Federal

  • October 21, 2022

    Timberland Appealing $505M Tax Court Case To 1st Circ.

    The parent of Timberland is challenging a $504.7 million tax bill in the First Circuit in a case in which the Tax Court said the company failed to recognize gains from intangible property after a merger with another apparel maker, court records show.

  • October 21, 2022

    House GOP Tax Writers Push IRS To Explain Destroyed Docs

    Internal Revenue Service Commissioner Chuck Rettig should provide Congress with all documents related to the agency's decision to destroy more than 30 million taxpayer documents last year, two House Ways and Means lawmakers said in a letter released Friday.

  • October 21, 2022

    Fla. Woman Owes $760K In FBAR Penalties, US Says

    A Floridian owes the U.S. government about $760,000 for failing to report her foreign bank accounts, the government said in a suit filed in Florida federal court.

  • October 21, 2022

    Trump Org Trial To Open With All Eyes On Ex-CFO's Testimony

    The criminal fraud trial against the Trump Organization begins Monday in Manhattan with its longtime chief financial officer set to testify to financial crimes amid the conspicuous absence of charges against former President Donald Trump or his adult children.

  • October 21, 2022

    Taxation With Representation: Gibson Dunn, Freshfields

    In this week's Taxation With Representation, Marriott International will acquire the City Express brand, BP will purchase Archaea Energy, and Continental Resources will go private.

  • October 21, 2022

    Transaction Insurance Marching On Despite M&A Slowdown

    Mergers and acquisitions may be slowing down in 2022, but improvements in underwriting and increased policyholder awareness mean transaction insurance, like representations and warranties insurance and tax insurance, continues to grow in popularity.

  • October 21, 2022

    2 Profit-Sharing Plans Can Be Treated As 1 Replacement Plan

    Two defined contribution profit-sharing plans to which excess assets from a terminated cash balance plan will be transferred can be considered a single replacement plan, the Internal Revenue Service said in a private letter ruling released Friday.

  • October 21, 2022

    IRS Ups Employee Plan Contribution, Compensation Limits

    The limit on contributions to defined contribution plans will increase to $66,000 for 2023, while the compensation limit for employees in certain employee retirement plans will go up to $330,000, the Internal Revenue Service said Friday.

  • October 21, 2022

    Tax Pros Hope For Broad Privilege Ruling From High Court

    The U.S. Supreme Court agreed this month to review a tax-related case on attorney-client privilege, and practitioners hope the court will use the occasion to take a broad approach toward privilege that acknowledges the importance of tax advice. 

  • October 21, 2022

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly revenue bulletin, which included requests for comments on provisions of the Inflation Reduction Act that deal with clean energy and other tax credits.

  • October 20, 2022

    Justice Barrett Rejects Effort To Block Student Debt Relief

    U.S. Supreme Court Justice Amy Coney Barrett on Thursday denied an emergency appeal by a group of Wisconsin taxpayers who want to block President Joe Biden's student debt relief program, the same day a Missouri federal judge rejected a similar effort by six Republican-led states.

  • October 20, 2022

    3 Takeaways From The OECD's Crypto Transparency Rules

    The OECD’s recently finalized proposal for cross-border tax information exchanges involving digital assets clarified the framework’s scope but leaves open questions about reporting obligations for cryptocurrency transactions carried out through decentralized computer code. Here, Law360 offers three takeaways from the final rules.

  • October 20, 2022

    9th Circ. Doubts Fed. Jurisdiction In Amazon Sellers' Tax Fight

    A Ninth Circuit panel cast doubt Thursday on whether federal courts have jurisdiction to hear an e-commerce trade group's attempt to block California from pursuing back sales taxes from sellers with inventory stored in-state through participation in an Amazon program.

  • October 20, 2022

    1st Circ. Dismisses FedEx Drivers' Stolen Wages Claim

    The First Circuit rejected on Thursday an argument by three FedEx drivers who claimed their wages were stolen, sending the case back to a lower court to decide whether it should be remanded to a state court in Massachusetts, where the drivers worked.

  • October 20, 2022

    Woman Owes $474K In FBAR Penalties, US Says

    A California woman could face at least $474,000 in penalties after the U.S. filed suit in a federal court accusing her of failing to report two Swiss bank accounts she and her now-deceased husband held in 2008.

  • October 20, 2022

    5th Circ. Agrees To End UK Co.'s $18M Tax Case

    Granting the joint request of the two parties, the Fifth Circuit tossed an appeal of a U.K.-based maritime company's $18 million tax bill on Thursday, ending a long-running case.

  • October 20, 2022

    Ga. Retiree Asks For $284,000 FBAR Penalty Refund

    A Georgia retiree who worked for a German-owned business asked a federal court to help him recoup $284,000 in penalties he contends the Internal Revenue Service wrongly forced him to pay for inadvertently failing to report foreign bank accounts.

  • October 20, 2022

    Calif. Couple Owe $29K Deficiency, Tax Court Says

    A California couple owe a tax deficiency of over $29,000 for 2015 but not an accuracy related penalty, the U.S. Tax Court said Thursday.

  • October 20, 2022

    House Bill Seeks 300% Excise Tax On Water-Intensive Crops

    A bill introduced by a member of the House Committee on Natural Resources would impose a 300% excise tax on the sale or export of water-intensive crops in drought-stricken areas by foreign entities.

  • October 20, 2022

    11th Circ. Asked To Revive $26.5M Conservation Deduction Row

    A Georgia partnership challenging an IRS decision to block its $26.5 million tax deduction for a conservation land donation asked the Eleventh Circuit to overturn a decision upholding the denial, saying the agency violated the company's right to an independent review.

