Federal

  • November 04, 2022

    9th Circ. Vacates Denial Of Ex-DOJ Atty's IRS Court Costs

    The Ninth Circuit on Friday undid a U.S. Tax Court decision denying a former Department of Justice attorney $31,600 in litigation costs after he successfully challenged an IRS bill, finding the lower court should consider his challenges to the agency's litigation position.

  • November 04, 2022

    No Trial Needed For Most Of $21M FBAR Case, Gov't Says

    The U.S. government urged a Florida federal court to reject arguments from a Texaco heiress' estate that's fighting more than $20.9 million in offshore account penalties, contending that the only dispute for a jury is whether her conduct was willful.

  • November 04, 2022

    IRS Seeks Comments On Real Estate Interest Transfer Form

    The Internal Revenue Service said Friday that it wanted comments on a form for reporting certain real estate mortgage investment conduit interest transfers.

  • November 04, 2022

    House Bill Would Exclude Military Needs Allowance From Income

    The basic needs allowance would be excluded from the gross income calculation of members of the U.S. military under a bill introduced in the House of Representatives.

  • November 04, 2022

    10th Circ. Rejects Ex-Ballard Spahr Partner's Energy Credits

    The U.S. Tax Court properly denied depreciation deductions and energy credits to an ex-Ballard Spahr LLP partner caught up in a $50 million solar tax credit scheme, the Tenth Circuit said Friday, finding his solar lens business activities lacked a profit motive.

  • November 04, 2022

    Trump Org. Trial Delayed Again With Key Witness Still Unwell

    The Manhattan district attorney's criminal case against the Trump Organization was delayed again Friday when the judge learned company controller and lead witness Jeffrey McConney was "still sick" with COVID-19, a court official said, pushing trial back another week.

  • November 04, 2022

    OECD's Former Tax Chief Leaves Institution Transformed

    Pascal Saint-Amans, who stepped down as the Organization for Economic Cooperation and Development's tax chief this month, is leaving at a time when what is arguably his greatest achievement, a sweeping agreement signed by 137 countries a year ago, is crumbling.

  • November 04, 2022

    Fla. Executors Say IRS Owes Canadian's Estate $500K

    The IRS must refund an incorrectly assessed income tax payment of more than $500,000 to a Canadian estate that should have received a deduction for Quebec estate taxes paid on $1.4 million, Florida executors said in a complaint filed in federal court.

  • November 04, 2022

    Taxation With Representation: Simpson Thacher, Davis Polk

    In this week's Taxation With Representation, Blackstone Inc. will buy a majority stake in a portion of Emerson Electric Co., shareholders are taking Atlas Corp. private, Johnson & Johnson will buy Abiomed, and a joint venture acquired a timberlands portfolio.

  • November 04, 2022

    CBD Co., Founder Ordered To Arbitrate Over $5M Tax Bill

    A Nevada federal judge ordered a CBD company fighting with its co-founder over who should pay a $5 million tax bill to resolve the issue in arbitration, saying federal laws and contracts the parties signed require it.

  • November 04, 2022

    IRS Urges Enforcement Of Summons On Org. In Tax Probe

    A Louisiana federal court should force a foundation to comply with an Internal Revenue Service summons seeking records for its investigation of a company's tax compliance, the agency told the court.

  • November 04, 2022

    Appeals Office Bringing Back Workers Who Eased Backlogs

    Some employees in the IRS Independent Office of Appeals who joined an agencywide effort to address amended return and correspondence backlogs caused by COVID-19 will return to the department in the 2023 fiscal year, according to the office's focus guide released Friday.

  • November 04, 2022

    IRS Seeks Feedback On Settlement Fund Reporting Rules

    The Internal Revenue Service asked for comments Friday on a regulation that governs reporting for funds created for settlements.

  • November 03, 2022

    GOP Urges Treasury To Reverse Hungary Tax Treaty Withdrawal

    The U.S. Treasury Department should reconsider its decision to withdraw from a bilateral tax treaty with Hungary because it appears retaliatory for the country's opposition to the OECD's corporate global minimum tax, according to a letter sent Thursday by top congressional Republicans.

  • November 03, 2022

    Midterms Unlikely To Revive Debate Over Int'l Taxes In US

    The midterm elections are unlikely to jump-start Congress into considering changes needed to align the U.S. international tax regime with an OECD minimum tax, but the outcome will influence how lawmakers prepare for a debate involving global reforms and expiring tax cuts in the years to come.

  • November 03, 2022

    IRS Criminal Investigation Head Plans Big Hiring Boost

    The Internal Revenue Service's criminal investigation arm aims to hire more than 500 workers in the 2023 fiscal year, including 360 special agents, its chief said Thursday.

