Federal
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February 12, 2023
IRS Phone Service Aided By Funding Boost, Official Says
The IRS' phone service has significantly improved in the first two weeks of this year's tax filing season thanks to the billions of dollars in additional funding the agency received from the Inflation Reduction Act last summer, according to a Treasury official.
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February 11, 2023
Buyback Tax Regs Must Be Practical, Treasury Official Says
The IRS and Treasury are working to get out proposed rules on the new excise tax on stock repurchases while also trying to ensure that the agency can administer and enforce the rules, a Treasury official said Saturday.
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February 11, 2023
IRS Won't Tax Most State Inflation Relief Payments
The IRS won't tax payments from a majority of states that issued special rebates to taxpayers last year among cost-of-living increases and the ongoing pandemic, the agency announced, with tax-free treatment applying to 17 state rebates and others meeting certain requirements.
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February 10, 2023
US Crypto Broker Rules Pending, Treasury Lawyer Says
The U.S. Treasury Department and the Internal Revenue Service have approved proposed rules on the U.S. reporting requirements for cryptocurrency brokers that are pending review by the White House before being published, a Treasury attorney said Friday.
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February 10, 2023
Fed. Circ. Affirms Toss Of Religious Org's Tax Status Suit
A religious organization can't proceed with a lawsuit seeking a court declaration that it's a church and doesn't count as a private foundation under the tax code. as the Federal Circuit affirmed a lower court's dismissal of the case on Friday.
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February 10, 2023
House Tax Writer Says Chinese Cos. Safe From Backstop Rule
Chinese companies that have government backing won't be negatively impacted by a backstop rule in the global minimum tax package, but U.S. companies will be, the House of Representatives' top tax writer said Friday in a letter to the OECD.
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February 10, 2023
DLA Piper Adds Ex-Baker McKenzie State And Local Tax Atty
DLA Piper added a former Baker McKenzie partner to its tax practice in New York who will focus on state and local taxation, the firm announced.
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March 02, 2023
Law360 Seeks Members For Its 2023 Editorial Boards
Law360 is looking for avid readers of its publications to serve as members of its 2023 editorial advisory boards.
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February 10, 2023
Russian Gas Exec Can't Hide Financial Docs In $93M Tax Case
A Russian gas executive accused of hiding $93 million from the Internal Revenue Service in overseas accounts may not exclude foreign financial documents from his trial next month, a Florida federal judge ruled, rejecting the executive's claim that the documents were untrustworthy.
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February 10, 2023
2nd Circ. Rejects Ex-Credit Union CEO Corrupt-Payout Appeal
The former CEO of Melrose Credit Union lost his Second Circuit appeal Friday challenging his conviction and nearly four-year prison sentence for accepting unlawful gratuities from a taxi mogul.
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February 13, 2023
CORRECTED: Corporate AMT Rules Will Evolve, Official Says
The Internal Revenue Service and U.S. Treasury Department will produce more guidance on the corporate alternative minimum tax after their initial publication of a so-called guidance framework, a department official said at a conference Friday.
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February 10, 2023
Taxation With Representation: Kirkland, Debevoise
In this week's Taxation With Representation, CVS Health acquires a senior-focused clinic operator, Brookfield Reinsurance buys Argo Group International, Holcim targets Duro-Last, and two cryptocurrency companies plan to merge.
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February 10, 2023
Weekly Internal Revenue Bulletin
The Internal Revenue Service released its weekly bulletin, which included updated rules saying some real estate developers can use an abridged form when applying to use the alternative cost method when determining the basis of improved units for 2023 and onward.
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February 09, 2023
Tax Pros Push Back On Proposed Limits On IRS Appeals
Some tax professionals are continuing to push for the IRS Independent Office of Appeals to consider taking on cases involving challenges to the validity of agency guidance, despite proposed regulations saying the office wouldn't generally accept such administrative appeals.
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February 09, 2023
Eaton's $9M Agreement With IRS OK'd By Tax Court
Multinational power management company Eaton Corp. was liable for $9.3 million for tax years 2005 and 2006 under a settlement approved by the U.S. Tax Court and obtained Thursday by Law360.
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February 09, 2023
US Chamber Asks FASB To Disclose Tax Project Consultants
The Financial Accounting Standards Board, a nonprofit that oversees generally accepted accounting principles, should disclose those it has consulted for its project on income tax disclosures by companies, the U.S. Chamber of Commerce said in a letter to the group.
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February 09, 2023
Tax Court Sides With IRS In 3M Transfer Pricing Dispute
The Internal Revenue Service wasn't required to account for Brazilian legal restrictions on royalty payments when allocating income from 3M's Brazilian affiliate, the U.S. Tax Court ruled Thursday, upholding contested regulations at the center of a long-running transfer pricing dispute.
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February 09, 2023
Tax Court Upholds $15K Penalty Following Approval Challenge
A $15,000 penalty assessment against a New Jersey man will stand because it didn't require approval by an Internal Revenue Service supervisor, the U.S. Tax Court said Thursday.
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February 09, 2023
IRS Too Slow On State Rebate Guidance, Advocate Says
The IRS' failure to issue timely guidance on the federal tax treatment of special state tax payments has put taxpayers in an uncomfortable position, National Taxpayer Advocate Erin Collins said Thursday, because they have to wait to file or file now and risk reporting the payments inaccurately.
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February 09, 2023
DC Circ. Skeptical Of Claim That ACA Penalties Aren't Taxes
The D.C. Circuit questioned a phone retailer's argument challenging $1.1 million in taxes for failing to offer employees health insurance, with the court saying Thursday that Congress warned of such a levy by calling the penalty a tax in the Affordable Care Act.
