Federal
-
April 12, 2024
Taxation With Representation: Freshfields, Kirkland & Ellis
In this week's Taxation with Representation, eBay acquires Collectors' Goldin auction house, Vertex Pharmaceuticals buys Alpine Immune Sciences, Vista Equity Partners purchases Model N and Tradeweb Markets buys Institutional Cash Distributors.
-
April 12, 2024
IRS Schedules Advisory Council Meeting For May
The Internal Revenue Service Advisory Council will hold its next meeting May 8, the agency announced Friday.
-
April 12, 2024
Moses & Singer Hires New Private Clients Chair, Trusts Expert
Moses & Singer LLP has hired a new chairman of its private clients group, who joins the firm after spending over a decade navigating trusts and estates matters with Kudman Trachten Aloe Posner LLP.
-
April 11, 2024
Biz Owners Tell House Panel Extending Tax Cuts Is Crucial
It is essential that Congress extends provisions of the 2017 tax law that are set to expire in 2025, especially the law's pass-through deduction, business leaders told the House Ways and Means Committee on Thursday.
-
April 11, 2024
Judge Sends Tax Data Suit Against H&R Block To Arbitration
A man who used H&R Block to prepare his taxes online and then sued the company, along with Google and Meta Platforms Inc., for sharing his private data must pursue his claims against the tax preparation software giant in arbitration, a California federal judge ruled Thursday.
-
April 11, 2024
Fla. Restaurateur Gets Prison Time For Dodging Payroll Taxes
The ex-CEO of a defunct Jacksonville, Florida-based restaurant chain was sentenced to 2½ years in federal prison after pleading guilty earlier this year to willfully failing to pay more than $5 million in payroll taxes.
-
April 11, 2024
Int'l Salesman Stuck With FBAR Fines For Swiss Account
An agricultural salesman earning money in Ukraine willfully hid a Swiss bank account from the IRS that neither his accountant nor his wife knew about, a Nebraska federal judge said Thursday in upholding more than $600,000 in reporting penalties against him.
-
April 11, 2024
Tax Controversy Quintet Joins Bradley Arant In Atlanta
Bradley Arant Boult Cummings LLP announced that it hired a five-person tax controversy team from Chamberlain Hrdlicka White Williams & Aughtry highlighted by the addition of three experienced partners, including two former Internal Revenue Service trial attorneys.
-
April 11, 2024
Proskauer Adds Kirkland Partner For Tax, Estate Issues
Proskauer Rose LLP has added to its private client services department a partner from Kirkland & Ellis LLP who specializes in developing domestic and international tax and estate plans for clients with very high net worth, the firm announced.
-
April 11, 2024
Burr & Forman Adds Longtime In-House Leader To Fla. Office
Burr & Forman LLP has brought on an in-house pro with more than $60 billion of transaction experience to its office in Jacksonville, Florida, adding the former general counsel of public company Cannae Holdings Inc. in Las Vegas to its corporate and tax practice.
-
April 11, 2024
Swiss Bank Probe May Prompt IRS To Revive Disclosure Effort
Senate Finance Committee Chairman Ron Wyden's latest investigation into the Swiss banking industry may apply further pressure to federal law enforcement officials to revive a program designed to encourage taxpayers' voluntary compliance in disclosing income held overseas to the IRS.
-
April 11, 2024
IRS Schedules 6 Taxpayer Advisory Panel Meetings For May
The Internal Revenue Service announced the schedule Thursday for six Taxpayer Advocacy Panel committee meetings to be held in May.
-
April 10, 2024
House Panel Leaders Say Tax Bill Delay Hurts Small Biz
The chairman and the ranking member of the House Small Business Committee both urged the Senate on Wednesday to pass the tax bill held up by Republican senators, saying continuing to delay the proposal's package would further burden small businesses.
