Federal

  • January 17, 2023

    Ex-SF Building Official Cops To Ducking Taxes On $1.6M

    An engineering firm owner and ex-president of the San Francisco Building Inspection Commission pled guilty to skipping taxes on $1.6 million in unreported, stolen income, one of several schemes he copped to, including bank fraud and paying off a public official, prosecutors announced.

  • January 17, 2023

    Tax Group Of The Year: Skadden

    Skadden Arps Slate Meagher & Flom LLP's tax team last year helped broker the largest merger deal ever in the video gaming industry, between independent studio Activision Blizzard and tech giant Microsoft, earning the firm a spot among Law360's 2022 Tax Groups of the Year.

  • January 17, 2023

    Justices Won't Hear Mo. Challenge To ARPA Tax Cut Limit

    The U.S. Supreme Court declined Tuesday to hear Missouri's challenge to a federal law that prohibits states from using certain coronavirus aid to offset tax cuts, keeping in place a circuit split over whether states have standing to challenge the law.

  • January 13, 2023

    Law360 Names Practice Groups Of The Year

    Law360 would like to congratulate the winners of its Practice Groups of the Year awards for 2022, which honor the attorney teams behind litigation wins and major deals that resonated throughout the legal industry this past year.

  • January 13, 2023

    New Catch-Up Law Forces Decision For Plans Lacking Roth

    Nonprofits, schools and governments that offer their workers certain retirement plans that lack Roth contribution options will face a decision about whether to add them to allow affluent employees to make catch-up contributions starting in 2024 to meet requirements under a new law.

  • January 13, 2023

    Tax Court Orders Cayman Partnership To Justify Late Args

    A Cayman Islands-based partnership battling tax bills from the Internal Revenue Service has to defend the untimeliness of post-trial arguments it made claiming it shouldn't owe withholding taxes on certain income attributable to foreign partners, the U.S. Tax Court said. 

  • January 13, 2023

    Crypto Donation Deduction Requires Appraisal, IRS Says

    A taxpayer can't take a charitable giving deduction of over $5,000 for the donation of cryptocurrency to a charity without a qualified appraisal, the Internal Revenue Service's Office of Chief Counsel said in memorandum released Friday.

  • January 13, 2023

    Effective Corp. Tax Rates Dropped After TCJA, GAO Says

    Big profitable corporations' effective tax rates dropped and more of those companies owed no federal income tax following the Tax Cuts and Jobs Act's passage, but tax changes to foreign-sourced income expanded the tax base, the U.S. Government Accountability Office reported Friday.

  • January 13, 2023

    Crypto Value Drop Isn't A Loss, IRS Says

    A taxpayer who bought cryptocurrency in 2022 and saw its value plummet to less than a cent, but retained ownership over it at the end of the year, can't take a loss on the steep decline in value, the Internal Revenue Service's Office of Chief Counsel said in memorandum released Friday.

  • January 13, 2023

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin, which included a notice declaring a 3-cent increase in the standard mileage rate for business use to 65.5 cents per mile in the new year.

  • January 13, 2023

    Ga. Business Owner Hit With $2.7M Unpaid Taxes Suit By Feds

    A prominent Georgia business owner, a bankruptcy law firm and a county tax commissioner were slapped with a complaint by the federal government seeking to recover nearly $3 million in unpaid taxes, saying the businessman has continually ignored demands for payment.

  • January 13, 2023

    Taxation With Representation: Skadden, Kirkland, CMS

    In this week's Taxation With Representation, Duck Creek Technologies agreed to be purchased by Vista Equity Partners, Nuvei agreed to buy Paya, BioNTech is to buy the remaining shares of InstaDeep, and Wejo Group Ltd. agreed to merge with TKB Critical Technologies 1.

  • January 13, 2023

    Trump Org. Fined $1.6M After Criminal Tax Fraud Conviction

    A New York state judge on Friday ordered two Trump Organization companies to pay a total of $1.6 million in fines after a jury found they ran a 15-year tax fraud conspiracy to benefit senior executives, saying the former president's corporation has continued to deflect blame.