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February 08, 2023
CPAs Urge Equalization Of Health Insurance Deductions
Congress should provide the same tax treatment for health insurance tax deductions for employees and for the self-employed, the American Institute of Certified Public Accountants said in a collection of legislative proposals announced Wednesday.
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February 08, 2023
US, Biz Owner Seek To Resolve $4M FBAR Case Without Trial
A $4.3 million fight over a business owner's failure to report her foreign bank accounts may be resolved without a trial as the U.S. government and the owner have asked a California federal court for summary judgment, according to a joint memorandum.
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February 08, 2023
Court Urged To Keep Suit Over IRS Crypto Doc Seizure Alive
A New Hampshire federal court shouldn't toss a man's suit disputing the Internal Revenue Service's procurement of his records relating to his cryptocurrency transactions, he said, arguing that he's made viable constitutional challenges to the agency's acquisition of the documents.
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February 08, 2023
Talks Hit Impasse In Former Mobil Oil Exec's $6.4M Tax Case
Talks to settle a former Mobil Oil Corp. executive's $6.4 million income tax case have come to a halt, a mediator told a Florida federal court Wednesday.
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February 08, 2023
Senate Committee Schedules Hearing For IRS Nominee
The Senate Finance Committee will hold a hearing Feb. 15 about President Joe Biden's nomination of former acting Internal Revenue Service Commissioner Daniel Werfel to lead the agency, the committee announced Wednesday.
Expert Analysis
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A Benefits Attorney's Role In Corporate Transactions: Part 1
Excerpt from Practical Guidance
Employee benefits and executive compensation attorneys must consider a spate of issues in the context of a corporate transaction, including the due diligence process and identification of plan-related liabilities, says Michelle Capezza at Epstein Becker.
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How Biden Administration Can Crack Down On Ransomware
By using the novel prosecutorial tactic known as access theory, President-elect Joe Biden can initiate a 2021 offensive to stop ransomware, says John Stark at John Reed Stark Consulting.
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US Economy Needs Cannabis Banking Bill More Than Ever
The cannabis industry is helping generate much-needed tax revenue and has kept people employed during the pandemic — it's time to provide these essential businesses with mainstream banking services, says Aaron Smith at the National Cannabis Industry Association.
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7 Considerations For Gift And Estate Valuation Amid COVID-19
As pandemic-related uncertainty continues to challenge business appraisals this year, practitioners should know that methods exist to help produce reliable gift and estate valuations, says Angela Sadang at Marks Paneth.
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Blockchain Holds Potential For Commercial Real Estate
Blockchain-based tokenization of commercial real estate has the capacity to bring about a paradigm shift in how real estate finance is conducted, as lower intermediary costs and minimum investment requirements unlock trillions of dollars in illiquid global real estate assets, says Josh Morton at Pillsbury.
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Prep For Increased Pay Equity Enforcement In Gov't Contracts
Federal contractors can prepare for an uptick in Office of Federal Contract Compliance Programs compensation enforcement under President-elect Joe Biden by conducting regular pay equity audits that identify and resolve gender- and race-based compensation disparities, says Jack Blum at Polsinelli.
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Top 10 Employer Resolutions For 2021
As the new year begins, employers will need to plan for several paradigm shifts, including the potential for tougher independent contractor classification standards, state-level medical and recreational marijuana legalization, and federal and state changes to paid and unpaid leave, say Allegra Lawrence-Hardy and Linda Spencer at Lawrence & Bundy.
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Mitigating IRS Cryptocurrency Enforcement Risk In 2021
The IRS seems poised to shift focus in 2021 from education to enforcement of virtual currency tax laws, and noncompliant taxpayers should consider whether they are eligible to file amended returns or voluntary disclosures to mitigate the risk of civil penalties, criminal investigation or prosecution, say Don Fort and Lawrence Sannicandro at Kostelanetz & Fink.
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2020's Key Tax Controversy Developments
Andrew Roberson and Kevin Spencer at McDermott highlight 2020's key tax controversy developments, offering their perspective on important tax decisions, the Internal Revenue Service’s cooperative audit program, informal tax return amendment procedures, Large Business & International Division campaigns, and handling virtual appeals conferences during the pandemic.
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What The Biden Administration Can Expect From State AGs
With the nationwide split between Republican and Democratic state attorneys general unchanged post-election, the Biden administration can anticipate challenges to major health care, energy and environmental policy initiatives, continued activity from state solicitors general, and increased consumer protection enforcement, say William Hurd and Christopher Carlson at Troutman Pepper.
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Justices Likely To Shield Treasury From Preemptive Action
Recent U.S. Supreme Court oral arguments in CIC Services v. Internal Revenue Service suggest the court will resolve a circuit split by ruling the Anti-Injunction Act shields the U.S. Department of the Treasury from preemptive challenges — bad news for those hoping to challenge unfavorable regulations, says Monte Silver at Silver & Co.
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Outlook For Digital Assets May Improve In 2021
Attorneys at Ropes & Gray evaluate several factors that may advance the burgeoning blockchain industry, such as the proliferation of decentralized tokens, the creation and acceptance of digital asset trading platforms, and greater clarity on tax and regulatory structure.
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Opportunity Zone Investment Options Should Be Expanded
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Future opportunity zone legislation should limit the capital gains requirement and broaden tax incentives to allow participation from currently excluded investors with deep connections to community revitalization, says Venroy July at Miles & Stockbridge.