Federal
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April 04, 2024
Snell & Wilmer Adds Former McDermott Partner In Dallas
A former McDermott Will & Emery partner and tax specialist has joined Snell & Wilmer's Dallas office to advise clients on cross-border transactions, particularly in Latin America and Mexico.
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April 04, 2024
NC Tax Fraud Trial Evidence Bids Get Lukewarm Reception
A North Carolina federal judge on Thursday seemed reluctant to limit certain evidence against two attorneys and an insurance agent in their upcoming tax fraud trial, saying some of it seemed pertinent to the government's quest to prove intent but suspected other information might be construed by jurors as "petty."
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April 04, 2024
Companies In Limbo As IRS Mulls Waiver For 15% Book Tax
Corporations preparing for their quarterly estimated taxes are uncertain about paying a 15% alternative minimum tax due on April 15, since the Internal Revenue Service granted waivers last year and has yet to release proposed regulations that officials have promised since October.
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April 04, 2024
IRS Penalties Proper In $11B Amgen Dispute, Tax Court Says
The Internal Revenue Service properly authorized penalties included in a tax bill of nearly $11 billion that drugmaker Amgen is challenging, the U.S. Tax Court said Thursday.
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April 04, 2024
Attys Awarded $1.5M In Fees On Tax Disclosure Suit
Attorneys who won a $4.5 million settlement for a class of investors claiming a Chinese startup misrepresented its tax liability will receive their requested $1.5 million in attorney fees, a New York federal judge ruled.
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April 04, 2024
IRS Pushes Back Deadlines For Some RI Taxpayers
Taxpayers in three Rhode Island counties will have until July to file federal tax returns and make payments under an extension granted because of January storms and flooding, the Internal Revenue Service said Thursday.
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April 04, 2024
IRS Pushes Back Tax Deadlines After Maine Storms
Certain Maine taxpayers will have additional time to file tax returns and make payments following storms and flooding in parts of the state, the Internal Revenue Service said Thursday.
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April 04, 2024
Ex-IRS Agent Caused $42.5M In Tax Loss As Preparer, US Says
A tax preparer who once worked for the Internal Revenue Service should be permanently barred from preparing federal returns because he caused an estimated $42.5 million in tax losses by scheming to underestimate his clients' liabilities, the government told a Washington federal court.
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April 04, 2024
Beyoncé's $3M Tax Trial Postponed
The trial scheduled for May in Beyoncé's challenge to a $3 million tax deficiency has been delayed, according to an order Thursday by the U.S. Tax Court.
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April 04, 2024
Project Owners Eager To Sell Energy Tax Credits, Report Says
Project owners are pursuing new financing strategies that would support the early sale of their clean energy tax credits as more projects in their initial development stage this year seek to capitalize on the incentives as early as possible, a report released Thursday said.
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April 03, 2024
NJ Tax Preparer Accused Of $150M COVID Relief Fraud
A New Jersey tax preparer has been indicted over what prosecutors are calling a yearslong scheme in which he filed more than 1,600 bogus tax forms seeking over $150 million in COVID-19-related employment tax credits for his clients and his own businesses that they weren't eligible for, the U.S. Department of Justice announced Wednesday.
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April 03, 2024
IRS Says $28M In Fines Against Microsemi Adhered To Rules
The Internal Revenue Service is again pressing the U.S. Tax Court to rule that it followed supervisory approval requirements when it imposed nearly $28 million in penalties against semiconductor manufacturer Microsemi in a transfer pricing dispute.
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April 03, 2024
McDermott Adds Ex-Baker McKenzie Tax Pro In Chicago
The former chair of Baker McKenzie's Chicago tax practice group has joined McDermott Will & Emery LLP and will work as a partner in the firm's Chicago office, McDermott said Wednesday.
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April 03, 2024
Construction Co. Owner Pleads Guilty In Payroll Tax Case
A construction company owner admitted to not paying more than $800,000 in employer and employee payroll taxes, the U.S. Department of Justice announced.
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April 03, 2024
Aflac Matriarch's Estate Tells Tax Court IRS Can't Bill $9.8M
The Internal Revenue Service improperly issued an assessment of almost $9.8 million against the estate of a matriarch of the family who founded insurance company Aflac, the estate told the U.S. Tax Court.
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April 03, 2024
Salesman Admits Lying To IRS In Tax Preparer's Refund Scam
A timeshare salesman who benefited from a scheme that inflated tax refunds pled guilty to obstruction after lying to Internal Revenue Service agents who sought to collect his 2015 tax refund.
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April 03, 2024
Fed. Circ. Backs Firing IRS Agent Who Golfed On Agency Time
A former senior appraiser for the Internal Revenue Service was appropriately fired for golfing on company time, a federal appeals court affirmed Wednesday.
