Federal

  • December 12, 2022

    IRS Finalizes Employee Health Coverage Statement Rules

    The Internal Revenue Service released final rules Monday dealing with reporting minimum essential coverage for health insurance tax laws, including an extension for applicable large employers to provide statements about health insurance offers to full-time employees.

  • December 12, 2022

    IRS Releases Procedures For EV Tax Credit Documentation

    The Internal Revenue Service released procedures Monday for electric vehicle manufacturers to submit written agreements and reports to certify that purchases qualify consumers for various electric vehicle tax credits, saying that required information includes vehicle make and model and battery capacity.

  • December 12, 2022

    Court Asked To Nix $56.5M In Estate Jeopardy Assessments

    The IRS shouldn't go forward with nearly $56.5 million in total jeopardy assessments against a woman's estate and its executor, the executor told a California federal court, saying neither he nor his assets will be moving out of the government's reach.

  • December 12, 2022

    Senate Bill Would Limit Tax Deductions For Large Oil Cos.

    A bill introduced in the Senate would bar oil companies with more than $50 million in gross receipts from claiming an assortment of tax deductions related to natural resources.

  • December 12, 2022

    Staffing Co. Owner Gets 3 Years For $3.4M Payroll Tax Crime

    A Baltimore staffing company owner who served three months in prison for cheating on his tax return almost a decade ago was sentenced in federal court Monday to three years in prison for failing to pay $3.4 million in employment taxes, the full sentence federal prosecutors recommended.

  • December 12, 2022

    FinCEN Extends Deadline For FBAR Signature Authority Filers

    The U.S. Department of the Treasury's Financial Crimes Enforcement Network issued a notice granting another one-year extension for some filers of reports of foreign bank accounts, citing a lack of finalized rules.

  • December 12, 2022

    Firm, Insurer Settle Suit Over Underlying Tax Shelter Claims

    A federal judge dismissed a lawsuit against a Georgia law firm accused of lying on an insurance policy application after the firm and its insurer said they reached a "complicated" settlement related to the firm being accused in a lawsuit of advising clients on illegal tax shelters.

  • December 12, 2022

    Top Firms Make Growth A Priority For 2023

    Law firm leaders are heading into 2023 with caution, anticipating a tighter budget in preparation for a prolonged period of economic challenge, but some BigLaw firms are planning to grow next year, with leaders eyeing opportunities to expand businesses to new locations and add to their attorney headcounts.

  • December 12, 2022

    The 2022 Law360 Pulse Leaderboard

    Check out the Law360 Pulse Leaderboard to see which first-in-class firms made the list this year.

  • December 12, 2022

    IRS Electronic Advisory Committee To Meet Jan. 11

    The Internal Revenue Service's Electronic Tax Administration Advisory Committee will host a meeting Jan. 11, the agency said Monday.

  • December 09, 2022

    Politician's Niece Asks 9th Circ. To Rethink IRS Summons

    The Ninth Circuit should reconsider its decision to enforce an Internal Revenue Service summons over the banking records of a prominent Indian politician's niece, she said in a petition filed Friday seeking the full court's review of the ruling.

  • December 09, 2022

    5th Circ. Stands Firm On Revocation Of Tax Debtor's Passport

    A Texas man remains unable to travel to foreign countries after the Fifth Circuit declined to reconsider its September decision that the U.S. government could revoke his passport as a consequence of his $400,000 tax debt.

  • December 09, 2022

    Amazon Sellers' Group Says 9th Circ. Misapplied Tax Law

    A Ninth Circuit panel erred in concluding that federal courts have no jurisdiction to hear an e-commerce trade group's attempt to block California from pursuing back sales taxes from sellers participating in an Amazon program, the trade group said in asking for a rehearing.

  • December 09, 2022

    Transfer, Distribution Constitute Reorganization, IRS Says

    A business transfer and distribution of controlled stock constitute a reorganization under the tax code, the Internal Revenue Service said in a private letter ruling released Friday.

