Federal

  • October 25, 2022

    Investment Group Seeks Clarity On Fannie, Freddie's Tax Status

    A lack of clarity regarding the tax-exempt status of Fannie Mae and Freddie Mac is causing headaches in the market for investments in low-income housing credit projects, an investment group said in a letter released Tuesday by the U.S. Department of the Treasury.

  • October 25, 2022

    Corp. Minimum Tax Guidance A High Priority, IRS Official Says

    Guidance on the new corporate alternative minimum tax and its application to split-offs and other transactions is a top priority for the Internal Revenue Service, and the agency is working on identifying the most urgent areas to address, an IRS official said Tuesday.

  • October 25, 2022

    Texas, Miss., La. Urge 5th Circ. To Affirm Win In ARPA Tax Fight

    Texas, Mississippi and Louisiana asked the Fifth Circuit to affirm a judge's injunction barring the federal government from enforcing a provision in the American Rescue Plan Act that prohibits states from using pandemic aid to offset tax cuts.

  • October 25, 2022

    Nonprofits Seek Update To Energy-Efficient Building Deduction

    Four energy-based nonprofits are asking the U.S. Department of the Treasury to update a standard for claiming recently expanded tax deductions for energy-efficient buildings, according to a letter released Tuesday by Treasury.

  • October 25, 2022

    Akin Gump Adds Two Choate Attys To Tax Practice

    Akin Gump Strauss Hauer & Feld LLP said Tuesday it has added two former Choate Hall & Stewart LLP attorneys to its tax practice, one of whom previously worked for the firm.

  • October 25, 2022

    Pa. Court OKs Settlement In Allstate Sales Tax Class Action

    A Pennsylvania federal court approved a class action settlement over the reimbursement of sales tax to customers with leased vehicles that were totaled.

  • October 25, 2022

    Avenatti's Leniency Bid 'Cannot Be Taken Seriously,' Feds Say

    California federal prosecutors have objected to disgraced attorney Michael Avenatti's claims that he should only serve an additional year in prison for stealing from clients, saying the request can't be taken seriously.

  • October 25, 2022

    US Expatriations Roughly Halved In 3rd Quarter, IRS Says

    The number of people expatriated from the U.S. dropped by about half during the third quarter of 2022 compared with the previous quarter, the Internal Revenue Service said in a notice released Tuesday.

  • October 24, 2022

    Attys Sued Over Woman's $4.6M Tax Bill For Yacht Donation

    Two New York attorneys gave a woman and her late husband "highly improper, self-interested and unsound legal advice" concerning a yacht donation that led to a $4.6 million tax bill, she told a federal court Monday, accusing them of malpractice.

  • October 24, 2022

    Fla. Couple Owe Deficiency Of Nearly $5K, Tax Court Says

    A Florida couple owes a tax deficiency of nearly $5,000 because their liability must increase by an excess tax credit benefit that was applied against their monthly health insurance premium, the U.S. Tax Court said Monday.

  • October 24, 2022

    11th Circ. Tosses $26.5M Deduction Appeal Due To Late Filing

    The Eleventh Circuit on Monday dismissed a Georgia partnership's challenge to an Internal Revenue Service decision to block a $26.5 million tax deduction, saying the partnership's lawyers missed the deadline for filing a routine form required by the court.

  • October 24, 2022

    9th Circ. Affirms IRS Summons Of Canadian Couple's Accounts

    The Ninth Circuit on Monday rejected a Canadian couple's challenge to an Internal Revenue Service summons for their bank records, saying the agency correctly issued the summons according to its treaty agreement with the Canadian government.

  • October 24, 2022

    TIGTA Outlines Safety Review Plans, Other Priorities For 2023

    The Treasury Inspector General for Tax Administration's priority programs for 2023 include programs focused on ensuring the safety of Internal Revenue Service employees, TIGTA said in a report released Monday.

  • October 24, 2022

    Trump Organization Jury Pool Winnowed As Some Admit Bias

    Jury selection in the criminal case against the Trump Organization began Monday with dozens of potential jurors seeking to excuse themselves and some expressing bias against the former president's company as they left the courthouse.

  • October 24, 2022

    US Incorrectly Calculates FBAR Penalties, Justices Told

    Penalties for unintentionally failing to disclose foreign bank accounts to the Internal Revenue Service should be assessed for each unfiled form and not per unreported account, a Texas man facing $2.72 million in such penalties told the U.S. Supreme Court.

  • October 24, 2022

    Nonprofit Atty Loses Tax Challenge To Biden Loan Relief Plan

    An Indiana federal judge dismissed a nonprofit attorney's lawsuit against the U.S. Department of Education seeking to shut down President Joe Biden's student debt relief program, saying the lawyer and a fellow worker who claimed the relief would increase their state taxes misplaced the blame.

  • October 24, 2022

    US Eyeing Global Implementation Of OECD Deal, Aide Says

    U.S. lawmakers are closely watching how the European Union and other major economies implement a global deal on changes to the corporate tax system even as the U.S. goes ahead with a law that differs from the global package, a congressional aide said Monday. 

