Federal
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February 13, 2023
IRS Kicks Off 'Bridge-Plus' Pilot For Real-Time Audit Program
The Internal Revenue Service announced Monday a new pilot phase of its popular real-time audit program for large companies considered to be a low compliance risk that will grant them access to an agency review of their tax returns.
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February 13, 2023
Tax Court OKs Failure-To-File Addition On Man's Tax Debt
A Massachusetts man owes an addition to his 2017 tax debt for failing to file his taxes for that year because he didn't show his failure was reasonable, the Tax Court said Monday.
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February 13, 2023
CohnReznick Secretly Diverted Tax, Partnership Tells Court
A housing partnership accused accounting firm CohnReznick LLP of professional negligence and fraud, telling a New York federal court that the firm secretly helped a general partner scheme to strip the partnership of millions in tax payments on an affordable housing project sale.
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February 13, 2023
Ex-Minneapolis Public Defender Lied On Taxes, Feds Say
A former chief public defender in Minneapolis has been charged by federal prosecutors with failing to pay taxes for his law firm and falsifying his own returns.
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February 13, 2023
Tax Overpayment, Underpayment Rates To Hold Steady In Q2
The Internal Revenue Service interest rates for tax overpayments and underpayments will hold steady in the second quarter of 2023, the agency announced Monday.
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February 13, 2023
TIGTA Urges IRS To Create Multiyear Exam Resource Plan
The Internal Revenue Service should consider creating a plan that will help guide resource allocations among the agency's tax examination divisions over multiple years, the Treasury Inspector General for Tax Administration said Monday.
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February 13, 2023
OMB To Review Proposed Superfund Tax Rules
Proposed rules for the taxes connected to the Superfund program are pending review with a division of the Office of Management and Budget, the office said.
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February 12, 2023
IRS Phone Service Aided By Funding Boost, Official Says
The IRS' phone service has significantly improved in the first two weeks of this year's tax filing season thanks to the billions of dollars in additional funding the agency received from the Inflation Reduction Act last summer, according to a Treasury official.
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February 11, 2023
Buyback Tax Regs Must Be Practical, Treasury Official Says
The IRS and Treasury are working to get out proposed rules on the new excise tax on stock repurchases while also trying to ensure that the agency can administer and enforce the rules, a Treasury official said Saturday.
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February 11, 2023
IRS Won't Tax Most State Inflation Relief Payments
The IRS won't tax payments from a majority of states that issued special rebates to taxpayers last year among cost-of-living increases and the ongoing pandemic, the agency announced, with tax-free treatment applying to 17 state rebates and others meeting certain requirements.
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February 10, 2023
US Crypto Broker Rules Pending, Treasury Lawyer Says
The U.S. Treasury Department and the Internal Revenue Service have approved proposed rules on the U.S. reporting requirements for cryptocurrency brokers that are pending review by the White House before being published, a Treasury attorney said Friday.
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February 10, 2023
Fed. Circ. Affirms Toss Of Religious Org's Tax Status Suit
A religious organization can't proceed with a lawsuit seeking a court declaration that it's a church and doesn't count as a private foundation under the tax code. as the Federal Circuit affirmed a lower court's dismissal of the case on Friday.
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February 10, 2023
House Tax Writer Says Chinese Cos. Safe From Backstop Rule
Chinese companies that have government backing won't be negatively impacted by a backstop rule in the global minimum tax package, but U.S. companies will be, the House of Representatives' top tax writer said Friday in a letter to the OECD.
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February 10, 2023
DLA Piper Adds Ex-Baker McKenzie State And Local Tax Atty
DLA Piper added a former Baker McKenzie partner to its tax practice in New York who will focus on state and local taxation, the firm announced.
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March 02, 2023
Law360 Seeks Members For Its 2023 Editorial Boards
Law360 is looking for avid readers of its publications to serve as members of its 2023 editorial advisory boards.
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February 10, 2023
Russian Gas Exec Can't Hide Financial Docs In $93M Tax Case
A Russian gas executive accused of hiding $93 million from the Internal Revenue Service in overseas accounts may not exclude foreign financial documents from his trial next month, a Florida federal judge ruled, rejecting the executive's claim that the documents were untrustworthy.
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February 10, 2023
2nd Circ. Rejects Ex-Credit Union CEO Corrupt-Payout Appeal
The former CEO of Melrose Credit Union lost his Second Circuit appeal Friday challenging his conviction and nearly four-year prison sentence for accepting unlawful gratuities from a taxi mogul.
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February 13, 2023
CORRECTED: Corporate AMT Rules Will Evolve, Official Says
The Internal Revenue Service and U.S. Treasury Department will produce more guidance on the corporate alternative minimum tax after their initial publication of a so-called guidance framework, a department official said at a conference Friday.
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February 10, 2023
Taxation With Representation: Kirkland, Debevoise
In this week's Taxation With Representation, CVS Health acquires a senior-focused clinic operator, Brookfield Reinsurance buys Argo Group International, Holcim targets Duro-Last, and two cryptocurrency companies plan to merge.
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February 10, 2023
Weekly Internal Revenue Bulletin
The Internal Revenue Service released its weekly bulletin, which included updated rules saying some real estate developers can use an abridged form when applying to use the alternative cost method when determining the basis of improved units for 2023 and onward.
