Federal

  • September 22, 2022

    Trump Fraud Referrals Present Political Minefield For DOJ, IRS

    The New York attorney general's criminal referrals to the U.S. Department of Justice and the IRS stemming from her probe of former President Donald Trump will force prosecutors to walk a political tightrope, given Trump's accusations of bias and Republicans' animus toward the IRS.

  • September 22, 2022

    Senate GOP Wants Details On IRS Funding Boost Allocation

    Senate Finance Committee Republicans on Thursday requested information from the Internal Revenue Service about how the agency will use the $80 billion funding boost passed by Congress under the Inflation Reduction Act.

  • September 22, 2022

    Cisco Allows Vote On Public Country-By-Country Reporting

    Cisco shareholders will vote on public country-by-country reporting of tax payments, profits and workers, as the corporation becomes the first in the U.S. not to legally challenge such a proposal, according to a statement from investors obtained Thursday by Law360.

  • September 22, 2022

    Tax Software Investor Asks Court To Block $8.4B Vista Deal

    An investor in tax software company Avalara asked a New York federal court Thursday to block the company's $8.4 billion merger with private equity fund Vista Equity Partners Management, accusing Avalara of failing to disclose pertinent financial details.

  • September 22, 2022

    Bill Seeks To Make Parts Of 2017 Tax Overhaul Permanent

    A bill introduced in the U.S. House of Representatives would make permanent some tax cuts for individuals included in the 2017 Republican tax overhaul.

  • September 22, 2022

    MVP: Skadden's Nathan W. Giesselman

    Nathan W. Giesselman, tax partner at Skadden Arps Slate Meagher & Flom LLP, has worked on major deals, including a $30 billion joint venture where he represented Intel, earning him a spot among Law360's 2022 Tax MVPs.

  • September 22, 2022

    Holland & Knight Adds Partner To Public Finance Tax Practice

    Holland & Knight LLP said Wednesday it has strengthened its public finance practice with the addition of a former Hawkins Delafield & Wood LLP partner.

  • September 22, 2022

    Georgia Pastor Sentenced For COVID-19 Relief Fraud

    A Georgia man with several careers, including as a pastor and tax preparer, was sentenced on Tuesday to over two years in prison, after pleading guilty to making false statements to receive COVID-19 relief loans and buying a Mercedes with the money.

  • September 22, 2022

    IRS To Automatically Share Some Interest Info With Turkey

    The Internal Revenue Service on Thursday added Turkey to a list of jurisdictions with which it will automatically share some deposit information regarding nonresident aliens.

  • September 21, 2022

    Meet The Lawyers On Deck In NY V. Trump Biz Fraud Case

    The New York attorney general's blockbuster fraud suit against former President Donald Trump, three of his adult children and the Trump organization will pit some of the family's fiercest defenders against a team of seasoned prosecutors.

  • September 21, 2022

    Tax Court Denies Deductions To Ill. Farm Owners

    Two operators of an Illinois farm group whose members the IRS said owe $14 million in personal income tax deficiencies cannot deduct farm expenses from personal income, the U.S. Tax Court said Wednesday, saying shareholders must keep company accounting separate.

  • September 21, 2022

    Backlogs Persist At IRS Processing Centers, TIGTA Says

    The Internal Revenue Service still has significant inventory backlogs at its three tax processing centers around the country, and hiring shortfalls of needed employees are hindering efforts to reduce them, a watchdog report released Wednesday said.

  • September 21, 2022

    IRS Should Take More Transition Tax Actions, Watchdog Says

    The Treasury Inspector General for Tax Administration on Wednesday outlined additional actions the IRS could take to ensure compliance with the 2017 federal overhaul's transition tax, including by following up on individuals who were encouraged to file amended returns.

  • September 21, 2022

    Ariz. Gov. Asks 9th Circ. To Revive Suit Over COVID Funds

    Arizona Gov. Doug Ducey told the Ninth Circuit that the federal government went too far in restricting how the state could use pandemic relief funds, arguing a lower court misread the American Rescue Plan Act when tossing the governor's suit.

