Federal

  • September 14, 2022

    11th Circ. Sends IRS' $4.6M Easement Win Back To Tax Court

    The Eleventh Circuit sent a $4.6 million conservation easement fight back to the U.S. Tax Court on Wednesday to determine if the easement was protected in perpetuity as required, saying the original reason disputed deductions were invalidated no longer stands.

  • September 14, 2022

    IRS Mostly Followed 'Tax Protester' Phrase Ban, TIGTA Says

    Internal Revenue Service employees largely abstained from using prohibited phrases such as "illegal tax protestor" in agency records from October 2020 through September 2021, the Treasury Inspector General for Tax Administration said in a report released Wednesday.

  • September 14, 2022

    GOP Bill Would Tie IRS Enforcement Hires To Customer Service

    The Internal Revenue Service would be barred from hiring new enforcement agents until it improves customer service, including answering phone calls in five minutes or less, under a law proposed by two Senate Republicans.

  • September 14, 2022

    Miller & Chevalier Gains Former Lockheed Int'l Tax Counsel

    A familiar face is back at Miller & Chevalier Chartered as a member in the firm's international tax practice following a stint in-house in the aerospace and defense industry.

  • September 13, 2022

    11th Circ. Reverses IRS Loss On Penalties On $25M Transfers

    The Eleventh Circuit reversed a U.S. Tax Court decision determining the Internal Revenue Service couldn't impose penalties on a man's $25 million in transfers, saying Tuesday that a supervisor wasn't required to approve the penalties until they were assessed.

  • September 13, 2022

    11th Circ. Suggests ARPA Tax Provision Could Be Too Vague

    Eleventh Circuit judges appeared reluctant Tuesday to overturn an Alabama district court's ruling that bars the federal government from enforcing in 13 states a tax provision of the American Rescue Plan Act because it is ambiguous.

  • September 13, 2022

    Feds Seek 1 Year For Math Prof. Hiding Chinese Bank Account

    Federal prosecutors are seeking a one-year prison sentence for an Illinois math professor who was convicted of concealing a Chinese bank account from the Internal Revenue Service, arguing Tuesday that such a sentence is supported by his "repeated, deceptive conduct."

  • September 13, 2022

    IRS Budgets May Decline After Funding Boost, Panelist Says

    The Inflation Reduction Act's increased funding for the Internal Revenue Service could lead to smaller congressionally passed annual budgets over the next decade, a former IRS chief counsel said Tuesday during a webinar.

  • September 13, 2022

    Dems Point To Poverty Data In Push To Renew Child Tax Credit

    U.S. Census Bureau data showing a record low in child poverty levels underscores the need for lawmakers to renew the expanded child tax credit that expired in December, congressional Democrats said Tuesday.

  • September 13, 2022

    Md. Accountant Must Pay $5.5M For Scheme, Tax Court Says

    A Maryland accountant must pay $5.5 million in federal income tax liabilities, including $2.3 million in fraud penalties, for underreporting income from companies he controlled that made payments for his benefit, the U.S. Tax Court said Tuesday.

  • September 13, 2022

    IRS Issues Rules For Making One-Time Alternative Fuel Claim

    The Internal Revenue Service released guidance Tuesday for seeking a one-time alternative fuel claim for the first three quarters of 2022.

  • September 13, 2022

    IRS Urged To Clarify Tax Rules For Geothermal Heat Pumps

    The Internal Revenue Service should clarify that a certain kind of infrastructure for geothermal heat pump systems isn't "limited-use property" for tax purposes, a coalition of environmental organizations said in a letter released Tuesday.

  • September 13, 2022

    Horse Breeders Entitled To Pass-Through Losses, 3rd Circ. Told

    The Third Circuit should undo a U.S. Tax Court opinion determining that two New Jersey men couldn't claim pass-through losses for their horse breeding business, the men argued, disputing findings that they didn't operate the business intending to profit.