  • January 12, 2023

    Justices Told To Rebuff Judge's Advice In MoneyGram Suit

    Delaware told the U.S. Supreme Court that it should decline to adopt a special master's recommendation for what would essentially be a split decision in a case that will determine who can claim about $300 million in abandoned MoneyGram checks.

  • January 12, 2023

    Valero Agrees To Drop $408M Fuel Credit Tax Refund Bid

    Valero Energy agreed to drop its bid for a nearly $408 million tax refund involving fuel mixture excise tax credits following a Fifth Circuit decision that sided with the government in a similar case, according to a filing in Texas federal court.

  • January 12, 2023

    NY Accountant's Deficiency Notices Are Valid, Tax Court Says

    A notice of deficiency against a New York accountant for the tax years 2007 through 2013 was valid, and the accountant owes penalties for tardy filings for each year, the U.S. Tax court said Thursday.

  • January 12, 2023

    Raytheon Engineer Can't Deduct Housing, Tax Court Says

    An engineer for defense contractor Raytheon cannot exclude from his reported income the value of his employee housing because it was not located on the military base in Australia where he worked, the U.S. Tax Court ruled Thursday.

  • January 12, 2023

    3rd Circ. Presses US On Mylan's $50M Tax Bill For Court Costs

    A Third Circuit panel questioned the government's position that generic-drug maker Mylan owes $50 million in taxes, asking during oral arguments Thursday why the IRS had suddenly changed its mind in claiming the company shouldn't be allowed to deduct its litigation costs.

  • January 12, 2023

    Late Summons Sinks Ex-CPA's $165K Preparer Penalty Case

    A Colorado federal court tossed a retired certified public accountant's suit over $165,000 in Internal Revenue Service tax preparer penalties, saying he failed to timely serve a summons on the federal government.

  • January 12, 2023

    US Insists It Properly Sued Liberty Global Over $283M In Taxes

    The federal government wasn't required to issue Liberty Global an administrative notice before suing the multinational telecommunications company over $283 million in taxes, the U.S. government told a Colorado federal court, rebutting claims that the lack of a notice kills the case.

  • January 12, 2023

    Tax Season To Start Jan. 23, IRS Says

    The Internal Revenue Service will begin accepting and processing 2022 tax year returns on Jan. 23, the agency said Thursday.

  • January 12, 2023

    Virtual Currency Broker Reporting Rules Pending OMB Review

    Proposed rules for virtual currency sales brokers' information reporting are pending review before a division of the Office of Management and Budget, the office said.

  • January 12, 2023

    IRS Seeks Feedback On Advance Insurance Payment Form

    The Internal Revenue Service said Thursday that it wanted feedback on a form for reporting advance insurance premium payments.

  • January 11, 2023

    Amount B Could Improve Pricing Status Quo, IRS Official Says

    An international agreement to streamline the process for pricing multinational companies' baseline marketing and distribution activities — an approach known as Amount B — could improve the application of the current transfer pricing method for these transactions, an IRS official said Wednesday.

  • January 11, 2023

    Cadwalader Adds Former Cravath Atty To NY Tax Group

    Cadwalader Wickersham & Taft LLP added an attorney from Cravath Swaine & Moore LLP to its tax group in New York, the firm announced.

Expert Analysis

  • MORE Act's Possible Impact On State-Licensed Cannabis Cos.

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    The Marijuana Opportunity Reinvestment and Expungement Act, recently passed in the U.S. House of Representatives, would dramatically alter the federal legal landscape for state-licensed cannabis businesses in both positive and negative ways — from opening new marketing avenues to compounding tax burdens, say attorneys at the Law Offices of Omar Figueroa​​​​​​​.

