Federal

  • October 27, 2022

    High Court Privilege Case Could Hinder In-House Counsel

    The U.S. Supreme Court has agreed to review a tax-related case concerning the scope of attorney-client privilege for multipurpose communications, and the outcome could potentially interfere with the work of in-house counsel, whose communications within a company often involve nonlegal business matters.

  • October 27, 2022

    Tax Court Denies $1.5M Refund To Calif. Trust

    A California trust can't receive a $1.5 million refund based on capital gain and interest income it received through a partnership because the tax treatment of that income should have been determined at the pass-through level, the U.S. Tax Court said Thursday.

  • October 27, 2022

    Caterpillar To Pay $740M To Settle $2.3B Tax Bill

    Construction equipment maker Caterpillar said Thursday that it will pay $740 million in taxes and interest to end its dispute with the Internal Revenue Service, a figure about $1.56 billion below the approximately $2.3 billion in taxes and penalties the agency had proposed.

  • October 27, 2022

    Tax Court Grants Woman Spousal Relief On $300K Bill

    A woman can get relief from $300,000 in joint tax debt with her ex-husband for 2007 through 2013 and 2017, the U.S. Tax Court said Thursday.

  • October 27, 2022

    House Bill Would Extend Full Biz Meal Deduction

    A bill introduced in the U.S. House of Representatives would temporarily extend the full deduction for business meal expenses.

  • October 27, 2022

    Hospice Services Provider Seeks $360K Payroll Tax Refund

    A hospice services provider is owed a refund of nearly $360,000 in payroll taxes after the IRS wrongly concluded that the business failed to file tax returns and incorrectly filed forms on its behalf, the company told an Alabama federal court.

  • October 27, 2022

    IRS Tells Tax Pros To Renew Tax Preparer ID Numbers

    The Internal Revenue Service said Thursday that those who are paid to participate in preparing tax returns should renew their preparer tax identification numbers in light of upcoming PTIN expirations.

  • October 27, 2022

    Former Faegre Drinker Tax Duo Moves To Flaster Greenberg

    A pair of attorneys specializing in like-kind real estate investment transactions has moved their practice from Faegre Drinker Biddle & Reath LLP to Flaster Greenberg PC's office in the Philadelphia suburbs.

  • October 27, 2022

    IRS Seeks Input On Rules For Space Income

    The Internal Revenue Service on Thursday requested comments on regulations concerning income sources for activities in space.

  • October 27, 2022

    IRS Advisory Council To Meet In November

    The Internal Revenue Service Advisory Council, which advises the IRS commissioner and suggests improvements to operations and taxpayer service, will meet in November, the agency said Thursday.

  • October 27, 2022

    5th Circ. Won't Rethink Denial Of Farm Investors' Tax Refund

    The Fifth Circuit denied a rehearing request by Texas investors in farmland partnerships seeking a $305,000 tax refund, upholding its decision to reject the refund on the grounds that district courts lack authority over partnership agreements with the IRS.

  • October 26, 2022

    Feds Reportedly Investigating Sen. Bob Menendez Again

    Five years after beating the government's corruption case, U.S. Sen. Bob Menendez is facing a new federal investigation, an adviser to the senator confirmed to Law360 on Wednesday.

  • October 26, 2022

    House GOP Pushes TCJA Permanency Ahead Of Midterms

    Republicans in the House Ways and Means Committee want to make several of the 2017 tax overhaul's provisions permanent before they expire in 2025 to combat increasing economic uncertainty, they said during a roundtable discussion Wednesday.

  • October 26, 2022

    Prosecuted NC Biz Exec Owes FBAR Penalties, US Says

    A North Carolina business executive facing federal bribery charges failed to tell the Internal Revenue Service he had signing authority over foreign bank accounts, according to a complaint filed in federal court.