  • October 24, 2022

    IRS Electronic Advisory Committee To Meet Nov. 3

    The Internal Revenue Service's Electronic Tax Administration Advisory Committee will host a meeting Nov. 3, the agency said Monday.

  • October 21, 2022

    8th Circ. Pauses Biden's Student Debt Relief Program

    The Eight Circuit on Friday granted an emergency motion by six Republican-led states to temporarily pause President Joe Biden's student debt relief program while they appeal the dismissal of their challenge by a Missouri federal judge, who found they don't have standing to sue.

  • October 21, 2022

    Virgin Islands Co. Argues Against Container Tax Row Dismissal

    A business urged a Virgin Islands district court to retain jurisdiction over its constitutional challenge to the territory's tax on shipping containers, arguing that the company can't obtain an injunction against the tax in the territory's superior court.

  • October 21, 2022

    The Tax Angle: Rettig's Retirement, Treasury Nominees

    From a look at IRS Commissioner Chuck Rettig's plans once he leaves the agency to nominations for pending tax jobs at Treasury, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • October 21, 2022

    National Grid Faces Proposed Class Actions Over Tax Charges

    Two independent solar energy companies filed a proposed class action against electric giant National Grid in a Massachusetts federal court Friday, arguing the company is illegally charging them for taxes to connect to its grid and flouting government policies promoting renewable energy.

  • October 21, 2022

    IRS To Issue Tax Gap Figures Within Weeks, Rettig Says

    The Internal Revenue Service will likely issue an estimate of the tax gap for 2014-16 and a projection for 2017-19 in the next few weeks, Commissioner Chuck Rettig said Friday.

  • October 21, 2022

    IRS Urges DC Circ. To Uphold $1.1 Million In ACA Penalties

    The Internal Revenue Service asked the D.C. Circuit on Friday to uphold $1.1 million in penalties on a phone retailer that failed to offer employees health insurance, saying the company wrongly claimed the penalties it owes the agency are not taxes.

  • October 21, 2022

    Tax Court Backs Liens In Frivolous Filing Case

    The Internal Revenue Service properly sustained liens seeking to collect $10,000 in frivolous filing penalties for 2016 and 2017 and a liability of over $363 million for 2018 assessed against a D.C. man, the U.S. Tax Court said Friday.

Expert Analysis

  • Surveying Global Tax Updates For Sovereign Wealth Investors

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    As the market transitions to a post-pandemic phase, sovereign wealth fund and other foreign institutional investors must evaluate how recent U.S., EU and U.K. tax changes may affect their private fund investments, say attorneys at Morgan Lewis.

  • Offshore Wind Push Is Good News For NYC Building Owners

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    With a surge of federal and state support for offshore wind power in New York state, the projects now in development should greatly benefit New York City building owners seeking to comply with the city's Climate Mobilization Act, says Raymond Pomeroy at Stroock.

  • Coke, 3M Tax Cases May Not Settle Blocked Income Debate

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    Even if the challenged U.S. Department of the Treasury regulation on blocked income is struck down by the U.S. Tax Court in the pending Coca-Cola and 3M cases, the obligations of a taxpayer that had, but failed to avail itself of, alternative means to secure payment will remain an open question, say Matthew Frank and Amanda Varma at Steptoe & Johnson.

  • OCC Rule Misaligned With Some Tax Equity Safe Harbors

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    The Office of the Comptroller of the Currency's recently finalized rule on national banks' participation in tax equity financings aligns with safe harbor guidance for renewable energy investments, but not with safe harbor structures for historic preservation and carbon capture tax credits, say attorneys at Nixon Peabody.

  • IRS Should Level The Field For R&D Tax Credits

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    A recent increase in denials of research and development tax credits to small businesses in the architectural, engineering and construction community shows the Internal Revenue Service should issue new guidance to ensure a fair playing field and an opportunity to continue innovating in the U.S., says Julio Gonzalez at Engineered Tax Services.

  • IRS Should Revise Private Debt Collection Methodology

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    To fulfill the congressional intent underlying the Taxpayer First Act, which aims to protect delinquent taxpayers from entering into payment plans they cannot afford, the Internal Revenue Service should use both last-return-filed and third-party income information in its methodology for identifying low-income taxpayers, says National Taxpayer Advocate Erin Collins.

  • Applying OECD Guidance On COVID-19 Transfer Pricing

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    In light of the recently released Organization for Economic Cooperation and Development's guidance on the transfer pricing implications of the pandemic, taxpayers should be prepared to explain and defend their transfer pricing decisions for fiscal year 2020 for contemporaneous documentation and in future tax audits, say Susan Fickling and TJ Michaelson at Duff & Phelps.

  • A Tough Road Ahead for Democrats' Ambitious Policy Agenda

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    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.

  • Coca-Cola Tax Ruling Offers 5 Lessons For Multinationals

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    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.

  • Small Biz Should Self-Advocate For Tax Relief Under Biden

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    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.

  • SD Ruling Threatens Marijuana Legalization Momentum

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    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.

  • Opportunity Zone Pandemic Relief Is Welcome, But Limited

    Excerpt from Practical Guidance
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    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.

  • Driving Forces Shaping The Life Settlements Market

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    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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