  • September 13, 2022

    CBD Co. Can't Slip Co-Founder's Suit Over $5M Tax Bill

    A Nevada federal judge denied a CBD company's bid to dismiss a suit by its co-founder, saying his argument that the company should pay his $5 million tax bill for company stock has legs.

  • September 13, 2022

    Housing Credit Income Test Rules Pending Review, OMB Says

    Final rules for average income tests for federal low-income housing are pending review before a division of the Office of Management and Budget, the office said.

  • September 12, 2022

    VMware Inks $8M Deal To End SEC Claim It Misled Investors

    Cloud computing firm VMware Inc. agreed to pay the U.S. Securities and Exchange Commission $8 million Monday to end the agency's allegations that the company misled investors by concealing its slowing sales performance in regulatory filings and earnings calls.

  • September 12, 2022

    NJ Judge OKs Textile Business Owner's FBAR Settlement

    A New Jersey federal court on Friday approved a nearly $318,000 settlement between the U.S. and a textile business owner over allegations he willfully failed to report his interest in five overseas bank accounts.

  • September 12, 2022

    FedEx's Tax Credits Not Allowed Under TCJA, US Says

    FedEx cannot take tax credits for offshore income that already offsets its tax liability because the 2017 federal overhaul's transition tax doesn't allow it, the U.S. told a Tennessee federal court hearing the company's $89.15 million dispute against the IRS.

  • September 12, 2022

    Senate Finance GOP Bill Seeks To Restrict IRS Audits

    Senate Finance Committee Republicans are seeking to block the Internal Revenue Service from using the funding boost the agency received under the Inflation Reduction Act to audit low- and middle-income taxpayers under a bill introduced Monday.

  • September 12, 2022

    Medical Co. Fights To Deduct $5M FCA Settlement From Taxes

    The IRS wrongly denied a medical equipment company a $5 million deduction for a settlement payment to resolve a False Claims Act suit challenging its billing practices, the company told the U.S. Court of Federal Claims.

  • September 12, 2022

    SEC Says Adviser's Clients Paid Founder's $50M Tax Bill

    The U.S. Securities and Exchange Commission announced Monday that two investment advisers have agreed to pay $11.2 million in civil penalties for allegedly charging private equity clients over $50 million to cover income tax liability that should have been paid by the billionaire founder of one of the firms. 

  • September 12, 2022

    NY, Native American Cigarette Cos. Settle Tax Fight For $50M

    Two Native American-owned companies will pay New York $50 million to settle allegations that they illegally distributed and sold untaxed and unstamped cigarettes inside the state, the New York attorney general announced Monday.

  • September 12, 2022

    Ga. Tax Preparer Must Pay $100K For Fraud, Tax Court Says

    The owner of a Georgia tax preparation business must pay a $100,000 fraud penalty for underreporting her income, the U.S. Tax Court ruled Monday, saying she was too knowledgeable about taxes to have made a simple mistake.

  • September 12, 2022

    Chamber Says US-Chile Tax Treaty's Delay Poses Energy Issues

    The U.S. Chamber of Commerce is calling on the Senate to immediately ratify a long-stalled tax treaty with Chile, saying the lack of a formal agreement between the two countries threatens to slow the transition away from fossil fuels.

  • September 12, 2022

    IRS' Overdue Quick-Refund Forms Spiked In 2021, TIGTA Says

    The number of quick-refund forms that were considered processed late by the Internal Revenue Service jumped almost 750% in 2021 from the previous year, the Treasury Inspector General for Tax Administration said in a report released Monday.

Expert Analysis

  • Long Road Ahead For Biden's Individual Tax Hike Proposal

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    Dustin Stamper at Grant Thornton provides insight into President Joe Biden's recently proposed individual tax increases to pay for his American Families Plan, and explains how competing interests among congressional Democrats and Republicans may shape the final provisions and prolong their implementation.