  • October 20, 2022

    Treasury Pulls Floated Repatriation Rules Ahead Of New Ones

    The U.S. Treasury Department withdrew guidance Thursday that was floated in 2006 to address the repatriation of previously taxed foreign earnings and profits, clearing the way for new proposed rules expected in 2023.

  • October 19, 2022

    KPMG Units To Pay $275K To End Audit Disclosure Claims

    Three KPMG units will be censured and pay fines totaling $275,000 to end allegations from the Public Company Accounting Oversight Board that they failed to disclose the affiliate firms that worked on three audits, the board announced Wednesday.

  • October 19, 2022

    Whirlpool Owes Taxes On $45M In Income, US Tells Justices

    The Sixth Circuit correctly affirmed Whirlpool owed taxes on more than $45 million in income earned by a Luxembourg affiliate and didn't need to look to the law's regulations, the U.S. government told the U.S. Supreme Court on Wednesday.

  • October 19, 2022

    Germany, France Seek Strong Reply To Inflation Reduction Act

    Europe should provide a strong response to parts of the Inflation Reduction Act — such as subsidies that could distort fair competition — without tit-for-tat measures that risk a trade war, German and French cabinet officials said Wednesday at a news conference.

  • October 19, 2022

    House GOP Lawmakers Slam Treasury Race Panel As Divisive

    The U.S. Department of the Treasury's racial equity advisory panel will worsen the Biden administration's politicization of the department and distract the department from its core work, four House Republican lawmakers said in a letter released Wednesday.

Expert Analysis

  • Key Trade Secret Developments Of 2020: Part 2

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    Last year, federal courts issued several important rulings on trade secret issues that will affect litigation practice, including the importance of narrow, well-supported sealing requests, whether refining trade secret identification after discovery is permissible, and when punitive damages comport with due process, say attorneys at Faegre Drinker.

  • A Road Map For US Involvement In Europe's Cum-Ex Probe

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    The dividend arbitrage trading strategy known as cum-ex continues to face regulatory scrutiny in Europe, and stateside regulators may soon follow suit with the U.S. Securities and Exchange Commission’s recent American depositary receipt probe as a guide for enforcement, says Joshua Ray at Rahman Ravelli.

  • What Energy Sector Should Expect From Biden's Tax Policies

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    The energy sector may find new investment opportunities or the need to adjust holdings, depending on whether company goals align with the Biden administration's potential rollback of Trump-era tax reforms, and push for clean energy, reduced carbon emissions and increased domestic manufacturing, says Gregory Matlock at Mayer Brown.

  • Congress Should Make TCJA Income Definition Permanent

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    Congress should not allow the Tax Cuts and Jobs Act's definition of adjusted taxable income, which includes depreciation and amortization, to expire in 2022 because it would discourage debt-free investment, running counter to the law's intent, says George Callas at Steptoe & Johnson.

  • Raising Capital For Real Estate Deals During The Pandemic

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    Real estate sponsors looking to invest in the current environment should consider the various advantages and risks of forming a commingled real estate investment fund versus raising capital on a deal-by-deal basis, says Matt Ertman at Allen Matkins.

  • Bankruptcy Ruling Highlights Longer Lookback Trend

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    The U.S. Bankruptcy Court's recent decision in Zagaroli underscores a trend among bankruptcy courts to allow longer lookback periods in certain types of fraudulent transfer cases, which could be a significant source of estate recovery for creditors, say attorneys at Lowenstein Sandler.

  • OECD Delays Are Imperiling Digital Tax Deal

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    As the Organization for Economic Cooperation and Development continues to push back its deadline for a digital tax overhaul, countries are beginning to pursue unilateral solutions and the negotiations are turning political, decreasing the likelihood of an agreement, says Joyce Beebe at Rice University.

  • How 2021 Appropriations Law Changes Employer Benefits

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    The Consolidated Appropriations Act signed into law in December makes a surprising number of changes to rules for employer-sponsored health and welfare benefits that will likely have a significant impact, especially the provisions concerning flexible spending accounts, say Eric Schillinger and Anne Hall at Hall Benefits Law.

  • How Rebooted Paycheck Protection Program Works: Part 2

    Excerpt from Practical Guidance
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    Attorneys at Cozen O'Connor analyze key provisions of the U.S. Small Business Administration's two new interim final rules regulating first-draw and second-draw loans under the reinstituted Paycheck Protection Program.

  • How Rebooted Paycheck Protection Program Works: Part 1

    Excerpt from Practical Guidance
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    Attorneys at Cozen O'Connor provide an overview of the recently reinstituted Paycheck Protection Program's provisions for new borrowers to receive loans and existing borrowers to receive additional funding, and the U.S. Small Business Administration's startup of the program.

  • How To Reliably Value Income-Producing Real Estate

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    Amid the pandemic-fueled surge in tax appeals and loan workouts, using the income approach to calculate the present worth of a property's future income provides the most reliable indication of value and does not rely on subjective adjustments, say Mark Dunec at FTI Consulting and Anthony DellaPelle at McKirdy Riskin.

  • What New AML Law Means For Correspondent Banking

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    In light of the National Defense Authorization Act’s recent overhaul of the Bank Secrecy Act and related anti-money laundering laws, foreign banks maintaining correspondent bank accounts in the U.S. should be aware of law enforcement's expanded authority to access bank records for their transactions, say attorneys at Arnold & Porter.

  • Addressing The Security Risks Of University Foreign Funding

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    Higher education institutions that accept foreign funding should address serious concomitant security risks by identifying specific sources and establishing compliance procedures that promote transparency, protect data and research, and account for U.S. national security interests, say attorneys at Manatt.

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