  • 3 Contract Considerations For Renewable Fuels Trade

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    As renewable fuels continue to develop and contracts for their sale and purchase become more common in the energy industry, companies should think about negotiating several key issues when entering into offtake agreements for feedstock purchase transactions, says Nneka Obiokoye at Holland & Knight.

  • What Microcaptive Reporting Ruling May Mean For The IRS

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    In CIC v. Internal Revenue Service, a Tennessee federal court’s decision to set aside an IRS requirement to disclose microcaptive insurance arrangements may be a step toward evidentiary standards to show that the potential for abuse in a lawful transaction is sufficient to support heightened disclosure requirements, says Samuel Lauricia at Weston Hurd.

  • Avoiding Surprise Taxation Of Employment Settlements

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    Sandra Cohen at Cohen & Buckmann discusses how to avoid unwelcome tax-related payments in connection with settling an employment claim, as the extra cost can significantly decrease the perceived value of an offer and push the parties further apart.

  • US Should Leverage Tax Rules To Deter Business With Russia

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    The U.S. should further restrict the flow of resources available for the Putin regime's war in Ukraine by denying U.S. businesses that operate in Russia or Belarus foreign tax credits and global intangible low-taxed income preferences, and by terminating its tax treaty with Russia, says Reuven Avi-Yonah at University of Michigan Law School.

  • Justices Must Apply Law Evenly In Shadow Docket Rulings

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    In recent shadow docket decisions, the U.S. Supreme Court has inconsistently applied the requirement that parties demonstrate irreparable harm to obtain injunctive relief, which is problematic for two separate but related reasons, says David Hopkins at Benesch.

  • Federal Cannabis Bill Needs A Regulatory Plan To Succeed

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    The Marijuana Opportunity Reinvestment and Expungement Act, which was passed by the U.S. House of Representatives on Friday, is laudable but fundamentally flawed because it lacks a robust regulatory plan that would allow for bipartisan support, says Andrew Kline at Perkins Coie.

  • To Capture All Digital Transactions, Tax Rules Must Keep Up

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    Legislative efforts to capture revenue from digital-transaction income can do better than the American Rescue Plan Act, which recently went into effect but employs definitions that have already been surpassed by technology, says Matthew Agramonte at Shutts & Bowen.

  • Lessons From Recent PPP Loan And COVID Fraud Cases

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    Following President Joe Biden's recent pledge to expand enforcement efforts against pandemic and Paycheck Protection Program loan fraud, a look at the U.S. Department of Justice's recent criminal and civil enforcement actions sheds light on its evolving priorities, say Sara Lord and Aaron Danzig at Arnall Golden.

  • Ampersand Clarifies Power Project Placed-In-Service Analysis

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    The Federal Circuit's recent ruling in Ampersand Chowchilla Biomass v. U.S. affirms a lower court's decision regarding when power generation projects were placed in service for federal income tax purposes, but also highlights that the placed-in-service analysis is not one size fits all, say David Burton and Viktoria Vozarova at Norton Rose.

  • Simplifying Tax Issues For Nonresident Athletes In Canada

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    Tax compliance can be particularly challenging for nonresident professional athletes playing in Canada, but as NHL contract negotiations approach a close, it's worth looking at some ways the tax burden can be mitigated, say Marie-France Dompierre and Marc Pietro Allard at Davies Ward.

  • Steps For Universities As DOJ Shifts Foreign Influence Policy

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    Notwithstanding Wednesday's U.S. Department of Justice announcement terminating the initiative targeting Chinese influence and raising the bar for criminal prosecutions, universities should ensure their compliance controls meet new disclosure standards and that they can efficiently respond to inquiries about employees' foreign connections, say attorneys at Covington.

  • How Gold Coin Tax Ruling May Apply To IRA Crypto Holdings

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    The U.S. Tax Court’s recent decision in McNulty v. Commissioner, affirming that a self-directed individual retirement account owner received taxable distributions in taking possession of her IRA’s gold coins, may have troublesome applications for retirement accounts with cryptocurrency holdings, says Luke Bailey at Clark Hill.

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