  • September 21, 2022

    Wyden Probes More Insurers Over Tax-Free Insurance Plans

    Senate Finance Committee Chair Ron Wyden on Wednesday pressed Prudential Financial and Zurich Insurance over the growing use of special life insurance policies as tax shelters in an escalation of his inquiry into the practice that began last month.

  • September 21, 2022

    NY AG Tells 2nd Circ. Trump Can't Revive Harassment Claim

    New York Attorney General Letitia James urged the Second Circuit to deny a bid by former President Donald Trump to challenge her investigation into his business dealings, arguing that Trump is trying to improperly revive his already rejected harassment claim.

  • September 21, 2022

    MVP: Quinn Emanuel's Liesl Fichardt

    Liesl Fichardt of Quinn Emanuel Urquhart & Sullivan LLP helped settle a $198 billion tax battle between Barrick Gold and the Tanzanian government, resolving a long-running dispute that created a template for business-government partnerships in the continent and earning her a spot among Law360's 2022 Tax MVPs.

  • September 21, 2022

    Greenberg Traurig Adds Global Tax Pro From KPMG

    Greenberg Traurig LLP landed a top tax attorney from KPMG LLP as a shareholder in its global tax practice, the firm has announced.

  • September 21, 2022

    NY AG James Sues Trump, Alleging $250M Business Fraud

    New York Attorney General Letitia James filed suit Wednesday against former President Donald Trump, his children and company executives, seeking the return of $250 million in allegedly ill-gotten gains from a 10-year scheme to defraud banks using misleading financial statements.

  • September 20, 2022

    Employment Tax Schemer Will Pay His Part Of $6M Restitution

    The U.S. Department of Justice and a naturalized U.S. citizen who admitted to defrauding the IRS of more than $3.5 million in employment taxes, told a Florida federal court Tuesday that the citizen will pay his portion of the $6 million in restitution he and other co-conspirators owe the federal government.

  • September 20, 2022

    US Seeks To Force Property Sale To Pay Man's $1.8M Tax Bill

    The U.S. asked a California federal court Tuesday to foreclose on a property allegedly owned by a man convicted of tax evasion, saying it wants the proceeds to pay down his more than $1.8 million in tax liabilities.

  • September 20, 2022

    House Panel Rejects GOP's Global Tax Deal Info Request

    The House Ways and Means Committee voted along party lines Tuesday to reject a Republican resolution that would have requested information on the Organization for Economic Cooperation and Development's global tax deal from the U.S. Department of Treasury.

  • September 20, 2022

    AMT Takes Pragmatic Approach To Big Cos., Dem Staffer Says

    A federal 15% alternative minimum tax involves a "commonsense approach" for determining whether multinational corporations — including those with foreign parents — are subject to the levy and whether they remain under the regime, a Democratic Senate Finance Committee staffer said Tuesday.

  • September 20, 2022

    Mylan Flags Claims Court Ruling In $50M Tax Fight At 3rd Circ.

    A recent Court of Federal Claims decision supports Mylan Inc.'s challenge to a $50 million tax bill by bolstering its argument that it's entitled to deduct the costs of patent litigation suits, Mylan told the Third Circuit.

  • September 20, 2022

    Labor Rules Key To Unlocking 'Bonus' Clean Energy Credits

    Large-scale clean energy construction projects that seek to claim the full value of the production or investment tax credit must now meet labor standards for the first time under Democrats' recently passed landmark climate and tax law.

Expert Analysis

  • Tips On Qualified Small Business Stock Exclusions

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    While awaiting more Internal Revenue Service guidance on the maze of requirements a taxpayer must satisfy for the qualified small business stock exclusion, there are steps proactive taxpayers can take to ensure their ability to establish their qualifications if they are audited, says Stephen Josey at Kostelanetz & Fink.

