Federal

  • September 16, 2022

    Prof Says Tax Rap In China-Ties Case Doesn't Merit Prison

    An Illinois math professor convicted of concealing a Chinese bank account should serve no prison time because he immediately took steps to fix the issue and fully repaid taxes he owed to the IRS, he said in a filing ahead of his sentencing Monday.

  • September 16, 2022

    Taxation With Representation: White & Case, Wachtell, Fenwick

    In this week's Taxation With Representation, Apollomics Inc. will merge with Maxpro Capital Acquisition Corp., Lavoro Ltd. reached a deal to merge with a blank-check company, and Adobe Inc. reached an agreement to acquire Figma Inc.

  • September 16, 2022

    IRS Says Applicable Federal Rates To Rise In October

    Applicable federal rates for income tax purposes will rise in October, the Internal Revenue Service said Friday.

  • September 16, 2022

    Improperly Forgiven PPP Loan Part Of Gross Income, IRS Rules

    A taxpayer who improperly had her Paycheck Protection Program loan forgiven must include the amount of the forgiven loan in her gross income, the IRS Office of Chief Counsel said in a ruling released Friday.

  • September 16, 2022

    MVP: Cravath's Lauren Angelilli

    Lauren Angelilli — the first woman to lead Cravath Swaine & Moore LLP's tax department — advised Canadian National Railway Co. in a proposed $33.6 billion combination with Kansas City Southern, earning her a spot as one of Law360's 2022 Tax MVPs.

  • September 16, 2022

    11th Circ. Upholds 11-Yr. Prison Sentence In Fla. Tax Scheme

    The Eleventh Circuit rejected the latest appeal of a Florida tax preparer convicted in a false return scheme, saying prejudicial statements by government attorneys at her trial don't warrant reconsideration of her 11-year prison sentence.

  • September 16, 2022

    ​​​​​​​No Weekly Internal Revenue Bulletin Articles For Sept. 19

    The Internal Revenue Service released its weekly bulletin, which said there were no articles to be published for Sept. 19.

  • September 15, 2022

    Deputy AG Reveals New DOJ Corporate Enforcement Strategy

    Deputy Attorney General Lisa Monaco on Thursday unveiled a series of new U.S. Department of Justice policies for corporate crime enforcement, warning cooperating companies not to slow-walk disclosures, telling prosecutors to speed things up and expanding self-reporting programs across the department.

  • September 15, 2022

    5th Circ. Upholds Revoking Man's Passport For Unpaid Taxes

    The Fifth Circuit on Thursday upheld a ruling revoking a man's passport because of his $400,000 tax debt, saying U.S. Supreme Court guidance shows that the freedom to travel internationally isn't a fundamental right protected by the U.S. Constitution.

  • September 15, 2022

    IRS Action Knowledge Bars Investor Suit Coverage, Court Told

    A company isn't covered in underlying litigation contending it promoted conservation easement transactions that exposed investors to Internal Revenue Service scrutiny because it knew several transactions had been disallowed before an effective date in its insurance policy, the company's insurers told a Georgia federal court.

  • September 15, 2022

    Challenge To IRS Life Insurance Guidance Barred, US Says

    An Arizona federal court should dismiss a recruiting firm's case seeking to undo an IRS requirement to disclose potentially abusive life insurance plans because the lawsuit is barred by a law prohibiting challenges to tax collection, the government said.

  • September 15, 2022

    NJ Diamond Dealer Agrees To Pay $1.3M In FBAR Case

    A diamond dealer agreed Thursday to pay $1.3 million as part of a consent judgment in New Jersey federal court settling allegations that he failed to report his overseas bank accounts.

  • September 15, 2022

    Ex-Uber Exec Wrongly Escaped Tax On Settlement, Court Told

    A bankruptcy court wrongly relieved an ex-Uber Technologies executive who pled guilty to stealing Google's trade secrets — but was pardoned by former President Donald Trump — from paying taxes on a settlement, California's tax agency told a federal court.