-
April 10, 2024
Plastic Surgeon Owes $7.7M From Offshore Scheme, US Says
A now-retired plastic surgeon owes the Internal Revenue Service more than $7.7 million after he ran an offshore employee leasing scheme and he and his wife transferred nearly all their assets to their then-11-year-old daughter, who is now a lawyer, the government told an Ohio federal court.
-
April 10, 2024
8th Circ. Skeptical Of Bid To Reveal IRS Fraud Detection Docs
Eighth Circuit judges seemed skeptical Wednesday of a retired Harvard law professor's efforts to force the IRS to reveal its techniques for questioning fraud suspects, as two of three judges on a panel highlighted the potential to prevent identity theft by keeping the techniques hidden.
-
April 10, 2024
Pension Plan Segment Rates Increase In April
Segment rates for calculating pension plan funding rose in April, the Internal Revenue Service said Wednesday.
-
April 10, 2024
Family's $25M Settlement Is Income, Tax Court Says
A $25 million settlement received by a family was not tied to personal injury damages, making it taxable, the U.S. Tax Court ruled Wednesday.
-
April 10, 2024
Fla. Atty Gets 8 Years For Fraudulent Tax Shelter Scheme
A Florida attorney was sentenced Wednesday to eight years in prison after pleading guilty in federal court to tax evasion and defrauding the U.S. government through a tax shelter scheme he pitched to clients that involved making purported charitable contributions so his clients could claim millions of dollars in tax deductions they weren't qualified to receive.
-
April 10, 2024
IRS' DOJ Referral Rules 'A Disaster,' Sen. Whitehouse Says
The IRS protocols for referring cases to the U.S. Department of Justice are "a disaster" for enforcing laws against bankers and other actors who help U.S. taxpayers evade taxes, Sen. Sheldon Whitehouse said Wednesday during a hearing on offshore tax evasion before the Senate Budget Committee.
-
April 10, 2024
Feds Cleared To Use Undercover Recording In Atty's Tax Trial
Federal prosecutors trying an attorney next week on charges he orchestrated a tax fraud scheme that spanned seven states will be allowed to play for the jury an audio recording made by an undercover agent, a North Carolina federal judge ruled.
-
April 10, 2024
IRS Floats Alternative For Hydrogen Credit Emissions Value
The Internal Revenue Service released guidance Wednesday that would allow hydrogen producers to pursue another method to value their emissions output — which is critical in qualifying for the clean hydrogen production tax credit — if they can't get the information using the Argonne National Laboratory model.
-
April 10, 2024
Senate Finance Panel Schedules Hearing On IRS Budget
The Senate Finance Committee will convene next week to discuss the Internal Revenue Service's budget for 2025, the committee said Wednesday.
-
April 10, 2024
IRS Fixes Heading For Apprenticeship Credits, Deductions
The Internal Revenue Service issued a correction notice Wednesday to fix a heading related to increased tax relief for meeting certain wage and apprenticeship requirements.
-
April 10, 2024
Ex-Trump Finance Chief Weisselberg Jailed For Perjury
A New York state judge on Wednesday sentenced former Trump Organization Chief Financial Officer Allen Weisselberg to five months in jail for lying under oath in the attorney general's civil fraud case against Donald Trump and his business associates, imprisoning a close ally of the former president on the eve of his hush-money trial.
-
April 09, 2024
Treasury Proposes Long-Awaited Stock Buyback Tax Rules
The U.S. Treasury Department proposed a pair of long-awaited rules Tuesday that detail the calculation and reporting of a new excise tax assessed to publicly traded corporations that recently bought back their own shares of stock on the open market.
Expert Analysis
-
How Cos. Can Prep For Alcohol Beverage Excise Tax Changes
The Craft Beverage Modernization Act will soon undergo a transition in administration to the Alcohol and Tobacco Tax and Trade Bureau, and importers or producers should address any issues that may arise under the act, such as foreign producers not being familiar with the mechanics of the TTB, say Louis Terminello and Bradley Berkman at Greenspoon Marder.
