Federal
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February 27, 2023
10th Circ. Urged To Revisit Reviving Convict's Tax Penalty Bill
The full Tenth Circuit should revisit a panel decision finding that the U.S. Tax Court wrongly nixed $43,000 in penalties owed by a man serving time in prison for tax evasion, he told the appeals court.
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February 27, 2023
Tax Court Grants Grocery Biz Over $1.7M In Costs Of Goods
A California couple running a grocery business can subtract $1.7 million in costs of goods sold from their receipts for 2016 and a comparable share of their receipts in 2014 and 2015, the U.S. Tax Court said.
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February 27, 2023
Calif. Couple Owe IRS $1M For Co. Transfers, Tax Court Says
A California couple owe the IRS more than $1 million after the U.S. Tax Court concluded Monday that transfers from a Cambodian construction company to the couple count as income and not loans for tax purposes.
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February 27, 2023
Global Min. Tax Treatment Of US Energy Credits Unclear
Investors seeking to use new options for monetizing U.S. green energy tax credits don't yet know how those mechanisms will be treated by countries enacting the 15% global minimum corporate tax, tax professionals said.
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February 27, 2023
US Wants Man's Settlement Rewards To Pay $1.1M Tax Penalty
The federal government is entitled to a former corporate officer's settlement rewards he received in litigation over the administration of his trusts in order to pay off his outstanding $1.1 million in employment tax penalties, the U.S. told a Florida federal court.
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February 27, 2023
ArentFox Schiff Adds Ex-Sen. Richard Burr Staffer In DC
ArentFox Schiff LLP has added to its government relations team a former Capitol Hill legislative assistant who most recently worked with former Republican Sen. Richard Burr of North Carolina, the firm said.
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February 24, 2023
Global Tax Plan May Not Spell The End Of Digital Measures
The core of an international tax pact centers around an agreement for countries to eliminate digital measures in exchange for new corporate taxing rights, but the proposed implementation plan has raised questions about whether this trade-off will occur in practice.
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February 24, 2023
Nev. Retiree Owes $1.1M In Foreign Bank Penalties, US Says
A retired shipping industry professional owes approximately $1.1 million in penalties for willfully failing to file reports of his foreign financial accounts, the U.S. said in Nevada federal court.
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February 24, 2023
FBAR Violations Not Willfull In $4.3M Case, Calif. Woman Says
An engineer and business owner didn't recklessly underreport her foreign holdings, she told a California federal court in a filing that opposed the government's $4.3 million tax case against her.
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February 24, 2023
Fla. Couple Skip Trial In Tax Court, Lose Case
A Florida couple who claimed they shouldn't have to pay their $15,000 tax bill because they were cheated by a contractor failed to properly prosecute their case in the U.S. Tax Court by not showing up for trial, the court said Friday in tossing the case.
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February 24, 2023
OMB Done Reviewing Virtual Currency Broker Reporting Rules
A division of the Office of Management and Budget completed its review of proposed rules for virtual currency sales brokers' information reporting, the agency said on its website.
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February 24, 2023
Mass. Money Manager Gets 9 Years For Gambling Client Funds
A Boston-area investment adviser who admitted to stealing millions of dollars from clients to support a ruinous gambling habit has been sentenced to more than nine years in prison, according to the U.S. Attorney's Office for the District of Massachusetts.
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February 24, 2023
IRS Extends Deadlines For Disaster Victims In Calif., Ga., Ala.
The Internal Revenue Service said Friday that it would push certain tax deadlines back to Oct. 16, from the previous extended deadline of May 15, for taxpayers affected by disasters in some parts of California, Georgia and Alabama.
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February 24, 2023
Manafort Agrees To Pay $3.2M In FBAR Penalties
Former Trump campaign manager Paul Manafort agreed to pay the federal government nearly $3.2 million for his failure to timely disclose his overseas bank accounts to the Internal Revenue Service, according to filings in a Florida federal court.
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February 24, 2023
IRS Seeks Comments On General Biz Credit Form
The Internal Revenue Service asked for comments Friday on the form used to calculate the general business credit.
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February 24, 2023
Weekly Internal Revenue Bulletin
The Internal Revenue Service released its weekly bulletin, which included an announcement of disciplinary sanctions.
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February 24, 2023
Treasury Floats Changes In Retirement Plan Forfeiture Regs
The U.S. Treasury Department issued proposed regulations Friday on the use of forfeitures in qualified retirement plans, saying the agency wants to simplify the rules by establishing a single date by which plan administrators must use such forfeitures.
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February 24, 2023
Pillar 1 Talks At Critical Point, OECD Head Says
International talks to conclude an agreement on the redistribution of taxing rights known as Pillar One are at a critical juncture, the head of the Organization for Economic Cooperation and Development said Friday.
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February 23, 2023
Calif. Man's Income Includes Disability, Tax Court Says
A California man's gross income for 2015 includes more than $26,000 in disability benefits paid out on behalf of Los Angeles County, the U.S. Tax Court said Thursday.
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February 23, 2023
IRS Issued Deficiency Notice On Time, Tax Court Says
The Internal Revenue Service sent a notice laying out tax deficiencies owed by a now-divorced couple on time, the U.S. Tax Court said Thursday, finding the deadline for issuing such a notice was extended due to their failure to disclose foreign transactions.
