Federal

  • November 09, 2022

    11th Circ. Affirms 9-Year Sentence For Harassing Tax Officials

    The Eleventh Circuit upheld Wednesday the nearly nine-year prison sentence of a Georgia man convicted of filing harassing liens against former IRS Commissioner John Koskinen and former Treasury Secretary Jacob Lew, saying his "profound" failure to accept responsibility warranted the sentence.

  • November 09, 2022

    Telecom Groups Push For Broadband Grant Tax Exemption

    Several major telecom groups have pressed Congress to approve a recently introduced bill that would prevent the taxation of broadband grants under last year's infrastructure law and American Rescue Plan.

  • November 09, 2022

    FBAR Penalty Case Arguments Show Justices Of Multiple Minds

    Questions from the U.S. Supreme Court justices in a recent oral argument signaled differing approaches that could result in multiple opinions in a Texas man's challenge to the government's attempts to penalize him $10,000 for each foreign bank account he failed to disclose nonwillfully.

  • November 09, 2022

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

    Federal courts lack 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, a Ninth Circuit panel affirmed Wednesday.

  • November 09, 2022

    Settlement Concludes $4M FBAR Penalty Dispute In DC

    A D.C. federal court dismissed a case seeking nearly $4 million in penalties against an estate whose decedent failed to report foreign bank accounts after the parties agreed to a stipulation to drop the case. 

  • November 09, 2022

    11th Circ. Upholds Tax Debt Scammer's 5-Year Sentence

    The Eleventh Circuit upheld the five-year prison sentence of a Florida mother who posed as an IRS liaison to people trying to pay their tax debts, saying Wednesday that a lower court correctly assessed the severity of her crimes when giving her the maximum sentence.

  • November 09, 2022

    IRS Seeks 700 New Taxpayer Assistance Center Employees

    The Internal Revenue Service is looking to fill 700 positions in Taxpayer Assistance Centers, the agency said Wednesday.

  • November 09, 2022

    IRS Data Officer To Become An Acting Deputy Commissioner

    The Internal Revenue Service's chief data and analytics officer will serve as the agency's acting deputy commissioner for services and enforcement, according to an announcement by the incoming acting commissioner provided to Law360 on Wednesday.

  • November 09, 2022

    IRS Seeks Comments On REMIC Information Form

    The Internal Revenue Service asked for comments Wednesday on a form that makes it possible for the agency to publish information that allows brokers to contact real estate mortgage investment conduits, or REMICs.

  • November 09, 2022

    Tax Court Strikes IRS' Conservation Easement Penalty Notice

    The IRS violated administrative law in issuing a notice requiring the disclosure of potentially abusive conservation easement transactions under threat of penalty, the U.S. Tax Court ruled Wednesday, striking down the guidance and rejecting penalties the agency sought to impose on four North Carolina partnerships.

  • November 09, 2022

    EU, South Korea Urge Loosening Of EV Credit Assembly Rules

    The U.S. should loosen requirements that electric vehicles have a final assembly in North America in order to qualify for clean vehicle tax credits under the Inflation Reduction Act, South Korea and the European Union said in comments.

  • November 09, 2022

    Feds Seek 3 Years In Prison For Exec In Tax Prep Fraud

    A former executive at a national tax return preparation business shuttered for committing tens of millions of dollars in fraud for nearly a decade should serve three years in prison, the government argued, saying his behavior was deliberate and sophisticated.

  • November 09, 2022

    Jurisdiction Issue Sinks Israeli Firm's Challenge To GILTI Regs

    A D.C. federal court dismissed an Israeli law firm's challenge to the global intangible low-taxed income regulations, saying it lacked jurisdiction to defer enforcement of rules that impose tax obligations.

  • November 08, 2022

    NY's AG Won Reelection. Next Up: Trump And The NRA

    New York Attorney General Letitia James won't have much time to celebrate winning a second term Tuesday as the Democratic incumbent ramps up an aggressive enforcement agenda, including politically fraught suits targeting Donald Trump's business empire and the National Rifle Association.