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April 02, 2024
Hunter Biden Can't Toss 'Vindictive' Criminal Tax Charges
Hunter Biden lost his bid to end his criminal tax case over claims his prosecution is vindictive and politically motivated, among other arguments, after a California federal judge ruled Monday that Biden "filed his motion without any evidence" and merely "cites portions of various internet news sources, social media posts and legal blogs."
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April 02, 2024
Ex-Fuddruckers Franchisee Can't Use NOLs, 11th Circ. Affirms
The U.S. Tax Court correctly ruled that the former owner of failing Fuddruckers franchises cannot deduct $1.8 million in carryover net operating losses because she did not show enough evidence she was entitled to the deductions, the Eleventh Circuit affirmed Tuesday.
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April 02, 2024
Challenges To IRS' Regs On SALT Cap Workarounds Tossed
The Internal Revenue Service and the U.S. Treasury Department won't face challenges from three states and a village in New York to final regulations barring workarounds to the cap on state and local tax deductions due to a New York federal judge's decision.
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April 02, 2024
Feds Seek Use Of 'Intertwined' Evidence In NC Tax Fraud Trial
Federal prosecutors have asked a North Carolina district court to permit tangential evidence in a tax fraud trial, saying that the evidence is "inextricably intertwined with the charged conduct" of two St. Louis attorneys and a North Carolina insurance agent.
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April 02, 2024
NJ Business Owner Charged With Tax Evasion, Failure To File
A New Jersey fireproofing and painting business owner has been charged with 12 counts of failure to file tax returns and six counts of tax evasion, New Jersey federal prosecutors said.
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April 02, 2024
COVID Delay Makes Ohio Pair's Filing Timely, Tax Court Says
The petition of an Ohio couple was timely filed because they were entitled to a 60-day postponement during the early days of the coronavirus pandemic, the U.S. Tax Court ruled Tuesday.
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April 02, 2024
Estate Owes $38K Tax Deficiency, 9th Circ. Affirms
The estate of a woman whose trust transferred $1.06 million to her son before she died owes $38,000 in federal estate taxes because some transfers were loans to prop up his architecture practice, the Ninth Circuit affirmed.
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April 01, 2024
US Support For Pillar 1 Still In Question After House Inquiry
U.S. lawmakers signaled that they think technical and other issues remain in the OECD's Pillar One taxing rights overhaul during a recent House subcommittee meeting, casting further doubt on the plan's implementation as the timeline to finalize it has slipped.
Expert Analysis
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Key Considerations For Seeking Relief From Double Taxation
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.
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High Court Could Resolve Thorny Atty-Client Privilege Issue
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.
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2 Tax Decisions Hold Key Transfer Pricing Takeaways
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.
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Patagonia's Succession Plan Is A Blueprint For Biz Owners
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.
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The CHIPS Act: Key Takeaways For Semiconductor Industry
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.
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Digital Taxation Is Necessary, But Tough To Manage
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.
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5 Considerations When Seeking Federal EV Funding
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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Unpacking The Inflation Reduction Act's Energy Tax Credits
Provisions in the recently enacted Inflation Reduction Act that affect how taxpayers can monetize clean energy tax credits will change how clean energy projects are financed, but taxpayers that may not be allowed multiple credits need to determine which type of credit will be the most advantageous, say attorneys at BakerHostetler.
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How COVID Has Changed Project Development And Finance
Two and a half years into the pandemic, some COVID-19-specific provisions are now common in the project development and finance markets, while others are still undergoing negotiation, say Nate Galer and Katy McNeil at Mayer Brown.
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Unpacking The Shift In DOJ Corporate Enforcement Policy
Attorneys at Paul Hastings provide takeaways for companies seeking to mitigate increased enforcement risks from the U.S. Department of Justice's recent corporate prosecution policy changes, including greater focus on individuals, requirements for cooperation credits, evaluations of prior misconduct, expectations for compliance programs and factors for determining whether to impose a monitor.
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What AML Bill Could Mean For Firms, Funds And FinCEN
If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.
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How Inflation Reduction Act Will Lift Offshore Wind Projects
The Inflation Reduction Act should promote the development of offshore wind energy in multiple ways — including by improving the planning and permitting process for transmission infrastructure, expanding potential lease areas and making beneficial changes to the tax credits available for renewable energy developers, say attorneys at Day Pitney.
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CORRECTED: New Tax Credits For Renewables Should Offer Investors Relief
The Inflation Reduction Act's changes to tax credits for renewable energy projects should finally liberate tax equity investors from the restraints of the complex and onerous federal anti-abuse regime, says Kay Hobart at Parker Poe. Correction: Because of an editing error, a previous version of this article incorrectly characterized tax enforcement regimes in North Carolina and other states. This error has been corrected.