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February 09, 2023
Tax Pros Push Back On Proposed Limits On IRS Appeals
Some tax professionals are continuing to push for the IRS Independent Office of Appeals to consider taking on cases involving challenges to the validity of agency guidance, despite proposed regulations saying the office wouldn't generally accept such administrative appeals.
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February 09, 2023
Eaton's $9M Agreement With IRS OK'd By Tax Court
Multinational power management company Eaton Corp. was liable for $9.3 million for tax years 2005 and 2006 under a settlement approved by the U.S. Tax Court and obtained Thursday by Law360.
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February 09, 2023
US Chamber Asks FASB To Disclose Tax Project Consultants
The Financial Accounting Standards Board, a nonprofit that oversees generally accepted accounting principles, should disclose those it has consulted for its project on income tax disclosures by companies, the U.S. Chamber of Commerce said in a letter to the group.
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February 09, 2023
Tax Court Sides With IRS In 3M Transfer Pricing Dispute
The Internal Revenue Service wasn't required to account for Brazilian legal restrictions on royalty payments when allocating income from 3M's Brazilian affiliate, the U.S. Tax Court ruled Thursday, upholding contested regulations at the center of a long-running transfer pricing dispute.
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February 09, 2023
Tax Court Upholds $15K Penalty Following Approval Challenge
A $15,000 penalty assessment against a New Jersey man will stand because it didn't require approval by an Internal Revenue Service supervisor, the U.S. Tax Court said Thursday.
Expert Analysis
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A Tough Road Ahead for Democrats' Ambitious Policy Agenda
While Democrats in Congress are well on their way to enacting an initial COVID-19 relief bill, they will face challenges when pivoting to President Joe Biden's Build Back Better goals for job creation and economic revitalization, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.
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Coca-Cola Tax Ruling Offers 5 Lessons For Multinationals
The U.S. Tax Court's decision that Coca-Cola owes more than $3.3 billion in taxes is instructive on important transfer pricing concepts, including those regarding intercompany agreements, the arm's-length standard and tax certainty, says Justin Radziewicz at Duff & Phelps.
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Small Biz Should Self-Advocate For Tax Relief Under Biden
Small and medium-sized businesses have significant potential for achieving regulatory relief from the U.S. Department of the Treasury and other federal agencies during the Biden administration, but to do so they must define their priorities, leverage two federal statutes that require the Treasury to protect them and make their voices heard through communal e-advocacy, says Monte Silver at Silver & Co.
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SD Ruling Threatens Marijuana Legalization Momentum
A South Dakota state court decision in Thom v. Barnett, invalidating a state constitutional amendment legalizing recreational marijuana, serves as a reminder that legalization efforts at any level could meet some resistance, says David Standa at Locke Lord.
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Opportunity Zone Pandemic Relief Is Welcome, But Limited
Excerpt from Practical Guidance
The Internal Revenue Service's new notice relaxing deadlines and requirements for opportunity zone investors during the pandemic is helpful, but misses an opportunity to clarify important safe harbors, says Jessica Millett at Duval & Stachenfeld.
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Driving Forces Shaping The Life Settlements Market
The life settlements market is evolving as a result of several recent legislative developments and cases concerning stranger-originated life insurance, and will likely see continued growth this year, say Brian Casey and Thomas Sherman at Locke Lord.
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Key Trade Secret Developments Of 2020: Part 2
Last year, federal courts issued several important rulings on trade secret issues that will affect litigation practice, including the importance of narrow, well-supported sealing requests, whether refining trade secret identification after discovery is permissible, and when punitive damages comport with due process, say attorneys at Faegre Drinker.
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A Road Map For US Involvement In Europe's Cum-Ex Probe
The dividend arbitrage trading strategy known as cum-ex continues to face regulatory scrutiny in Europe, and stateside regulators may soon follow suit with the U.S. Securities and Exchange Commission’s recent American depositary receipt probe as a guide for enforcement, says Joshua Ray at Rahman Ravelli.
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What Energy Sector Should Expect From Biden's Tax Policies
The energy sector may find new investment opportunities or the need to adjust holdings, depending on whether company goals align with the Biden administration's potential rollback of Trump-era tax reforms, and push for clean energy, reduced carbon emissions and increased domestic manufacturing, says Gregory Matlock at Mayer Brown.
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Congress Should Make TCJA Income Definition Permanent
Congress should not allow the Tax Cuts and Jobs Act's definition of adjusted taxable income, which includes depreciation and amortization, to expire in 2022 because it would discourage debt-free investment, running counter to the law's intent, says George Callas at Steptoe & Johnson.
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Raising Capital For Real Estate Deals During The Pandemic
Real estate sponsors looking to invest in the current environment should consider the various advantages and risks of forming a commingled real estate investment fund versus raising capital on a deal-by-deal basis, says Matt Ertman at Allen Matkins.
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Bankruptcy Ruling Highlights Longer Lookback Trend
The U.S. Bankruptcy Court's recent decision in Zagaroli underscores a trend among bankruptcy courts to allow longer lookback periods in certain types of fraudulent transfer cases, which could be a significant source of estate recovery for creditors, say attorneys at Lowenstein Sandler.
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OECD Delays Are Imperiling Digital Tax Deal
As the Organization for Economic Cooperation and Development continues to push back its deadline for a digital tax overhaul, countries are beginning to pursue unilateral solutions and the negotiations are turning political, decreasing the likelihood of an agreement, says Joyce Beebe at Rice University.