Federal

  • April 19, 2023

    No Decision Yet On Free IRS Filing Program, Chief Says

    The IRS hasn't decided whether to enact a free electronic filing program for taxpayers and won't until a study to evaluate such program is completed, the new head of the agency told the Senate Finance Committee on Wednesday.

  • April 19, 2023

    Tax Court Slashes NH Man's Rental Loss Deduction

    A New Hampshire man who owns rental property can't claim the entirety of a nearly $24,000 loss claimed related to the rentals because he doesn't count as a real estate professional under the tax code, the U.S. Tax Court said Wednesday.

  • April 19, 2023

    Court Urged To Not Revive Adviser's Suit Against IRS, Ex-Atty

    An Arizona federal court should not revive an investment adviser's case against the Internal Revenue Service, several federal employees and his ex-attorney dealing with $2.2 million in foreign account reporting penalties the government alleges he owes, the U.S. government said, arguing the case wasn't properly filed.

  • April 19, 2023

    IRS Made 4.5M Tax Disclosures To Foreign Gov'ts Last Year

    The Internal Revenue Service last year made approximately 4.5 million disclosures of tax returns and return information to foreign governments that have tax treaties with the U.S., the agency told the Joint Committee on Taxation.

  • April 19, 2023

    Ex-Atlanta Exec Cops To Bribery, Evading $1.5M In Tax

    A former executive of an Atlanta construction and design firm pled guilty Wednesday to evading more than $1.5 million in taxes and bribing two city officials in exchange for government contracts and public-private partnerships, according to a Georgia federal court.

  • April 19, 2023

    Bracewell Recruits Tax Atty From Baker Botts In Dallas

    Bracewell LLP announced that a former Baker Botts LLP senior associate who is experienced in advising businesses on state and local tax issues has joined the firm's tax practice as a partner in its Dallas office.

  • April 19, 2023

    Feds Seek 3 Years For Brother In $12M Tax Refund Scam

    An Atlanta nightclub owner who admitted helping his brother steal taxpayers' personal information to illegally obtain more than $12 million in refunds should spend nearly three years in prison, federal prosecutors told a Georgia federal judge.

  • April 18, 2023

    Betterment To Pay $9M In SEC Deal Over Tax-Loss Harvesting

    The U.S. Securities and Exchange Commission announced Tuesday that it reached a $9 million settlement with robo-adviser Betterment LLC for alleged failures in its automated tax loss harvesting service that caused clients to lose about $4 million in potential benefits.

  • April 18, 2023

    Tax Court Denies Initial IRS Bid For $115M Easement Row Win

    The U.S. Tax Court denied an initial bid from the IRS for a win without trial in a partnership's challenge to the agency's denial of a $115.4 million conservation easement deduction, ruling Tuesday that it's not clear there were property mining rights that undermine the claim.

  • April 18, 2023

    IRS Levy On Fla. Man Rightly Upheld, Tax Court Says

    An Internal Revenue Service settlement officer did not abuse her discretion by sustaining a levy notice issued to a Florida man for tax years 2016 and 2017, the U.S. Tax Court said Tuesday.

  • April 18, 2023

    On Tax Day, Dems Float Nixing Carried Interest Loophole

    Democrats in the House and Senate suggested on Tuesday — the same day as the deadline to submit 2022 tax returns or an extension to file and pay taxes — eliminating the so-called carried interest loophole and making changes to the taxation of capital gains.

  • April 18, 2023

    Gov't Seeking Excessive Interest From Tax Evader, Court Told

    The federal government is improperly demanding millions of dollars in interest from a man who pled guilty to tax evasion, he told a Florida federal court, arguing that Treasury had enough of his money to pay off any interest that had accrued on his liabilities.

  • April 18, 2023

    National Grid Escapes Solar Co.'s Tax Suits In Mass.

    A lawsuit brought by two Massachusetts solar companies accusing electric giant National Grid of illegally charging them part of the taxes it claims to owe the government is barred by a law restricting federal courts from granting tax relief, a Massachusetts federal judge ruled Tuesday in dismissing the case.

  • April 18, 2023

    Beyoncé Challenges $3M In Taxes, Penalties Imposed By IRS

    Pop star Beyoncé is challenging the Internal Revenue Service's determination that she owes about $3 million in taxes, interest and penalties for 2018 and 2019, according to a petition filed in the U.S. Tax Court.

  • April 18, 2023

    11th Circ. Asked To Uphold Nix Of $26.5M Easement Suit

    The Eleventh Circuit should reject a partnership's bid to revive its $26.5 million conservation easement deduction lawsuit and uphold a lower court ruling that the case is barred by laws that prevent suits hampering tax collection, the government argued Tuesday.

