Federal
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March 28, 2024
IRS Floats Expanding Tax Info Disclosures To Census Bureau
The Internal Revenue Service proposed rules Thursday that would expand what tax return information can be disclosed to the U.S. Census Bureau.
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March 28, 2024
IRS Investigated $9B In Potential COVID Aid Fraud
The criminal investigation arm of the Internal Revenue Service investigated nearly $9 billion in potential fraud cases related to coronavirus relief funds, the agency said Thursday.
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March 28, 2024
Nev. Estate Owes Over $3.8M In FBAR Penalties, Court Rules
The estate of a Nevada entrepreneur must pay over $3.8 million in penalties and interest for willfully failing to report his foreign bank accounts in Belize, the Bahamas and Panama, a federal district court ruled.
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March 27, 2024
Hunter Biden Judge Doubts Tax Charges Politically Motivated
A California federal judge Wednesday appeared unpersuaded by Hunter Biden's claim that the special counsel's decision to file criminal tax charges after a plea deal collapsed was motivated by pressure from Republican lawmakers, remarking that "there really is no evidence to support that contention."
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March 27, 2024
Zaxby's Co-Founder's $43M Easement Fight Headed For Trial
A trial will be needed to determine whether a co-founder of the Zaxby's restaurant chain and his wife are entitled to a $43.3 million tax refund for donations of conservation easements, a Georgia federal judge ruled Wednesday, saying the value of the easements remains in dispute.
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March 27, 2024
NY Couple Hid $1.4M In Dividends, Tax Court Says
A New York man who pled guilty to healthcare fraud and his wife are liable for tax deficiencies after failing to report more than $1.4 million in constructive dividends, the U.S. Tax Court said Wednesday.
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March 27, 2024
Treasury Urged To Adjust Shift To Foreign Currency Rules
The U.S. Treasury Department should let corporations take an aggregate approach regarding certain affiliates that conduct business in foreign currencies when transitioning to new rules for determining taxable income or loss, the American Bar Association's Tax Section recommended.
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March 27, 2024
IRS Delays Some Hawaii Deadlines Until August After Fires
The Internal Revenue Service granted an additional extension of filing and payment deadlines for some Hawaii taxpayers affected by wildfires, the agency said Wednesday.
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March 27, 2024
Justices Grapple With Complex $3M Estate Tax Dispute
The U.S. Supreme Court confronted a complicated dispute Wednesday over whether the estate of a deceased building supply company owner should be taxed on $3 million in life insurance proceeds the company used to buy his shares after his death, with two justices seeming to take opposing sides.
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March 27, 2024
Groups Urge IRS To Keep Strict Hydrogen Tax Credit Rules
Some supporters of the Internal Revenue Service's proposed rules for the clean hydrogen production tax credit encouraged the agency Wednesday to maintain strict qualification criteria for the incentive to further discourage the use of fossil fuels in the manufacturing process and to reduce pollution.
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March 27, 2024
NY County Seeks To Bar NYC Congestion Prices As Illegal Tax
A New York county with limited access to the Metropolitan Transportation Authority's service system jumped into the litigation fray against New York City's congestion pricing plan, arguing that the proposed charges for driving into portions of Manhattan are illegal taxes.
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March 27, 2024
Worker Credit Cutoff Seen As Harsh But Fair Potential Fix
Tax legislation pending in the Senate would retroactively end the employee retention tax credit program and leave businesses with a legitimate need for the credit out in the cold, but lawmakers say the move is necessary given the magnitude of fraud in the program.
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March 27, 2024
Advice-Of-Counsel Defense Curbed From NC Tax Fraud Trial
Two St. Louis attorneys and a North Carolina insurance agent can't fall back on advice-of-counsel defenses during their upcoming tax fraud trial after a federal judge found that they had failed to follow court orders requiring them to hand over information about the advice they sought.