  • What Value-Added Tax Might Look Like In The US

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    Christiaan Van Der Valk and Charles Maniace at Sovos consider the value-added tax, a primary source of revenue for many countries, and what it might mean for the U.S. were it implemented to raise funds for large-scale federal initiatives such as President Joe Biden's infrastructure plan.

  • New Markets Credit Will Aid Recovery In Low-Income Areas

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    The recently extended New Markets Tax Credit is a critical tool for economic development in low-income communities, which have been hit especially hard by the pandemic, so public finance attorneys should consider its benefits when advising clients on projects, says Julia Fendler at Butler Snow.

  • The International Outlook For US Border Carbon Adjustments

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    The Biden administration may see enacting a border carbon adjustment system as a good way to advance climate goals and protect domestic industries and jobs, but any such plan must take into account the need to respect existing international trade agreements, say attorneys at Akin Gump.

  • The Domestic Landscape For US Border Carbon Adjustments

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    With the Biden administration possibly eyeing border carbon adjustments on imported goods as a means to mitigate climate change, attorneys at Akin Gump discuss such policies' potential benefits to domestic businesses, and the political and technical challenges to their enactment in the U.S.

  • Prepare For Global Collaboration In Crypto Tax Enforcement

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    Recent Internal Revenue Service victories involving John Doe summonses served on cryptocurrency exchanges — and statements by the Joint Chiefs of Global Tax Enforcement about global collaboration in cryptocurrency-related tax investigations — should prompt assessment of prior virtual currency transactions and remediation before an enforcement agency shows up at the door, say attorneys at McDermott.

  • 10 Things to Know About US Competent Authority Assistance

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    Taxpayers should consider seeking U.S. competent authority assistance to help eliminate double taxation from a transfer pricing adjustment, especially now that the competent authorities are resolving cases virtually and more quickly, say attorneys at Thompson & Knight.

  • Lessons From Tax Court's Nixing Of Investor's Energy Credits

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    The U.S. Tax Court's recent ruling in Olsen v. Commissioner, the first of 200 cases involving individual taxpayers who invested in a tax shelter involving solar equipment, is a case study in how not to structure an energy tax credit investment, says David Burton at Norton Rose.

  • Partial Repeal Could Resolve Biden's SALT Cap Dilemma

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    Lawmakers' calls to repeal the cap on federal deductions for state and local taxes are controversial because doing so could cost over $600 billion, but a partial repeal could be accomplished on a revenue-neutral basis, providing relief to some, if not most, affected taxpayers, says Joseph Mandarino at Smith Gambrell.

  • Alcohol Taxation Provides Good Model For Cannabis Taxes

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    Although the alcohol taxation system isn't perfect, it could serve as a useful template for cannabis taxation with a three-tier licensing scheme and tax rates based on potency, says Louis Terminello at Greenspoon Marder.

  • US Advance Pricing Agreements, Amid COVID And Before

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    Steptoe & Johnson's Matthew Frank, former director of the U.S. Advance Pricing Agreement Program, shares insights from an Internal Revenue Service report revealing an uptick in APA completions amid the pandemic, discusses trends over the program's 30-year history, and suggests ways taxpayers and the IRS could bolster program participation.

  • High Court Hotels.com Case Could Alter Appellate Strategy

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    If the U.S. Supreme Court upholds the Fifth Circuit in the upcoming San Antonio v. Hotels.com case, ruling that district courts may not amend taxable appellate costs, it could reprioritize the incentive structure and decision-making calculus of appeals, says Patrick Hammon at McManis Faulkner.

  • Choosing A Branch Or Subsidiary For Overseas Expansion

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    Samuel Pollack and Naoko Watanabe at Baker McKenzie examine the corporate and U.S. tax law considerations involved in deciding whether a branch or subsidiary is the most efficient way to expand operations overseas, now that recent Treasury regulations clarified the complicated international tax regime created by the Tax Cuts and Jobs Act.

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