  • November 08, 2022

    Control Of Congress Too Close To Call

    Control of both chambers of Congress remained up for grabs on Wednesday, with the House and the Senate too close to call amid unexpectedly strong Democratic performance across the country in Tuesday's elections.

  • November 08, 2022

    King & Spalding Adds Tax Partner In Paris

    The Paris office of King & Spalding LLC added a new tax partner who will join the firm's corporate, finance and investments practice.

  • November 08, 2022

    Automakers Ask For Transition Period For EV Credit Rules

    Hyundai, Subaru and Volkswagen asked the U.S. Department of the Treasury for a more flexible transition to the Inflation Reduction Act's rules for the electric vehicle tax credit for cars that were previously eligible for the program.

  • November 08, 2022

    Netflix, Hulu Don't Owe Ark. City's Fees, 8th Circ. Affirms

    The Eighth Circuit agreed Tuesday that an Arkansas city cannot impose fees on Netflix and Hulu and that state law does not give the city the right to bring a class action suit against the streaming companies.

  • November 08, 2022

    Cross-Border Tax Complications May Limit Digital Nomads

    The normalization of remote work has prompted companies to embrace geographic mobility, but for businesses seeking to accommodate digital nomads — those untethered to specific locations — the associated tax headaches of global teleworking may narrow what employers can offer in practice.

  • November 08, 2022

    Bond Attys Ask For Guidance On Interbank Rate Regs

    The Internal Revenue Service should clarify that contract modifications accounting for the discontinuation of some interbank offered rates will not be treated as a taxable sale, a group representing state and municipal bond attorneys said in a letter made public Tuesday.

  • November 08, 2022

    NY Bar Tax Section Urges IRS To Clarify Stock Buyback Law

    The U.S. Department of the Treasury should release guidance clarifying how net stock buybacks are determined for an excise tax on repurchases under the Inflation Reduction Act, the New York State Bar Association's Tax Section said in a letter released Tuesday.

  • November 08, 2022

    Virgin Islands Co. Sues For Immediate $28M Tax Refund

    A U.S. Virgin Islands mortgage company sued the territorial government for nearly $28 million in tax refunds, saying the government's offer to pay the money back over potentially eight years is unfair and would cost the public too much in interest.

  • November 08, 2022

    Couple Can Offset Taxes With Partner Losses, 9th Circ. Told

    A Nevada couple said the Ninth Circuit should affirm a U.S. Tax Court decision finding they could offset their taxes using partnership losses they claimed on unsigned returns after filing their suit.

  • November 08, 2022

    IRS Corrects Comment Period On Proposed Actuary User Fee Hike

    The Internal Revenue Service on Tuesday corrected the date until which comments will be accepted on proposed rules increasing user fees for enrolled actuaries to $680.

  • November 08, 2022

    11th Circ. Reopens $26.5M Deduction Appeal After Late Filing

    A Georgia partnership whose appeal of its rejected $26.5 million conservation deduction was tossed when its lawyers missed a filing deadline will have another chance to pursue the appeal after the case was reinstated at the Eleventh Circuit.

Expert Analysis

  • To Capture All Digital Transactions, Tax Rules Must Keep Up

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    Legislative efforts to capture revenue from digital-transaction income can do better than the American Rescue Plan Act, which recently went into effect but employs definitions that have already been surpassed by technology, says Matthew Agramonte at Shutts & Bowen.

  • Lessons From Recent PPP Loan And COVID Fraud Cases

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    Following President Joe Biden's recent pledge to expand enforcement efforts against pandemic and Paycheck Protection Program loan fraud, a look at the U.S. Department of Justice's recent criminal and civil enforcement actions sheds light on its evolving priorities, say Sara Lord and Aaron Danzig at Arnall Golden.