  • September 15, 2022

    SEC Eyeing Public Country-By-Country Reporting, Chair Says

    The U.S. Securities and Exchange Commission is looking at whether, to mitigate risks, investors need large multinational corporations to publicly report each country where they book profits and pay taxes, SEC Chair Gary Gensler told a Senate committee Thursday.

  • September 15, 2022

    IRS Taking Real-Time Audit Program Applications

    Publicly traded companies with assets of $10 million or more can apply for the Internal Revenue Service's real-time audit program for 2023 until Nov. 15, the agency said Thursday.

  • September 15, 2022

    Qualified Intermediary Application Deadline Is Sept. 30

    Taxpayers have until the end of the month to apply for agreements under the Qualified Intermediary, Withholding Foreign Partnership, Withholding Foreign Trust Application & Account Management System for 2022, the Internal Revenue Service said in a reminder Thursday.

  • September 15, 2022

    Yellen Says IRS To Staff Tax Centers With Funding Boost

    The Internal Revenue Service will use a recent funding boost passed by Congress to fully staff all the agency's tax assistance centers, U.S. Treasury Secretary Janet Yellen said Thursday.

  • September 15, 2022

    TIGTA Says Lien Notices IRS Sent Not Always Timely

    Though the Internal Revenue Service mostly sent lien notices on time from July 2020 through June 2021, 14.5% of a sample examined by the Treasury Inspector General for Tax Administration were sent late, TIGTA said Thursday.

  • September 15, 2022

    TIGTA Says Entities With Tax Debts Get $32.9B In Fed. Awards

    From October 2018 to December 2019, federal awards worth $32.9 billion went to nearly 4,000 contractors and grantees that were delinquent on their taxes, the Treasury Inspector General for Tax Administration said Thursday.

  • September 15, 2022

    Judge Spares Calif. Retreat Center, For Now, In $1M Tax Case

    A federal judge delayed foreclosure Thursday on a retreat center owned by a California sleep clinic founder and his wife accused of owing $1 million in taxes after they promised they could sell other properties to cover the debt.

  • September 15, 2022

    Ex-Partner Accuses EY Of Retaliation Over Tax Whistleblowing

    A former Ernst & Young partner specializing in transfer pricing accused the accounting giant of violating whistleblower protections, saying the firm retaliated against her after she raised concerns that clients were committing tax and securities fraud in intercompany transactions.

  • September 14, 2022

    Gov't Subpoenas Limited In Captive Health Plan Tax Suit

    A Florida federal court narrowed subpoenas served on clients of a man the government claims misrepresented the tax consequences of illegitimate health plans, ruling Wednesday that they didn't have to provide information about claim histories or the insured's taxes.

  • September 14, 2022

    IRS Releases Foreign Insurance Calculation Guidelines

    The Internal Revenue Service on Wednesday published values for certain foreign insurance companies to use when calculating their minimum effectively connected net investment income for taxable years beginning after Dec. 31, 2020.

  • September 14, 2022

    Man Concealed $1M From IRS, Filed False Forms, Tax Court Says

    A Florida man's estate is liable for fraud penalties after the U.S. Tax Court found Wednesday that he failed to disclose over $1 million to the IRS, used foreign bank accounts to conceal funds and filed false tax forms.

  • September 14, 2022

    IRS Must First Tackle Paper Backlog, Taxpayer Advocate Says

    The Internal Revenue Service's top priority for the funding boost recently approved by Congress should be eliminating its paper return backlog before moving forward on improving its overall operations, National Taxpayer Advocate Erin Collins said Wednesday.

Expert Analysis

  • What Crypto Holders Can Learn From Early-2000s Tax Scandal

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    The Internal Revenue Service’s recent push to gather information about cryptocurrency accounts is similar to its Swiss bank account investigations of the early 2000s, which should prompt taxpayers to consider voluntarily disclosing transactions before they are individually targeted for enforcement, say Timothy Wagner and Thomas Barnard at Baker Donelson.

