Federal

  • December 16, 2022

    CPAs Call For Raising Reporting Threshold For Card Payments

    Congress should walk back new sales reporting requirements for online platforms dealing in credit and debit card payments before tax filing season starts, the American Institute of Certified Public Accountants said Friday, saying the new, lower threshold of $600 will create confusion among taxpayers.

  • December 16, 2022

    Departing Treasury Official Criticizes UN Steps On Int'l Tax

    Countries in the United Nations that recently took steps to consider a bigger role in shaping international tax policy should suspend their efforts and contribute to the ongoing project at the Organization for Economic Cooperation and Development, a departing U.S. Treasury Department official said Friday.

  • December 16, 2022

    Pension Plan Segment Rates Rise In Dec.

    Segment rates for calculating pension plan funding rose in December, the Internal Revenue Service said Wednesday.

  • December 16, 2022

    House Tax Committee To Meet On Trump's Tax Returns

    The House Ways and Means Committee is scheduled to meet next week to consider former President Donald Trump's tax returns, according to a notice Friday.

  • December 16, 2022

    Watchdog's Bid For Trump Tax Whistleblower Docs Tossed

    A D.C. federal court tossed a watchdog's lawsuit seeking Treasury records dealing with its response to an Internal Revenue Service whistleblower's allegation of interference in the agency's audit processes for former President Donald Trump's tax returns, saying the agency sufficiently searched for the documents.

  • December 16, 2022

    Chinese Investor Can't Halt Arbitration In $3M Fraud Dispute

    A California federal judge denied a Chinese investor's request to stop arbitration proceedings relating to his claims that he was the victim of a $3 million tax scheme, saying there are still questions about whether he participated willingly in a contract he claimed was fraudulent.

  • December 16, 2022

    IRS Backlogs Led To Poor Customer Service, GAO Says

    Backlogs and hiring challenges at the Internal Revenue Service led to poor customer service and delays in refunds, the U.S. Government Accountability Office said in a report released Friday.

  • December 16, 2022

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service on Friday released its weekly bulletin, which included guidance for employee retirement plans as well as new interest rates on underpayments and overpayments of taxes.

  • December 16, 2022

    Ex-Iowa Tax Director Named IRS Taxpayer Experience Officer

    The former director of the Iowa Department of Revenue has been named the deputy chief of the Taxpayer Experience Office at the Internal Revenue Service, the agency announced Friday.

  • December 16, 2022

    Taxation With Representation: Wachtell, Davis Polk, Cravath

    In this week's Taxation With Representation, M3-Brigade Acquisition III Corp. will merge with Greenfire, Southwest Gas will sell MountainWest Pipelines, and Weber will be taken private.

  • December 16, 2022

    Surveys, Awards & More: Law360's 2023 Editorial Calendar

    Law360 publishes several award series throughout the year, including ones that highlight top-performing attorneys and practice groups. Here, find all you need to know about our awards and surveys, including due dates, FAQs, and the questions we'll ask so you can prepare ahead of time.

  • December 15, 2022

    FinCEN To Propose Beneficial Owner Registry Access Rules

    The U.S. Treasury Department's financial crimes unit said Thursday it plans to propose rules spelling out when governments and financial institutions may be granted access to so-called beneficial ownership information, following related final rules the unit issued in September.

  • December 15, 2022

    IRS Urges Tax Court To Rethink Nixing Of Easement Notice

    The U.S. Tax Court should reconsider a decision striking down a notice requiring the disclosure of potentially abusive conservation easement transactions, the IRS said, saying the court overlooked the agency's arguments that Congress permitted it to issue such guidance without public feedback.

  • December 15, 2022

    Corp. AMT Guidance May Arrive This Year, Official Says

    The U.S. Treasury Department may issue guidance for the new 15% corporate alternative minimum tax this year, an official said Thursday, noting that the department is trying to prioritize issues that will help more taxpayers sooner.

  • December 15, 2022

    US Asks 5th Circ. To Lift Block On ARPA Tax Cut Limit

    The Fifth Circuit should throw out an injunction that blocks a provision in federal law preventing Texas, Louisiana and Mississippi from using COVID-19 aid to fund tax cuts, the U.S. Department of the Treasury said Thursday.

  • December 15, 2022

    Global Min. Tax Violates Treaties, GOP Lawmakers Say

    Congressional Republicans criticized President Joe Biden's administration for acceding to a backstop to the 15% minimum tax under an international agreement to overhaul the global tax system, telling Treasury that the provision violates current treaties and hurts U.S. companies.

  • December 15, 2022

    Hiring A Priority As IRS Solidifies Funding Plans, Official Says

    The Internal Revenue Service is working to solidify details regarding how it will spend its nearly $80 billion funding boost, and a significant portion will be used for hiring, the agency's acting commissioner said Thursday.

