Federal

  • October 03, 2022

    IRS Can Seize $1.4B In Property From Dead Software CEO

    A Texas federal judge approved what the IRS calls its largest immediate property seizure in history, a jeopardy collection of $1.4 billion against a deceased software CEO accused of unloading assets as the government closed in on him.

  • October 03, 2022

    IRS To Waive Dyed Fuel Penalties After Hurricane Ian

    The Internal Revenue Service will waive penalties on the sale of some dyed diesel fuel for emergency vehicles responding to Hurricane Ian in Florida, the agency said.

  • October 03, 2022

    Justices To Review Firm's Bid To Shield Client Tax Comms

    The U.S. Supreme Court said Monday it will consider a law firm's bid to shield client communications from grand jury subpoenas seeking documents on its tax advice in a case concerning the scope of attorney-client privilege over mixed-use legal advice.

  • September 30, 2022

    The 5 Biggest Cases This Supreme Court Term

    The reversal of constitutional abortion protections last term has court watchers wondering: Is affirmative action next? But the lawsuits against Harvard University and the University of North Carolina are far from the only blockbusters on the docket in what is likely to be another landslide term for conservatives. Here, Law360 breaks down five cases to watch. 

  • September 30, 2022

    5th Circ. Won't Rethink Exxon's $1B Tax Refund Bid

    The Fifth Circuit on Friday stood by its decision to reject Exxon Mobil's $1 billion tax refund bid for its oil-and-gas agreements with Qatar and Malaysia, declining to hear the company's contention that the ruling conflicts with the appellate court's precedent.

  • September 30, 2022

    The Tax Angle: Corporate Book Taxes And Retirement Savings

    From the possibility of changes to the 15% alternative minimum tax on corporations to progress on retirement security legislation, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • September 30, 2022

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin, which included segment rates for calculating pension plan funding in September.

  • September 30, 2022

    US Gov't Sues NY Man To Collect FBAR Penalties

    A New York man owes the Internal Revenue Service almost $600,000 after failing to report his foreign bank accounts on his tax returns, the U.S. government said in a complaint filed in federal court.

  • September 30, 2022

    Biz Group Renews Call To Delay Foreign Tax Credit Regs

    The National Foreign Trade Council asked the U.S. Treasury Department for a second time Friday to delay the effective date for final foreign tax credit rules, citing proposed revisions that have yet to be issued.

  • September 30, 2022

    No Signs Of Supreme Court's Conservatives Slowing Down

    The U.S. Supreme Court's last term was considered by many to be the most consequential in a generation as the court's conservative justices delivered key victories on abortion and guns. But one quick glance at the new term's docket suggests this new supermajority has only just begun shifting the law to the right.

  • September 30, 2022

    IRS Beats Claims It Exposed Atty's Tax Info In Reg Dispute

    A D.C. federal court on Friday tossed a lawsuit from an expatriate attorney alleging the Internal Revenue Service improperly disclosed his returns and other sensitive records while defending itself against his challenges to international tax regulations.

  • September 30, 2022

    5th Circ. Won't Revisit Denial Of Man's $338K Jet Deduction

    The Fifth Circuit on Friday declined to reconsider its decision that a Texas man couldn't claim a $338,000 deduction for donating his interest in a jet to a charitable organization, according to an order from the appeals court.

  • September 30, 2022

    How Well Do You Know Supreme Court History?

    As the U.S. Supreme Court kicks off its October 2022 term, it's the perfect time to dive into the court's history. Law360 will try to stump you with this 10-question quiz about the court. 

  • September 30, 2022

    Taxation With Representation: Sullivan & Cromwell, Skadden

    In this week's Taxation With Representation, Provident Financial Services Inc. will acquire Lakeland Bancorp, EQT has agreed to purchase BTRS Holdings Inc., and Brookfield Renewable is acquiring Scout Clean Energy and Standard Solar.

  • September 30, 2022

    Bipartisan Bill Would Stop Taxation Of Broadband Grants

    A bipartisan group of U.S. senators introduced legislation Thursday that excludes some broadband infrastructure grants from taxable income.

  • September 30, 2022

    Texas Tax Preparers Agree To Pay $7.5M Over Bogus Refunds

    Texas tax preparers accused of falsely claiming $53 million on behalf of their clients, including coronavirus aid, settled with the government, agreeing to stop preparing taxes and to pay $7.5 million, according to a federal court.

  • September 30, 2022

    Justice Ketanji Brown Jackson Takes Bench, Makes History

    Justice Ketanji Brown Jackson received her official commission Friday in a ceremony attended by President Joe Biden and Vice President Kamala Harris, becoming the first Black female justice to take the nation's top bench in its 230-year history.

  • September 29, 2022

    Harris Says US Will Consult With S. Korea On EV Tax Credit

    Vice President Kamala Harris sought to assure President Yoon Suk Yeol of South Korea on Thursday about the country's issues with a U.S. law that will change the eligibility criteria for electric vehicle tax incentives, the White House said.

  • September 29, 2022

    Sens. Seek To Bar Tax Deductions For Athletes' NIL Pay

    Two U.S. senators are pushing a legislative proposal to deny charitable contribution tax deductions for donations used to compensate secondary or college athletes for use of their names, images and likenesses.