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February 23, 2023
Tax Court Upholds Limit To Scoreboard Co.'s Research Credit
A scoreboard manufacturer cannot include the money it paid its president in calculations of its research tax credit, partly because it didn't track the hours the president spent working on qualifying projects, the U.S. Tax Court said Thursday.
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February 23, 2023
Locke Lord Adds Tax Controversy Partner From Gray Reed
Locke Lord LLP's Dallas office gained a former Gray Reed & McGraw LLP partner to chair its tax controversy practice group, the firm announced.
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February 23, 2023
ABA Urges Clarification Of Tax Credit Election Rules
The U.S. Treasury Department should clarify that agencies of state and local governments can elect to treat some tax credit sums as direct tax payments, the American Bar Association's Tax Section recommended.
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February 23, 2023
Gov't Finalizes Reporting Changes For Benefit Plans
The U.S. government unveiled Thursday the final set of revisions to forms for reporting employee benefit plans that were authorized under a 2019 law that expanded workers' retirement savings.
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February 23, 2023
Justices Urged To Affirm 6th Circ. OK Of IRS Firm Summonses
The U.S. Supreme Court should affirm a Sixth Circuit decision finding the IRS could proceed with summonses seeking the banking records of two law firms and the spouse of a man owing $2 million in taxes without notifying them of the requests, the U.S. government argued.
Expert Analysis
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Navigating CARES Act Social Security Tax Deferral Payments
Attorneys at Morgan Lewis examine Internal Revenue Service guidance on payment of employer-share social security tax deferrals due Jan. 3 under the Coronavirus Aid Relief and Economic Security Act, and offer tips for avoiding costly underpayment and late deposit penalties.
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Tech Improvements That Can Help Gov't Tackle FOIA Backlog
Government agencies can implement effective technological solutions that will help them address the growing backlog of Freedom of Information Act requests, and avoid costly noncompliance litigation, by taking steps to identify agency-specific needs, develop cohesive strategies and obtain leadership buy-in, say Ken Koch and Erica Spector at KPMG.
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IRS Memo Helps Clarify Research Credit Filing Requirements
A recently published Internal Revenue Service chief counsel memorandum offers long-awaited guidance about information requirements for taxpayers seeking research credit refunds and provides helpful notice of the agency’s litigating position where credits are denied, say Deborah Roth and Brian Coddington at Source Advisors.
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Questions To Ask If Doing Business In A Corruption Hot Spot
Businesses facing new scrutiny after the U.S. Department of Justice's recently announced task force for combating human trafficking in Central America, the release of the Pandora Papers and continuing fallout from 2019's Panama Papers, should address compliance risks by having employees ask three questions about every transaction, say attorneys at White & Case.
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New DOJ Corporate Crime Approach May Deter Self-Reporting
Deputy U.S. Attorney General Lisa Monaco's recent unveiling of a tougher white collar enforcement approach at the U.S. Department of Justice — focusing on corporate recidivism and compliance monitors — could result in companies being less willing to self-report wrongdoing or enter into resolutions with the government, say attorneys at Morgan Lewis.
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Infrastructure Bill May Limit Cryptocurrency Loss Deductions
If enacted, provisions in President Joe Biden's infrastructure bill would broaden a rule meant to prevent the harvesting of tax losses, causing every cryptocurrency investor who wants to deduct a loss to consider whether it is worth cashing out to fiat currency and waiting 30 days before reinvesting to take a loss deduction, says Andrew Leahey at Hunter Creek Consulting.
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The Infrastructure Bill Should Not Target Cryptocurrency
Congress should excise a provision in the pending infrastructure bill that would require anyone who accepts $10,000 in cryptocurrency for goods or services to report the transferring party's personal information to the Internal Revenue Service — this would be unnecessary, ill-advised and possibly unconstitutional, says James Burnham at Jones Day.
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Opportunity Zone Regulations Require More Fine Tuning
Problems with the latest revisions to the qualified opportunity zone investment rules reinforce a recurring theme of regulatory hiccups that may prevent investors and communities from actualizing the program's potential benefits, unless we have more guidance, says Mitchell Goldberg at Berger Singerman.
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Preserving Disgorgement Tax Deductibility In SEC Settlements
The U.S. Securities and Exchange Commission recently added language to its enforcement orders that could affect a settling party's ability to deduct certain disgorgement payments, but proper planning can help them satisfy Internal Revenue Service prerequisites, say attorneys at Sidley.
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How The Global Tax Agreement Could Backfire For Biden
If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.
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Tax-Exempt Orgs, Beware This 403(b) Plan Compliance Pitfall
A recent Internal Revenue Service publication puts 403(b) retirement plan sponsors on notice about a contribution aggregation compliance failure often identified in audits of government and tax-exempt entities, but risk can be minimized by ensuring plan documents and communications address the issue directly, say Greg Needles and Michael Gorman at Morgan Lewis.
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Pandora Papers Reveal Need For Greater Tax Enforcement
The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.
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Telehealth Providers Must Beware Of Fraud As Industry Grows
A recent fraud charge against a telehealth executive highlights the rise we're seeing in telefraud scams during the industry's pandemic growth, and there are some steps that all health providers should take to stay clear of potentially illegal arrangements, says LaTawnda Moore at Dinsmore.