Federal

  • October 31, 2022

    Tax Court Disbars 1 Practitioner, Suspends 2

    U.S. Tax Court disciplined three tax practitioners, disbarring one and suspending the other two from practice before the court.

  • 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.

Expert Analysis

  • 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.

  • Surveying Global Tax Updates For Sovereign Wealth Investors

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    As the market transitions to a post-pandemic phase, sovereign wealth fund and other foreign institutional investors must evaluate how recent U.S., EU and U.K. tax changes may affect their private fund investments, say attorneys at Morgan Lewis.

  • Offshore Wind Push Is Good News For NYC Building Owners

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    With a surge of federal and state support for offshore wind power in New York state, the projects now in development should greatly benefit New York City building owners seeking to comply with the city's Climate Mobilization Act, says Raymond Pomeroy at Stroock.

  • Coke, 3M Tax Cases May Not Settle Blocked Income Debate

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    Even if the challenged U.S. Department of the Treasury regulation on blocked income is struck down by the U.S. Tax Court in the pending Coca-Cola and 3M cases, the obligations of a taxpayer that had, but failed to avail itself of, alternative means to secure payment will remain an open question, say Matthew Frank and Amanda Varma at Steptoe & Johnson.

  • OCC Rule Misaligned With Some Tax Equity Safe Harbors

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    The Office of the Comptroller of the Currency's recently finalized rule on national banks' participation in tax equity financings aligns with safe harbor guidance for renewable energy investments, but not with safe harbor structures for historic preservation and carbon capture tax credits, say attorneys at Nixon Peabody.

  • IRS Should Level The Field For R&D Tax Credits

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    A recent increase in denials of research and development tax credits to small businesses in the architectural, engineering and construction community shows the Internal Revenue Service should issue new guidance to ensure a fair playing field and an opportunity to continue innovating in the U.S., says Julio Gonzalez at Engineered Tax Services.

  • IRS Should Revise Private Debt Collection Methodology

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    To fulfill the congressional intent underlying the Taxpayer First Act, which aims to protect delinquent taxpayers from entering into payment plans they cannot afford, the Internal Revenue Service should use both last-return-filed and third-party income information in its methodology for identifying low-income taxpayers, says National Taxpayer Advocate Erin Collins.

  • Applying OECD Guidance On COVID-19 Transfer Pricing

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    In light of the recently released Organization for Economic Cooperation and Development's guidance on the transfer pricing implications of the pandemic, taxpayers should be prepared to explain and defend their transfer pricing decisions for fiscal year 2020 for contemporaneous documentation and in future tax audits, say Susan Fickling and TJ Michaelson at Duff & Phelps.

  • A Tough Road Ahead for Democrats' Ambitious Policy Agenda

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    While Democrats in Congress are well on their way to enacting an initial COVID-19 relief bill, they will face challenges when pivoting to President Joe Biden's Build Back Better goals for job creation and economic revitalization, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.

  • Coca-Cola Tax Ruling Offers 5 Lessons For Multinationals

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    The U.S. Tax Court's decision that Coca-Cola owes more than $3.3 billion in taxes is instructive on important transfer pricing concepts, including those regarding intercompany agreements, the arm's-length standard and tax certainty, says ​​​​​​​Justin Radziewicz at Duff & Phelps.

  • Small Biz Should Self-Advocate For Tax Relief Under Biden

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    Small and medium-sized businesses have significant potential for achieving regulatory relief from the U.S. Department of the Treasury and other federal agencies during the Biden administration, but to do so they must define their priorities, leverage two federal statutes that require the Treasury to protect them and make their voices heard through communal e-advocacy, says Monte Silver at Silver & Co.

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