  • April 18, 2023

    Court Urged To Void IRS Summons To Atty For Client Docs

    A North Carolina federal court should void an IRS summons sent to an attorney seeking records on the businesses currently or previously owned by a former client, the ex-client said in a petition Tuesday, arguing the agency improperly failed to notify him of the request.

  • April 18, 2023

    Couple Owe $27K In Deficiencies, Tax Court Says

    A Michigan couple owe tax deficiencies for 2019 and 2020 totaling almost $27,000, the U.S. Tax Court said in an opinion released Tuesday.

  • April 18, 2023

    US Expatriations Halved In 1st Quarter, IRS Says

    The number of people expatriated from the U.S. fell by about half during the first quarter of 2023 compared with the previous quarter, the Internal Revenue Service said in a notice released Tuesday.

  • April 18, 2023

    7th Circ. Won't Revive Ex-IRS Worker's Race Bias Suit

    A former Internal Revenue Service employee's allegations that her bosses created a hostile workplace where she was discriminated against because of her race are without merit, the Seventh Circuit decided, upholding an Illinois federal court decision.

  • April 18, 2023

    Indiana Storm Victims Get Extensions On Federal Taxes

    Taxpayers affected by tornadoes and storms in some counties in Indiana will have until July 31 to submit some returns and payments, the Internal Revenue Service said Tuesday.

  • April 18, 2023

    Jury Awards $3M In Punitive Damages To Defamed Tax Atty

    A Florida jury awarded more than $3 million in punitive damages on Tuesday to the former law partner of a deceased Miami tax attorney whose widow publicly accused him of scheming to keep the proceeds of a $2 million life insurance policy.

  • April 18, 2023

    Williams & Connolly Partner Gives Up $7M Tax Debt Defense

    Uncle Sam will collect on a $7.3 million debt owed by a Williams & Connolly LLP partner and his wife after the two abandoned their defense in a 2022 complaint the government filed alleging that they skipped out on federal taxes for 11 of the past 22 years.

  • April 17, 2023

    Fla. Jury Finds Widow Defamed Husband's Ex-Law Partner

    A Miami jury on Monday found that a tax attorney's widow defamed her husband's former law partner with statements to the press and a lawsuit accusing him of scheming to keep the proceeds of a $2 million life insurance policy.

  • April 17, 2023

    IRS Criminal Unit To Open Cyber Data Center, Chief Says

    The IRS Criminal Investigation division is close to unveiling a centralized hub that will provide additional resources to bolster the agency's efforts to crack down on highly technical and cryptocurrency-related crimes, division chief Jim Lee said Monday.

  • April 17, 2023

    Biz Groups Urge Justices To Review NC Sales Tax Case

    The North Carolina Supreme Court's decision to allow the state to impose sales tax on a Wisconsin-based company threatens to upend established tax law and disregards established U.S. Supreme Court precedent, business groups said Monday in urging the U.S. justices to review the case.

Expert Analysis

  • 10 Things to Know About US Competent Authority Assistance

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    Taxpayers should consider seeking U.S. competent authority assistance to help eliminate double taxation from a transfer pricing adjustment, especially now that the competent authorities are resolving cases virtually and more quickly, say attorneys at Thompson & Knight.

  • Lessons From Tax Court's Nixing Of Investor's Energy Credits

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    The U.S. Tax Court's recent ruling in Olsen v. Commissioner, the first of 200 cases involving individual taxpayers who invested in a tax shelter involving solar equipment, is a case study in how not to structure an energy tax credit investment, says David Burton at Norton Rose.

  • Partial Repeal Could Resolve Biden's SALT Cap Dilemma

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    Lawmakers' calls to repeal the cap on federal deductions for state and local taxes are controversial because doing so could cost over $600 billion, but a partial repeal could be accomplished on a revenue-neutral basis, providing relief to some, if not most, affected taxpayers, says Joseph Mandarino at Smith Gambrell.

  • Alcohol Taxation Provides Good Model For Cannabis Taxes

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    Although the alcohol taxation system isn't perfect, it could serve as a useful template for cannabis taxation with a three-tier licensing scheme and tax rates based on potency, says Louis Terminello at Greenspoon Marder.

  • US Advance Pricing Agreements, Amid COVID And Before

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    Steptoe & Johnson's Matthew Frank, former director of the U.S. Advance Pricing Agreement Program, shares insights from an Internal Revenue Service report revealing an uptick in APA completions amid the pandemic, discusses trends over the program's 30-year history, and suggests ways taxpayers and the IRS could bolster program participation.

  • High Court Hotels.com Case Could Alter Appellate Strategy

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    If the U.S. Supreme Court upholds the Fifth Circuit in the upcoming San Antonio v. Hotels.com case, ruling that district courts may not amend taxable appellate costs, it could reprioritize the incentive structure and decision-making calculus of appeals, says Patrick Hammon at McManis Faulkner.

  • 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.

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