Federal

  • October 31, 2022

    1st Circ. Urged Not To Allow US New Arguments In Crypto Suit

    The First Circuit should reject a request from the federal government to permit additional jurisdictional challenges to a New Hampshire man's suit contesting the IRS' procurement of his cryptocurrency records, he told the appeals court.

  • October 31, 2022

    Trump Org's Fraud Defense Opens With Flurry Of Objections

    Trump Organization attorneys had a bumpy start in the Manhattan district attorney's criminal tax fraud trial Monday as the judge repeatedly warned the former president's companies not to interpret the law for jurors.

  • October 31, 2022

    No Renewal Required For Some Withholding Entities, IRS Says

    The Internal Revenue Service said some entities acting as withholding agents on behalf of foreign taxpayers won't have to renew their agreements with the agency in 2023.

  • October 28, 2022

    'Chrisley Knows Best' Stars Won't Get New Trial In Fraud Case

    A Georgia federal judge on Friday refused to acquit or grant a new trial for stars of the reality television show "Chrisley Knows Best" who have been convicted of bank fraud and tax evasion, sticking with plans for a November sentencing.

  • October 28, 2022

    Reluctant Trump Witnesses Flagged To Jury Before Openings

    New York state prosecutors told jurors Friday that some witnesses testifying at the tax fraud trial of the Trump Organization were still being paid by the company and may be reluctant to tell the truth, and that some "won't even talk to us."

  • October 28, 2022

    Fla. Judge OKs $18M In FBAR Penalties Recalculated By IRS

    A Florida man owes $18 million in penalties for willfully failing to report his foreign bank accounts after a Florida federal court found that the Eleventh Circuit, which had faulted the IRS' penalty calculation, didn't vacate the court's determination of his culpability.

  • October 28, 2022

    Annual Tax Gap Hit Nearly $500 Billion, IRS Projects

    The IRS projected Friday that the annual gap between taxes owed and taxes actually paid widened to $496 billion between 2014 and 2016, or less than half of the $1 trillion estimate that IRS Commissioner Chuck Rettig has claimed.

  • October 28, 2022

    IRS Says Self-Dealing Calculation Must Include Interest

    For purposes of calculating the excise tax on self-dealing, the balance of a foundation's self-dealing loan includes interest from years for which the limitations period has closed, the Internal Revenue Service said in a memorandum released Friday

  • October 28, 2022

    DOJ Won't Appeal 5th Circ.'s Nix Of Fee On Crude Exports

    The U.S. Department of Justice will not pursue an appeal of a Fifth Circuit decision that a charge on crude oil exports is an unconstitutional tax, according to Solicitor General Elizabeth Prelogar.

  • October 28, 2022

    The Cannabis Attorneys Who Take The DEA To Court

    Two attorneys talk to Law360 about the role that impact litigation plays in drug policy reform, what they expect to see from the president's order reviewing marijuana's Schedule I status, and what they really think of the Drug Enforcement Administration lawyers who work across from them.

  • October 28, 2022

    US Urges Justices To Skip Dispute Over IRS Firm Summonses

    The Sixth Circuit correctly determined that the IRS wasn't obligated to notify two law firms and the spouse of a man owing $2 million in taxes of agency summonses seeking their bank records, the government told the U.S. Supreme Court.

  • October 28, 2022

    Yellen Names Acting IRS Commissioner Ahead Of Rettig's Exit

    The Internal Revenue Service's deputy commissioner will head the agency temporarily after Commissioner Chuck Rettig's term ends next month, Treasury Secretary Janet Yellen announced Friday.

  • October 28, 2022

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin, which included final rules that will increase the fee required to become an enrolled agent or renew that status to $140 from $67.

  • October 28, 2022

    Calif. Rebuffs Tribes' Bid For $1.1M Atty Fee In Gaming Appeal

    California and its governor, Gavin Newsom, say five Native American tribes that earlier this year won a Ninth Circuit decision over their gaming negotiations with the state are not entitled to more than $1.1 million in attorney fees, since federal Indian law offers no such relief.

  • October 28, 2022

    Ascension Employee Benefits Atty Joins Crowell & Moring

    A senior attorney at Ascension Health Alliance, one of the largest private health care systems in the U.S., has joined Crowell & Moring LLP's team in Washington, D.C.

  • October 28, 2022

    Taxation With Representation: Sullivan, Latham, Fenwick

    In this week's Taxation With Representation, Myovant Sciences' stock rose after it accepted a deal, JKN Global Media Public Co. Ltd. is purchasing the Miss Universe Organization, Regal Rexnord Corp. will acquire Altra Industrial Motion Corp., and two private equity firms acquired UserTesting.

  • October 28, 2022

    Feds Charge Dallas Lawyer In $1B Tax Shelter Scheme

    A Dallas lawyer helped his clients hide $1 billion in business income from the Internal Revenue Service, creating shell companies to make their deductions and tax exemptions appear legitimate and helping them file false returns, federal prosecutors said.

  • October 28, 2022

    IRS Seeks Input On Dividend Reporting Form

    The Internal Revenue Service asked for feedback Friday on a form used to report dividends.

  • October 27, 2022

    Trump Org Meets Jury In Fraud Trial, Trump Skeptics Included

    Trump Organization attorneys and New York prosecutors have selected a jury in the criminal tax fraud case against two Trump companies, cobbling together a cross-section of the city including several who voiced negative opinions about the former president.

  • October 27, 2022

    Trump Org. Slams NY AG In Response To $250M Fraud Case

    The New York attorney general's lawsuit accusing former President Donald Trump of a $250 million scheme to defraud banks using misleading financial statements is "politically motivated" and "rides to the rescue" of corporate titans, a slew of Trump entities said in a filing.

  • October 27, 2022

    Centrist Dems Push Pelosi For R&D, Child Credit Extensions

    Congress needs to renew expired tax breaks for research costs and extend the enhanced child tax credit under any year-end legislative package, members of a centrist House Democratic coalition said in a letter to their party's leaders in the chamber Thursday.

  • October 27, 2022

    DC Circ. Won't Delay Release Of Trump Tax Returns To House

    The D.C. Circuit won't delay the release of former President Donald Trump's tax returns to a House committee but it won't hasten their release either, the appeals court said Thursday.

  • October 27, 2022

    IRS Hires 4,000 Customer Service Reps Ahead Of Tax Season

    The Internal Revenue Service has hired 4,000 customer service representatives over the last several months, the agency announced Thursday.

  • October 27, 2022

    Special Master In MoneyGram Case Partially Reverses Opinion

    A special master advising the U.S. Supreme Court on an interstate battle over claim to abandoned MoneyGram checks has partially reversed his earlier opinion on whether federal unclaimed property law governs all the checks, according to an order Law360 obtained Thursday.

  • October 27, 2022

    Treasury Opens Foreign Alcohol Producer Registering System

    The U.S. Department of the Treasury launched an online registration system for foreign producers of alcohol hoping to take advantage of tax cuts for U.S. importers, part of an overhaul of alcohol-related tax breaks signed into law in 2020.

Expert Analysis

  • 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.

  • 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.

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