  • October 26, 2022

    Draft Partnership Instructions Allow Filing Exception

    Domestic partnerships that meet four specific criteria for the 2022 tax year don't have to file two schedules on their partnership income returns with the Internal Revenue Service, according to draft instructions released by the agency.

  • October 26, 2022

    Bank Rebuffs Fixed Records Claims From Cannabis Co.

    Cann Distributors and the cannabis industry banking firm it has accused of withholding its money continue to spar over discovery after their last conflict frustrated the judge overseeing their case, prompting him to warn that "sanctions are going to fly."

  • October 26, 2022

    DC Circ. Judges Skeptical Of Israeli Atty's Transition Tax Suit

    D.C. Circuit judges doubted during oral arguments Wednesday whether an Israeli lawyer and his firm had standing to sue the Internal Revenue Service over regulations governing the 2017 tax law's transition tax on foreign earnings.

  • October 26, 2022

    Woman Accepts Liability For Husband's $755K FBAR Fine

    A woman is liable for a nearly $755,000 penalty assessed against her husband's estate for wilfully failing to report 12 bank accounts in Switzerland and Israel, according to a judgment agreed upon by her and the government in Texas federal court.

  • October 26, 2022

    IRS Aiming To Clear Up Partnership Terminations, Official Says

    The Internal Revenue Service could be close to issuing guidance on the 2017 federal tax overhaul's elimination of technical partnership terminations, according to an agency official who said Wednesday that there is uncertainty over when a partnership is now deemed terminated.

  • October 26, 2022

    Fla. Adviser Gets 23 Years For $80M Trading Scam

    A Sarasota, Florida, investment adviser who had been banned from making foreign trades was sentenced to 23 years in prison for bilking more than $80 million from hundreds of people he persuaded to invest in a fraudulent company, according to the government.

  • October 25, 2022

    'Hate' For Trump Weeded Out As Jurors Picked For Fraud Trial

    A Manhattan judge presiding over the criminal fraud trial against the Trump Organization cut potential jurors Tuesday who claimed they could be impartial despite admitting strong negative views of Donald Trump.

  • October 25, 2022

    'Branded As Spies,' Chinese Academics Vindicated In Court

    Even after the Justice Department announced a shift away from the troubled China Initiative, it has aggressively sought convictions and tough sentences in pending cases — only to encounter the same legal issues that marred the Trump-era program from the beginning.

  • October 25, 2022

    Chile Tax Treaty Changes Cover TCJA, Treasury Official Says

    A U.S. Senate committee's changes to the pending Chile tax treaty represent the entirety of the rules that are needed to align this agreement and future ones with the 2017 federal tax overhaul, a U.S. Treasury Department official said Tuesday.

  • October 25, 2022

    Light Sentence Appropriate In False Tax Return Case, Feds Say

    A light sentence is appropriate for a woman who pled guilty to aiding in the filing of false tax returns, federal prosecutors told a Nevada federal judge.

  • October 25, 2022

    Ex-Uber Exec Asks Court To Uphold His Tax-Free Settlement

    An ex-Uber Technologies executive who declared bankruptcy after admitting to stealing trade secrets from Google asked a California federal court to uphold a decision freeing his settlement with the companies from income taxes, saying the bankruptcy court had authority to determine his bottom-line liability.

Expert Analysis

  • 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.

  • Why S Corporation Payments Are Almost Always Wages

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    The recent U.S. Tax Court ruling in Lateesa Ward v. Commissioner has employment and income tax lessons about why payments from an S corporation to its sole shareholder are wages and not distributions of profit in most cases, says Bryan Camp at Texas Tech University School of Law.

  • 3 Arthrex-Adjacent High Court Cases Could Affect PTAB's Fate

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    As patent practitioners await a decision on the constitutionality of Patent Trial and Appeal Board judges in U.S. v. Arthrex, they should keep their eyes on three other pending U.S. Supreme Court cases that, while not IP-related, involve overlapping legal issues, including the severability doctrine, says William Milliken at Sterne Kessler.

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