-
New R&E Capitalization A Costly Change For Companies
Unless modified by legislation in the coming weeks, radical new capitalization rules for research and experimentation costs mean companies should brace for the loss of a major tax break starting with their 2022 tax returns, says Nancy Dollar at Hanson Bridgett.
-
Congress Is Right To Advance Comprehensive Retirement Bill
As 2022 comes to a close, Congress' move to include the Secure 2.0 Act, a comprehensive retirement bill, in its omnibus spending package will bring retirees and those nearing retirement more peace of mind regarding their 401(k)s, IRAs and pensions, while reducing red tape for employers, says Andy Banducci at the ERISA Industry Committee.
-
10 Pre-Deal Considerations In Cross-Border M&A Transactions
Excerpt from Practical Guidance
Sergio Galvis and Benjamin Kent at Sullivan & Cromwell discuss steps that can be taken to preemptively address important issues that acquirers of foreign businesses encounter in cross-border M&A transactions, including tax planning and political risk.
-
Clean Hydrogen Developers Should Track Incentives, Risks
Clean hydrogen project developers and investors should be aware of new funding opportunities from the U.S. Department of Energy and tax benefits under the Inflation Reduction Act, but must also guard against risks associated with new and evolving technologies, say Pamela Wu and Kirstin Gibbs at Morgan Lewis.
-
IRS Starts Clock On Energy Projects' Labor Rule Exemption
A U.S. Department of the Treasury notice published this week started the 60-day clock for clean energy projects seeking to be grandfathered from having to meet new labor requirements to qualify for enhanced tax credits, and uncertainty about how the provisions will apply should be incentive for some investors to begin construction soon, say attorneys at Eversheds Sutherland.
-
Foreign Tax Credit Proposal Is Some Help, But More Is Needed
New foreign tax credit regulations proposed by the U.S. Treasury Department provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the 2021 final foreign tax credit regulations, but the final regulations are still harmful to many taxpayers, making litigation inevitable, say attorneys at Fenwick.
-
Anticipating The New Congress' Private Sector Investigations
With Republicans claiming a new majority in the House of Representatives in the upcoming Congress, corporates and individuals should expect a sea change in Congress' investigative priorities and areas of focus — and private sector entities can take prudential steps in the near term to best prepare for and mitigate risk, say attorneys at Latham.
-
Tax Equity Requires Reinstating The Home Office Deduction
Congress should restore the home office deduction for W-2 workers in the interest of tax equity because permanently remote workers now bear the cost of creating quiet, dedicated work spaces, a pandemic-related shift unforeseen when the deduction was eliminated by 2017's Tax Cuts and Jobs Act, say James Mahon and Samantha Lesser at Becker.
-
Keys To IRA Tax Breaks For US Green Energy, EV Production
The Inflation Reduction Act includes three powerful tax incentives for domestic production of renewable energy projects and electric vehicles — but there are key questions that investors and manufacturers must ask when evaluating whether they can take advantage of these incentives, say attorneys at Troutman Pepper.
-
Crypto Case Failed To Clarify Taxation Of Staking Rewards
A Tennessee federal court's recent dismissal of Jarrett v. U.S. — after the IRS issued a refund for taxes paid on cryptocurrency and mooted a greater question about the tax treatment of staking rewards — leaves the crypto industry in need of guidance on the IRS’ position, say attorneys at Cadwalader.
-
How The IRS May Define 'Clean Hydrogen'
The Internal Revenue Service is still taking comments on how to define "clean hydrogen" for purposes of Inflation Reduction Act tax credits, but developers can look to the IRA's legislative history — as well as the European Union's struggle to define "green hydrogen" — as guideposts, says Ben Reiter at Nixon Peabody.
-
What To Expect From The Post-Midterms Lame-Duck Session
Depending on the results of the midterm elections, the upcoming lame-duck session may be the last chance for Congress to enact meaningful legislation for the next several years, so organizations must push through legislative priorities now, lest they are forced to restart their efforts in a much different environment next year, says James Brandell at Dykema.