  • Bipartisan Support Shows Bright Future For Carbon Capture

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    Recent policy proposals — from the Biden administration as well as members of Congress from both parties — promoting carbon capture, utilization and sequestration suggest that this technology has a key role to play in reducing carbon dioxide emissions, says Kevin Poloncarz at Covington.

  • International Tax Reform's Implications For Transfer Pricing

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    As the Organization for Economic Cooperation and Development overhauls the global tax rules on base erosion and profit shifting, and the Biden administration rolls out new U.S. tax proposals, multinational enterprises need to prepare for the effects of these tax changes on their transfer pricing structures, say Mandy Li and Shuang Feng at MGO.

  • Justices' Preemptive Tax Challenge Ruling Shows Divisions

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    The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service reveals divisions among the justices about when potentially burdensome tax regulations can be challenged, making the holding less clear and less valuable, say George Isaacson and David Swetnam-Burland at Brann & Isaacson.

  • Takeaways From 2 New FBAR Rulings

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    In light of two recent California federal court decisions, capping penalties for nonwillful violations of foreign bank account reporting but broadening the willfulness standard, U.S. taxpayers must be vigilant about understanding their reporting obligations, and prepare for the Internal Revenue Service to target willful conduct, which yields much higher penalties, say Friedemann Thomma and Marianna Felshtiner at Venable.

  • How Biden Tax Plans Would Boost Renewable Energy

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    The Biden administration's recently released revenue proposals for fiscal year 2022 include major enhancements and extensions to various green energy tax credits, and show that the administration is aligned with Congress in supporting renewable development, even if they differ on details, say attorneys at Eversheds Sutherland.

  • What Tax Court's Mylan Legal Fee Ruling Means For IP Suits

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    The U.S. Tax Court's recent ruling that Mylan Inc. could deduct as regular business expenses the legal fees it incurred defending itself against patent infringement suits from brand-name drug manufacturers has the potential to increase patent litigation and may make settlement less appealing, say attorneys at Snell & Wilmer.

  • Biden's Clean Energy Goals Require Big Hydrogen Push

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    To realize its ambitious renewable energy goals, the Biden administration, along with Congress, must promote the growth of the hydrogen industry using every available tool, including regulations, grants, tax incentives and direct purchases, say Abdon Rangel at Andersen Tax and John Taylor at King & Spalding.

  • IRS Summons Ruling Isn't A Total Loss For Investors

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    A California federal court’s recent order allowing an IRS information summons on cryptocurrency exchange Kraken paradoxically provides hope for investors concerned about their privacy by limiting the scope of the agency’s inquiry, says Joshua Smeltzer at Gray Reed.

  • Justices' Nod To Preemptive Tax Challenges May Caution IRS

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    The U.S. Supreme Court's recent decision in CIC Services v. Internal Revenue Service, allowing pre-enforcement challenges of tax reporting rules despite the Anti-Injunction Act, is likely to make the U.S. Department of the Treasury more careful about its own compliance obligations under the Administrative Procedure Act, says Robert Carney at Caplin & Drysdale.

  • Let's End The Offshoring Of US Patents

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    Congress should work toward removing the loophole that allows companies to avoid U.S. taxes by moving their patents offshore, and ensure profits are taxed where the sales take place, says Sen. Patrick Leahy, D-Vt.

  • How Biden's First 100 Days Will Affect Gov't Contractors

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    Joseph Berger and Thomas Mason at Thompson Hine examine the significant opportunities for government contractors arising from actions during the first 100 days of the Biden administration, which set the stage for unprecedented investment in national infrastructure, domestic manufacturing, research and development, clean energy, pandemic response and economic recovery.

  • Addressing New COBRA Duties Under Virus Relief Law

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    Following the issuance of fully subsidized COBRA premiums for certain workers under the recently passed American Rescue Plan Act, employers should take steps to determine who is eligible, ensure additional notice requirements are satisfied, and train human resources on communicating with qualified individuals, say Randi May and Dustin Grant at Hoguet Newman.

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