  • Inside The OECD Transfer Pricing Documentation Guidance

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    The Organization for Economic Cooperation and Development's recently modified documentation guidelines can assist tax administrations in developing requirements for transfer pricing risk assessments and evaluations, and help multinational entity taxpayers demonstrate satisfaction of the arm's-length principle, says Neil Aragones at Lexis Tax.

  • Superfund Tax Is Back: Implications For Chemical Industry

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    In light of the Internal Revenue Service's recently issued guidance on the reinstated Superfund tax, manufacturers, producers and importers should review their existing agreements that involve taxable chemicals and substances to determine who will be commercially responsible for the tax, say attorneys at Eversheds Sutherland.

  • Tech Co.'s Suit May Create Hurdles For Research Tax Credits

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    The recently filed U.S. Tax Court case Perficient v. Commissioner — challenging standards under research credit regulations that determine whether research is funded by any grant or contract — could make it difficult to substantiate research tax credits, say Dennis St. Martin and Kevin Benton at Grant Thornton.

  • Expected Retirement Law Changes May Spark ERISA Suits

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    As Congress is poised to pass bipartisan retirement legislation that could bring collective investment trusts and 403(b) plans together and may form a new wave of litigation under the Employee Retirement Security Act, it is helpful to review the important roles that they have played in prior waves of ERISA excessive fee cases, say attorneys at King & Spalding.

  • A Close Look At The Decentralized Effort To Tax Digital Assets

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    Clarity on taxation is one of the biggest hurdles to mass adoption of cryptocurrency, and although digital asset innovation has consistently outpaced worldwide government regulation, recent efforts in the U.S. and elsewhere hint at an emerging standard, says Joshua Smeltzer at Gray Reed.

  • Lessons From The SEC's Largest-Ever Audit Firm Penalty

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    The U.S. Securities and Exchange Commission's recent $100 million settlement over professional test cheating with Ernst & Young — the largest ever in an audit firm case — points to important ramifications for any entity responding to an SEC inquiry, say attorneys at Cleary.

  • Navigating The IRS Pre-Audit Retirement Plan Pilot Program

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    The Internal Revenue Service launched a Pre-Examination Compliance Pilot program for retirement plans last month that gives sponsors and administrators 90 days to self-correct errors and avoid audits, and while several details are unclear, there are important steps to take at this time, say attorneys at Ice Miller.

  • Key Takeaways From IRS Reversal On FDII Stance

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    The Internal Revenue Service's recent memo regarding allocation of deferred compensation expenses for purposes of foreign-derived intangible income is a departure from the agency's previous position and may have implications beyond the context of deferred compensation, say attorneys at Miller & Chevalier.

  • How To Address Research Expenditures Amid Uncertainty

    Taxpayers need to prepare for the significant technical and compliance challenges of following Internal Revenue Code Section 174's new rules for experimentation expenditure capitalization and amortization, notwithstanding the rules' unresolved legislative future, say tax advisers at Grant Thornton.

  • LeClairRyan Bankruptcy Highlights Pass-Through Tax Issue

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    A Virginia bankruptcy court's recent ruling in the case of defunct law firm LeClairRyan shows there may be serious tax consequences for pass-through entity partners who give up their ownership interest without following operating agreement exit provisions and updating bankruptcy court filings, say Edward Schnitzer and Hannah Travaglini at Montgomery McCracken.

  • Tax, Social Services And The Need For An IRS Overhaul

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    Revamping the Internal Revenue Service should start with visibly improving taxpayer experiences to help pave the way for other fundamental changes needed to address the recent drop in audit numbers, personnel losses, burdens of its increasing expansion into social services and other problems, says Rice University fellow Joyce Beebe.

  • Key Legal And Regulatory Trends In Oil And Gas Transactions

    Excerpt from Practical Guidance
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    Attorneys involved in oil and gas transactions must be aware of important legal and regulatory trends that have emerged recently, including issues surrounding hydraulic fracturing, climate change, pipeline tariffs and a resurgence of regulation under the Biden administration, say Justin Hoffman and Thomas Blackwell at Baker Botts.

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