  • Ampersand Clarifies Power Project Placed-In-Service Analysis

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    The Federal Circuit's recent ruling in Ampersand Chowchilla Biomass v. U.S. affirms a lower court's decision regarding when power generation projects were placed in service for federal income tax purposes, but also highlights that the placed-in-service analysis is not one size fits all, say David Burton and Viktoria Vozarova at Norton Rose.

  • Simplifying Tax Issues For Nonresident Athletes In Canada

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    Tax compliance can be particularly challenging for nonresident professional athletes playing in Canada, but as NHL contract negotiations approach a close, it's worth looking at some ways the tax burden can be mitigated, say Marie-France Dompierre and Marc Pietro Allard at Davies Ward.

  • Steps For Universities As DOJ Shifts Foreign Influence Policy

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    Notwithstanding Wednesday's U.S. Department of Justice announcement terminating the initiative targeting Chinese influence and raising the bar for criminal prosecutions, universities should ensure their compliance controls meet new disclosure standards and that they can efficiently respond to inquiries about employees' foreign connections, say attorneys at Covington.

  • How Gold Coin Tax Ruling May Apply To IRA Crypto Holdings

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    The U.S. Tax Court’s recent decision in McNulty v. Commissioner, affirming that a self-directed individual retirement account owner received taxable distributions in taking possession of her IRA’s gold coins, may have troublesome applications for retirement accounts with cryptocurrency holdings, says Luke Bailey at Clark Hill.

  • Why I'll Miss Arguing Before Justice Breyer

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    Carter Phillips at Sidley shares some of his fondest memories of retiring Justice Stephen Breyer both inside and out of the courtroom, and explains why he thinks the justice’s multipronged questions during U.S. Supreme Court oral arguments were everything an advocate could ask for.

  • Corporate Reporting Considerations As Tax Meets ESG

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    With the U.S. Securities and Exchange Commission filing season upon us amid increasing pressure for greater transparency around effective tax rates and tax strategies, multinational companies must decide how they will approach voluntary tax reporting and prepare their responses if they want to control the narrative, say Michael Lebovitz and Jenny Austin at Mayer Brown.

  • How To Navigate Equity Rollovers In A Tight M&A Market

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    As heavy competition for acquisition targets allows buyers to be more flexible in fulfilling their desire for management to roll equity and invest with them, businesses should be mindful that equity rollover transactions, which take many forms, also require thorough review as part of the overall transaction assessment, says Joshua Klein at Neal Gerber.

  • 11th Circ. Ruling Moves Circuits Closer To Tax Procedure Split

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    The Eleventh Circuit's recent decision in the conservation easement case Hewitt v. Commissioner of Internal Revenue, holding a long-standing tax regulation procedurally flawed under the Administrative Procedure Act, is unusual and may presage a circuit split over the APA's applicability in tax cases, say Maria Jones and Samuel Lapin at Miller & Chevalier.

  • How Justices May Interpret Statutory Time Bar In Tax Context

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    In Boechler PC v. Commissioner, the U.S. Supreme Court will rule on whether a tax court filing deadline acts as a jurisdictional limitation, and whether to broaden a jurisprudential trend that requires Congress to clearly state its intent if statutory time periods are to limit jurisdiction, say Saul Mezei and Terrell Ussing at Gibson Dunn.

  • Money Laundering Regs Too Unwieldy To Police Art Market

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    As the arts and antiquities trade awaits the U.S. Department of the Treasury's new money laundering regulations — which apply the Bank Secrecy Act to the arts for the first time — whether they are reasonable, optimal or practical remains in question, says Alexandra Darraby at The Art Law Firm.

  • Why US Businesses May Stop Accepting Cryptocurrency

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    New reporting requirements from the IRS and Financial Crimes Enforcement Network could be game changers that dramatically curtail U.S. businesses that accept cryptocurrency, says cybersecurity consultant John Reed Stark.

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