  • December 15, 2022

    IRS Collected $4.9T In Taxes In Fiscal 2022, Report Says

    The Internal Revenue Service collected $4.9 trillion in taxes and remitted $642 billion in refunds in the 2022 fiscal year, according to a report released by the agency Thursday.

  • December 15, 2022

    Holland & Knight Adds Tax Pro From Eversheds Sutherland

    Holland & Knight LLP has added a longtime Eversheds Sutherland tax attorney, who will split his time between its Washington, D.C., and Orange County, California, offices.

  • December 15, 2022

    IRS, DOL Extend Pact To Stop Violations Of Worker Laws

    Aiming to stop businesses from shirking employment taxes and illegally withholding benefits by wrongly classifying workers as independent contractors, the IRS and the U.S. Department of Labor updated their agreement to share information about investigations into labor law violations, the government announced Thursday.

  • December 15, 2022

    OECD May Issue Min. Tax Guidance By Year-End, Official Says

    It's possible the Organization for Economic Cooperation and Development could release guidance before the end of the year that addresses certain administrative aspects of the new international minimum tax rules, including safe harbors, an OECD official said Thursday.

  • December 15, 2022

    Gov't Can't Prove ACA Fines Are Taxes, Retailer Tells DC Circ.

    In its bid to overturn $1.1 million in penalties for failing to offer health insurance to employees, a phone retailer told the D.C. Circuit that the U.S. government failed to prove Congress considered the penalties to be taxes.

  • December 15, 2022

    Partnership Reporting Exception Guidance Set To Be Finalized

    Updates to draft instructions for a domestic filing exception for broad reporting requirements in the form of tax schedules for businesses with foreign interests should be finalized sometime in January, an IRS official said Thursday at a conference in Washington, D.C.

  • December 15, 2022

    Applicable Federal Rates To Drop In January

    Applicable federal rates for income tax purposes will fall to start the new year, the Internal Revenue Service said Thursday.

  • December 15, 2022

    Norton Rose Adds Ex-Dorsey & Whitney Tax Atty In Houston

    A tax attorney with in-house experience at Amazon has joined Norton Rose Fulbright as a partner in Houston after more than a year at Dorsey & Whitney LLP.

Expert Analysis

  • Partial Repeal Could Resolve Biden's SALT Cap Dilemma

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    Lawmakers' calls to repeal the cap on federal deductions for state and local taxes are controversial because doing so could cost over $600 billion, but a partial repeal could be accomplished on a revenue-neutral basis, providing relief to some, if not most, affected taxpayers, says Joseph Mandarino at Smith Gambrell.

  • Alcohol Taxation Provides Good Model For Cannabis Taxes

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    Although the alcohol taxation system isn't perfect, it could serve as a useful template for cannabis taxation with a three-tier licensing scheme and tax rates based on potency, says Louis Terminello at Greenspoon Marder.

  • US Advance Pricing Agreements, Amid COVID And Before

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    Steptoe & Johnson's Matthew Frank, former director of the U.S. Advance Pricing Agreement Program, shares insights from an Internal Revenue Service report revealing an uptick in APA completions amid the pandemic, discusses trends over the program's 30-year history, and suggests ways taxpayers and the IRS could bolster program participation.

  • High Court Hotels.com Case Could Alter Appellate Strategy

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    If the U.S. Supreme Court upholds the Fifth Circuit in the upcoming San Antonio v. Hotels.com case, ruling that district courts may not amend taxable appellate costs, it could reprioritize the incentive structure and decision-making calculus of appeals, says Patrick Hammon at McManis Faulkner.

  • Choosing A Branch Or Subsidiary For Overseas Expansion

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    Samuel Pollack and Naoko Watanabe at Baker McKenzie examine the corporate and U.S. tax law considerations involved in deciding whether a branch or subsidiary is the most efficient way to expand operations overseas, now that recent Treasury regulations clarified the complicated international tax regime created by the Tax Cuts and Jobs Act.

  • Why S Corporation Payments Are Almost Always Wages

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    The recent U.S. Tax Court ruling in Lateesa Ward v. Commissioner has employment and income tax lessons about why payments from an S corporation to its sole shareholder are wages and not distributions of profit in most cases, says Bryan Camp at Texas Tech University School of Law.

  • 3 Arthrex-Adjacent High Court Cases Could Affect PTAB's Fate

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    As patent practitioners await a decision on the constitutionality of Patent Trial and Appeal Board judges in U.S. v. Arthrex, they should keep their eyes on three other pending U.S. Supreme Court cases that, while not IP-related, involve overlapping legal issues, including the severability doctrine, says William Milliken at Sterne Kessler.

  • 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.

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