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March 26, 2024
Meta Can't Escape Suit Over Collection Of Taxpayers' Data
A California federal judge refused to release Meta from a consolidated class action accusing it of unlawfully collecting sensitive information from tax filing websites H&R Block, TaxAct and Tax Slayer, allowing state and federal wiretapping claims to move forward and permitting the plaintiffs to amend several deficient privacy allegations.
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March 26, 2024
Adjusting To Amount B's Rules May Bring Growing Pains
Countries designed a new tax framework known as Amount B to streamline the pricing of certain cross-border operations, but the criteria for determining whether transactions qualify for the regime, which negotiators recently made optional, may complicate the goal of simplicity.
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March 26, 2024
$4.5M Microcaptive Insurance Deduction Nixed By Tax Court
An eye doctor can't deduct more than $4.5 million in insurance premiums that he paid to two microcaptive companies because the payments don't qualify as valid insurance purchases for federal income tax purposes, the U.S. Tax Court ruled Tuesday.
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March 26, 2024
$23M Easement Deduction Worth Only $480K, Tax Court Says
The U.S. Tax Court significantly reduced the value of a $23 million deduction taken by the members of a Delaware partnership Tuesday, instead allowing them $480,000 for the charitable donation of an easement.
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March 26, 2024
NC Software Execs Ask To Raze Payroll Tax Fraud Conviction
Two former software executives found guilty of failing to pay hundreds of thousands of dollars in employment taxes have sought to wipe out their conviction based on what they allege was insufficient evidence presented by the government at trial.
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March 26, 2024
Producers Push IRS For Flexible Clean Hydrogen Credit Regs
The IRS should adopt flexible metrics to measure greenhouse gas emissions in proposed rules for the clean hydrogen production tax credit to accommodate energy companies' transition toward cleaner production methods, stakeholders said during a hearing on the regulations Tuesday.
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March 26, 2024
9th Circ. Judges Skeptical Senior Care Facility Owes IRS $20M
Ninth Circuit judges seemed skeptical of the Internal Revenue Service's efforts to force a California-based senior care facility to pay a $20 million tax bill, saying the facility's deferral of unamortized portions of resident fees didn't run afoul of generally accepted accounting methods.
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March 26, 2024
Nev. Foreclosed Property To Be Sold To Pay Co.'s Tax Debt
A Nevada federal court approved the sale of a foreclosed Las Vegas property in the federal government's efforts to recoup nearly $943,000 in taxes owed by a security company.
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March 26, 2024
IRS Fixes Typo In Contribution Rules
The Internal Revenue Service issued a correction notice Tuesday fixing a typographical error within regulations about contributions to certain organizations.
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March 25, 2024
Clean Hydrogen Tax Credit Regs' Pillars Too Strict, IRS Told
The so-called three pillars in proposed clean hydrogen production tax credit rules used to determine the incentive's value would prevent the rapid scaling of a nascent sector that aims to produce zero-carbon emissions fuel, stakeholders told the Internal Revenue Service on Monday.
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March 25, 2024
Tax Groups Urge Justices To Review Philly Tax Credit System
The U.S. Supreme Court should hear a woman's claims that Philadelphia unconstitutionally declined to credit her Delaware state income taxes paid against her city wage tax liabilities, a taxpayer advocacy organization and a group of tax lawyers told the justices Monday.
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March 25, 2024
Alaskans Hit By Storms Can Delay IRS Tax Filings, Payments
Taxpayers in Alaska impacted by severe storms, landslides and mudslides that started Nov. 20 now have until July 15 to file various federal individual and business tax returns and make tax payments, the Internal Revenue Service said Monday.
Expert Analysis
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Lessons From The SEC's Largest-Ever Audit Firm Penalty
The U.S. Securities and Exchange Commission's recent $100 million settlement over professional test cheating with Ernst & Young — the largest ever in an audit firm case — points to important ramifications for any entity responding to an SEC inquiry, say attorneys at Cleary.