  • December 09, 2022

    Treasury Proposes Regs For Groups With Foreign Stock Shifts

    The U.S. Treasury Department proposed regulations Friday that would treat members of consolidated groups as a single shareholder of a foreign corporation when stock in the affiliate moves within the group in certain ways that affect taxable offshore income.

  • December 09, 2022

    11th Circ. Urged To Revisit Secretary's Tax Penalty Liability

    The Eleventh Circuit should reconsider its affirmation of a Florida jury's decision that a corporate secretary was responsible for the employment tax noncompliance of her father's air conditioning company and consequently is on the hook for penalties, she told the appeals court.

  • December 09, 2022

    Justices To Review Firms' IRS Bank Summonses Dispute

    The U.S. Supreme Court said Friday it will consider whether the Internal Revenue Service can proceed with summonses seeking the banking records of two law firms and the spouse of a man owing $2 million in taxes without informing them of the requests.

  • December 09, 2022

    The Odd Phrase That Could Flip The Trump Org. Verdict

    After a Manhattan jury convicted the Trump Organization of criminal tax fraud, defense lawyers told Law360 that their appeal would focus on the meaning of a peculiar legal phrase they believe the judge confused, misleading the jury on the key issue of what it takes to convict a company in the Empire State.

  • December 09, 2022

    HMRC Makes Arrests In 'Multimillion-Pound' Till Fraud Probe

    HM Revenue and Customs has arrested five suspects tied to a global fraud operation that allegedly used software to manipulate till transactions, rerouting millions in sales into an offshore bank, the tax authority said Friday.

  • December 09, 2022

    Taxation With Representation: Kirkland, Simpson Thacher, Latham

    In this week's Taxation With Representation, Keurig Dr Pepper will purchase a stake in Nutrabolt, Turkish airliner MNG Airlines will go public, NRG Energy will acquire Vivint Smart Home, and Infrared Cameras Holdings will merge with a technology corporation.

  • December 09, 2022

    IRS Names Calendar Administrators For 44 Tax Court Sessions

    The Internal Revenue Service named calendar administrators for 44 U.S. Tax Court sessions in February and March, according to a notice released Friday.

  • December 09, 2022

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin, which included rules for when tax returns contain adequate information to lower income understatement penalties.

  • December 08, 2022

    UBS Calls $3.8M Disclosure Lawsuit Baseless, Untimely

    Attorneys for UBS asked a New York federal court to dismiss a "baseless" $3.8 million lawsuit from a man who said several bank entities disclosed his wife's address to the IRS, which led to accusations that she failed to report her foreign bank accounts

  • December 08, 2022

    Judge Apologizes For Shaking Up High Court MoneyGram Suit

    A U.S. Supreme Court-appointed special master advising on a dispute over abandoned MoneyGram checks apologized to the justices and to the states involved in the case for partially changing his mind and submitting a revised interim report, according to a transcript released Thursday.

  • December 08, 2022

    8th Circ. Won't Rehear Decision On SD Casino Tax Rules

    The Eighth Circuit will not revisit its decision allowing South Dakota to impose a 2% excise tax on construction work done by a non-tribal company at a Native-owned casino, upholding a ruling that the Flandreau Santee Sioux Tribe says will gut its coffers and erode tribal sovereignty.

Expert Analysis

  • 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.

  • Key Trade Secret Developments Of 2020: Part 2

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    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.

  • A Road Map For US Involvement In Europe's Cum-Ex Probe

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    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.

  • What Energy Sector Should Expect From Biden's Tax Policies

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    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.

  • Congress Should Make TCJA Income Definition Permanent

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    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.

  • Raising Capital For Real Estate Deals During The Pandemic

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    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.

  • Bankruptcy Ruling Highlights Longer Lookback Trend

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    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.

  • OECD Delays Are Imperiling Digital Tax Deal

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    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.

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