an $843 million tax and penalty assessment that stemmed from the company's acquisition of another pharmaceutical business, according to a securities filing.

  • April 27, 2023

    Homebuilder Says IRS Is Delaying Refund For $2.2M Loss

    A California homebuilder who belatedly claimed a $2.2 million operating loss sustained during the 2008 housing crash has sued the federal government, saying he has waited nearly 10 years for the corresponding $475,000 refund and is out of options for recovering his money.

  • April 27, 2023

    Coca-Cola's Head Tax Lawyer Retiring, Deputy Promoted

    The Coca-Cola Co. is promoting an in-house counsel to vice president and naming him head of its legal tax team, according to an announcement.

  • April 26, 2023

    Kraken Decries 'Overbroad' IRS Summons For Taxpayer Info

    Crypto exchange Kraken fired back against the IRS' attempt to compel it to turn over customer information Friday, arguing the court previously forced the tax agency to narrow its request for similar information from crypto exchange Coinbase.

  • April 26, 2023

    IRS Hopes To Release Energy Credit Transferability Regs Soon

    The Internal Revenue Service is working on regulations regarding direct payment and transferability of renewable energy credits provided by the Inflation Reduction Act and hopes to release them later in the spring, an agency official said Wednesday.

  • April 26, 2023

    Clearer Tax-Exempt Hospital Reports Needed, Lawmakers Told

    The Internal Revenue Service should update its requirements for tax-exempt hospitals to report their charitable activities to make it easier for the public to determine whether they meet standards for providing community benefits, tax experts told lawmakers at a hearing Wednesday.

  • April 26, 2023

    Kyocera Given Tax Refund That May End $8.9M Fight, US Says

    The U.S. and Kyocera AVX Components Corp. are considering a dismissal of the company's $8.9 million tax refund lawsuit after the electronic parts maker received a refund larger than the amount at issue, the U.S. told a South Carolina federal court.

  • April 26, 2023

    House Approves Debt Limit Bill With IRS Funding Repeal

    House Republicans passed legislation Wednesday that would increase the federal debt limit while dismantling key provisions of the Inflation Reduction Act, including rescinding most of the $80 billion funding boost for the Internal Revenue Service.

  • April 26, 2023

    Ex-Ark. Lawmaker Gets Another 4 Years In Prison For Bribery

    A onetime Arkansas lawmaker and member of the Hutchinson political dynasty received a four-year sentence in Missouri for bribe-taking that he will have to serve on top of a previous four-year sentence meted out in Arkansas, the U.S. Department of Justice said Wednesday.

  • April 26, 2023

    Multilateral APAs May Increase In Frequency, IRS Official Says

    Multilateral advance pricing agreements will likely become more common, an Internal Revenue Service official said Wednesday, noting that recent guidance from the Organization for Economic Cooperation and Development could help with related considerations that arise under bilateral tax treaties.

  • April 26, 2023

    US Asks Court To Toss Citadel CEO's IRS Data Leak Suit

    A lawsuit brought by the CEO of hedge fund Citadel that accuses the IRS of leaking his tax returns to news organization ProPublica relies so heavily on speculative allegations that it should be tossed by a Florida federal court, the government said.

  • April 26, 2023

    Court Urged To Toss Funds' IRS Easement Notice Challenge

    An Ohio federal court should dismiss a case from a group of real estate investment funds challenging an IRS notice requiring the disclosure of syndicated conservation easement transactions, the U.S. government said, arguing the case is moot because the agency has limited its enforcement of the notice.

Expert Analysis

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

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    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.

  • IRS Ruling Opens Runway For Stalled Carbon Capture Deals

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    A recent Internal Revenue Service ruling that clarifies how multiparty ownership affects eligibility for the carbon sequestration tax credit should accelerate the pace of project financing transactions that were held up by lingering uncertainty, and should increase the pool of projects into which tax equity will consider investing, say attorneys at Orrick.

  • What Biden's Tax Proposals May Mean For Int'l Private Clients

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    Jennifer Wioncek and Paul D’Alessandro at Bilzin Sumberg discuss the U.S. Department of the Treasury's recently released explanation of the Biden administration's tax proposals and how the changes would affect income and wealth transfer planning for international private clients.

  • Justices Open The Door Wider For Donor Info Law Challenges

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    The U.S. Supreme Court’s recent decision in Americans for Prosperity Foundation v. Bonta, striking down California's requirement that charities disclose the identity of major donors, will make similar state and federal statutes more vulnerable to constitutional challenge, says Lloyd Mayer at Notre Dame Law School.

  • IRS Extension Is Partial Relief For Renewable Energy Projects

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    The Internal Revenue Service’s recent extension of the start-of-construction safe harbor for renewable-energy projects is welcome relief for solar companies unable to benefit from previous extensions, but it is still unclear whether a project that exceeds the deemed continuity period qualifies for a tax credit if it cannot prove continuous work, says David Burton at Norton Rose.

  • Justices Should Find California Donor Law Unconstitutional

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    The U.S. Supreme Court's decision in Americans for Prosperity Foundation v. Bonta should strike down a California law requiring charities to disclose their donors because the state’s interest in this information is not sufficiently compelling to overcome constitutional rights to free speech and peaceful assembly, says James Skyles at Skyles Law Group and M2M Legal.

  • US Must Boost Solar Industry To Protect Human Rights, Jobs

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    Recent revelations that many solar panels are made using polysilicon from the Xinjiang province of China, allegedly the site of mass forced labor and other abuses, make it all the more urgent that Congress and the Biden administration enact policies that promote American solar manufacturing in place of dumped and artificially cheap Chinese products, says Tim Brightbill at Wiley Rein.

  • What Crypto Holders Can Learn From Early-2000s Tax Scandal

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    The Internal Revenue Service’s recent push to gather information about cryptocurrency accounts is similar to its Swiss bank account investigations of the early 2000s, which should prompt taxpayers to consider voluntarily disclosing transactions before they are individually targeted for enforcement, say Timothy Wagner and Thomas Barnard at Baker Donelson.

  • Bipartisan Support Shows Bright Future For Carbon Capture

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    Recent policy proposals — from the Biden administration as well as members of Congress from both parties — promoting carbon capture, utilization and sequestration suggest that this technology has a key role to play in reducing carbon dioxide emissions, says Kevin Poloncarz at Covington.

  • International Tax Reform's Implications For Transfer Pricing

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    As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.

  • Justices' Preemptive Tax Challenge Ruling Shows Divisions

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    The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service reveals divisions among the justices about when potentially burdensome tax regulations can be challenged, making the holding less clear and less valuable, say George Isaacson and David Swetnam-Burland at Brann & Isaacson.

  • Takeaways From 2 New FBAR Rulings

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    In light of two recent California federal court decisions, capping penalties for nonwillful violations of foreign bank account reporting but broadening the willfulness standard, U.S. taxpayers must be vigilant about understanding their reporting obligations, and prepare for the Internal Revenue Service to target willful conduct, which yields much higher penalties, say Friedemann Thomma and Marianna Felshtiner at Venable.

  • How Biden Tax Plans Would Boost Renewable Energy

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    The Biden administration's recently released revenue proposals for fiscal year 2022 include major enhancements and extensions to various green energy tax credits, and show that the administration is aligned with Congress in supporting renewable development, even if they differ on details, say attorneys at Eversheds Sutherland.

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