  • November 03, 2022

    3rd Circ. Affirms Convictions For False Tax Return Prep

    The Third Circuit on Thursday affirmed a man's convictions for assisting in preparing false tax returns, rejecting his argument that a lower court lacked jurisdiction because he had renounced his U.S. citizenship.

  • November 03, 2022

    IRS Seeks Comments On Debt Instrument Reporting Rules

    The Internal Revenue Service said on Thursday that it wants comments on rules for reporting contingent payment debt instruments.

  • November 03, 2022

    IRS Tax-Exempt Arm Focused On Rolling Out Direct Pay Rules

    The Internal Revenue Service Tax-Exempt and Government Entities Division is "vigorously focused" on developing a new regime for public utilities and other tax-exempt entities to directly receive payment of clean energy tax credits under the Democrats' new climate law, the division commissioner said Thursday.

  • November 03, 2022

    Treasury Seeking Input On Tax, Climate Bill Energy Provisions

    The U.S. Treasury is seeking public input on clean energy tax provisions of the Inflation Reduction Act, including on the new credit for clean commercial vehicles, the updated carbon capture credit and an extended incentive for electric vehicle charging stations, the department said Thursday. 

  • November 03, 2022

    Treasury Pressed On $1B In Improper Child Tax Credits

    Treasury should provide details on how it plans to recoup over $1 billion in advance child tax credits paid to people who weren't eligible for them, Republican leaders of the House Ways and Means and Budget committees said Thursday.

  • November 03, 2022

    US Urges Nix Of $638K Investment Tax Refund Suit

    The U.S. government asked a California federal court to dismiss a man's request for a $638,000 net investment income tax refund, saying he wrongly believed foreign tax credits should offset his bill.

  • November 03, 2022

    Court Orders Trump Org. Monitor During NY AG's Fraud Case

    A New York judge ordered the Trump Organization to install an independent monitor Thursday, ruling in favor of the state attorney general amid her $250 million fraud lawsuit against former President Donald Trump, his companies and its officers.

  • November 03, 2022

    Ex-Mass. Police Union Head, Lobbyist Guilty In Kickback Trial

    The former head of the Massachusetts state police union was convicted by a Boston federal jury Thursday of steering business to a Beacon Hill lobbyist in exchange for kickbacks, an across-the-board win for prosecutors in the public corruption case.

  • November 03, 2022

    Rep. Tells IRS To Review Conservative Nonprofit's Exempt Status

    The Internal Revenue Service should investigate potential tax status violations by a conservative nonprofit that sent out anti-transgender political mailers, a Democratic member of the House of Representatives told IRS Commissioner Charles Rettig.

Expert Analysis

  • 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.

  • What Tax Court's Mylan Legal Fee Ruling Means For IP Suits

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    The U.S. Tax Court's recent ruling that Mylan Inc. could deduct as regular business expenses the legal fees it incurred defending itself against patent infringement suits from brand-name drug manufacturers has the potential to increase patent litigation and may make settlement less appealing, say attorneys at Snell & Wilmer.

  • Biden's Clean Energy Goals Require Big Hydrogen Push

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    To realize its ambitious renewable energy goals, the Biden administration, along with Congress, must promote the growth of the hydrogen industry using every available tool, including regulations, grants, tax incentives and direct purchases, say Abdon Rangel at Andersen Tax and John Taylor at King & Spalding.

  • IRS Summons Ruling Isn't A Total Loss For Investors

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    A California federal court’s recent order allowing an IRS information summons on cryptocurrency exchange Kraken paradoxically provides hope for investors concerned about their privacy by limiting the scope of the agency’s inquiry, says Joshua Smeltzer at Gray Reed.

  • Justices' Nod To Preemptive Tax Challenges May Caution IRS

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    The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service, allowing pre-enforcement challenges of tax reporting rules despite the Anti-Injunction Act, is likely to make the U.S. Department of the Treasury more careful about its own compliance obligations under the Administrative Procedure Act, says Robert Carney at Caplin & Drysdale.

  • Let's End The Offshoring Of US Patents

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    Congress should work toward removing the loophole that allows companies to avoid U.S. taxes by moving their patents offshore, and ensure profits are taxed where the sales take place, says Sen. Patrick Leahy, D-Vt.

  • How Biden's First 100 Days Will Affect Gov't Contractors

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    Joseph Berger and Thomas Mason at Thompson Hine examine the significant opportunities for government contractors arising from actions during the first 100 days of the Biden administration, which set the stage for unprecedented investment in national infrastructure, domestic manufacturing, research and development, clean energy, pandemic response and economic recovery.

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