  • September 29, 2022

    NRA Can't Stop NY AG From Seeking Compliance Monitor

    A New York state judge in Manhattan said Thursday it's too soon to rule out an independent compliance monitor as a potential remedy in state Attorney General Letitia James' financial probe of the National Rifle Association, rejecting the gun organization's bid to dismiss newly added claims.

  • September 29, 2022

    Colo. Man Owes $450K In FBAR Case, US Says

    A Colorado man owes almost $450,000 in penalties and interest for failing to report his overseas bank accounts to the Internal Revenue Service, the U.S. said in a complaint filed in federal court Thursday.

  • September 29, 2022

    NY AG Seeks Fast-Tracked Trump Fraud Trial Before 2024

    The New York attorney general Thursday pushed for trial to start before 2024 in a $250 million fraud case against Donald Trump, asking to keep the case before the same state court judge who held Trump in contempt over her subpoenas, due to his knowledge of the case.

  • September 29, 2022

    Treasury Issues Final Beneficial Ownership Reporting Rules

    The U.S. Treasury Department's financial crimes unit issued final regulations Thursday that largely retain the overall framework of proposed guidance that aims to shine a light on shell companies by requiring businesses to report information about so-called beneficial owners.

  • September 29, 2022

    IRS Gives Extensions To Hurricane Ian Victims

    Taxpayers impacted by Hurricane Ian in Florida have until Feb. 15 to submit some returns and payments, the Internal Revenue Service said Thursday.

  • September 29, 2022

    Tax Court Lets Man Duck Fines For Claims Deemed Meritless

    A North Carolina man is liable for additions to his tax liabilities for failing to file his returns for a couple of years, but doesn't owe penalties for making groundless arguments challenging the IRS, the U.S. Tax Court said Thursday.

Expert Analysis

  • 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

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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.

  • Employer Considerations For Leave Donation Programs

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    As the battle for talent continues and workers return to the office, companies may consider allowing employees to donate accrued leave time to a shared bank, but employers should first review these programs' complex design issues to comply with state laws and avoid tax consequences, says Rebecca Hudson at Holland & Hart.

  • Crypto Cos. Should Prep For More IRS John Doe Summonses

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    In anticipation of new reporting requirements that will go into effect in 2024, cryptocurrency exchanges and custodians should inform themselves on the John Doe summons, a unique mechanism that allows the IRS to obtain expansive information about cryptocurrency transactions, say Shivani Poddar and Andrew Heighington at Herrick Feinstein.

  • Employer Travel Benefits Options For Abortion Care Post-Roe

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    Given the likelihood that Roe v. Wade will be overturned, and with the proliferation of state legislation restricting abortion access, employers may want to consider the legal implications of several options to expand travel reimbursement benefits for employees who seek abortion services, say Danita Merlau and Ben Conley at Seyfarth.

  • Global Tax Chiefs Should Look To US Whistleblower Programs

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    As the Joint Chiefs of Global Tax Enforcement develops its international whistleblower program to address tax evasion and money laundering schemes in new areas like cryptocurrency, it should take lessons from highly successful U.S. programs on which features to include and pitfalls to avoid, say Neil Getnick and Nico Gurian at Getnick & Getnick.

  • Crypto Investors May Face Increasing State FCA Tax Liability

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    Cryptocurrency investors who fail to report the state tax consequences of transactions are poised to encounter increased civil or criminal legal exposure as a growing number of states bring tax fraud under the purview of their whistleblower statutes, say attorneys at Brownstein Hyatt.

  • Justices' Boechler Ruling May Spell Tax Exceptionalism's End

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    By basing its decision on cases outside the tax arena, the U.S. Supreme Court treated Boechler v. Commissioner as an administrative law case rather than a tax case and stripped away the traditional lines of tax exceptionalism, says James Creech at Baker Tilly.

  • MORE Act's Possible Impact On State-Licensed Cannabis Cos.

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    The Marijuana Opportunity Reinvestment and Expungement Act, recently passed in the U.S. House of Representatives, would dramatically alter the federal legal landscape for state-licensed cannabis businesses in both positive and negative ways — from opening new marketing avenues to compounding tax burdens, say attorneys at the Law Offices of Omar Figueroa​​​​​​​.

  • 3 Contract Considerations For Renewable Fuels Trade

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    As renewable fuels continue to develop and contracts for their sale and purchase become more common in the energy industry, companies should think about negotiating several key issues when entering into offtake agreements for feedstock purchase transactions, says Nneka Obiokoye at Holland & Knight.

  • What Microcaptive Reporting Ruling May Mean For The IRS

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    In CIC v. Internal Revenue Service, a Tennessee federal court’s decision to set aside an IRS requirement to disclose microcaptive insurance arrangements may be a step toward evidentiary standards to show that the potential for abuse in a lawful transaction is sufficient to support heightened disclosure requirements, says Samuel Lauricia at Weston Hurd.

  • Avoiding Surprise Taxation Of Employment Settlements

    Excerpt from Practical Guidance
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    Sandra Cohen at Cohen & Buckmann discusses how to avoid unwelcome tax-related payments in connection with settling an employment claim, as the extra cost can significantly decrease the perceived value of an offer and push the parties further apart.

  • US Should Leverage Tax Rules To Deter Business With Russia

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    The U.S. should further restrict the flow of resources available for the Putin regime's war in Ukraine by denying U.S. businesses that operate in Russia or Belarus foreign tax credits and global intangible low-taxed income preferences, and by terminating its tax treaty with Russia, says Reuven Avi-Yonah at University of Michigan Law School.

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