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Navigating The IRS Pre-Audit Retirement Plan Pilot Program
The Internal Revenue Service launched a Pre-Examination Compliance Pilot program for retirement plans last month that gives sponsors and administrators 90 days to self-correct errors and avoid audits, and while several details are unclear, there are important steps to take at this time, say attorneys at Ice Miller.
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Key Takeaways From IRS Reversal On FDII Stance
The Internal Revenue Service's recent memo regarding allocation of deferred compensation expenses for purposes of foreign-derived intangible income is a departure from the agency's previous position and may have implications beyond the context of deferred compensation, say attorneys at Miller & Chevalier.
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How To Address Research Expenditures Amid Uncertainty
Taxpayers need to prepare for the significant technical and compliance challenges of following Internal Revenue Code Section 174's new rules for experimentation expenditure capitalization and amortization, notwithstanding the rules' unresolved legislative future, say tax advisers at Grant Thornton.
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LeClairRyan Bankruptcy Highlights Pass-Through Tax Issue
A Virginia bankruptcy court's recent ruling in the case of defunct law firm LeClairRyan shows there may be serious tax consequences for pass-through entity partners who give up their ownership interest without following operating agreement exit provisions and updating bankruptcy court filings, say Edward Schnitzer and Hannah Travaglini at Montgomery McCracken.
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Tax, Social Services And The Need For An IRS Overhaul
Revamping the Internal Revenue Service should start with visibly improving taxpayer experiences to help pave the way for other fundamental changes needed to address the recent drop in audit numbers, personnel losses, burdens of its increasing expansion into social services and other problems, says Rice University fellow Joyce Beebe.
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Key Legal And Regulatory Trends In Oil And Gas Transactions
Excerpt from Practical Guidance
Attorneys involved in oil and gas transactions must be aware of important legal and regulatory trends that have emerged recently, including issues surrounding hydraulic fracturing, climate change, pipeline tariffs and a resurgence of regulation under the Biden administration, say Justin Hoffman and Thomas Blackwell at Baker Botts.
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Employer Considerations For Leave Donation Programs
As the battle for talent continues and workers return to the office, companies may consider allowing employees to donate accrued leave time to a shared bank, but employers should first review these programs' complex design issues to comply with state laws and avoid tax consequences, says Rebecca Hudson at Holland & Hart.
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Crypto Cos. Should Prep For More IRS John Doe Summonses
In anticipation of new reporting requirements that will go into effect in 2024, cryptocurrency exchanges and custodians should inform themselves on the John Doe summons, a unique mechanism that allows the IRS to obtain expansive information about cryptocurrency transactions, say Shivani Poddar and Andrew Heighington at Herrick Feinstein.
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Employer Travel Benefits Options For Abortion Care Post-Roe
Given the likelihood that Roe v. Wade will be overturned, and with the proliferation of state legislation restricting abortion access, employers may want to consider the legal implications of several options to expand travel reimbursement benefits for employees who seek abortion services, say Danita Merlau and Ben Conley at Seyfarth.
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Global Tax Chiefs Should Look To US Whistleblower Programs
As the Joint Chiefs of Global Tax Enforcement develops its international whistleblower program to address tax evasion and money laundering schemes in new areas like cryptocurrency, it should take lessons from highly successful U.S. programs on which features to include and pitfalls to avoid, say Neil Getnick and Nico Gurian at Getnick & Getnick.
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Crypto Investors May Face Increasing State FCA Tax Liability
Cryptocurrency investors who fail to report the state tax consequences of transactions are poised to encounter increased civil or criminal legal exposure as a growing number of states bring tax fraud under the purview of their whistleblower statutes, say attorneys at Brownstein Hyatt.
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Justices' Boechler Ruling May Spell Tax Exceptionalism's End
By basing its decision on cases outside the tax arena, the U.S. Supreme Court treated Boechler v. Commissioner as an administrative law case rather than a tax case and stripped away the traditional lines of tax exceptionalism, says James Creech at Baker Tilly.