Federal
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April 18, 2024
IRS Seeks Advisory Council Noms, Creates Fairness Panel
The Internal Revenue Service is seeking nominations for the council that advises the agency's commissioner, the IRS said Thursday, while the council is also launching a new subcommittee on fairness in tax administration.
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April 18, 2024
Transfer Pricing And Dancing: Recalling KPMG's Sean Foley
Sean Foley, who died suddenly in September, was a devoted husband, father, brother and friend and a brilliant colleague. He was one of the world's top experts in an area of international tax known as transfer pricing, where he became the global leader of KPMG's practice.
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April 18, 2024
IRS Adds 2nd Public Hearing Day On Donor-Advised Regs
The Internal Revenue Service has added a second, telephone-only public hearing in May on proposed regulations on excise taxes on certain taxable distributions made from donor-advised funds, the agency announced Thursday.
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April 17, 2024
'I Am Mad': Client Regrets Trusting Atty Accused Of Tax Fraud
Emotions ran high Wednesday in a North Carolina federal courtroom as former clients unwittingly roped into an alleged tax fraud scheme took the stand, one of whom was openly exasperated at learning he'd been misled by the two attorneys and an insurance agent who are on trial.
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April 17, 2024
Damages Still Possible In Lease Tax Reimbursement Row
A Court of Federal Claims judge has ruled that the General Services Administration could unilaterally adjust the real estate tax reimbursement methodology under a lease for the Defense Health Agency's headquarters building, but the building owner may still be owed damages.
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April 17, 2024
EV Tax Credit Restrictions, Trade Bills Advance In House
The House Ways and Means Committee advanced several trade bills Wednesday that would impose more restrictions for new electric vehicles to qualify for a federal tax credit, assert congressional authority in agreements with foreign governments, and renew the country's largest and oldest trade preferences program.
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April 17, 2024
$22B In Earned Income Tax Credits Wrongly Handed Out
The U.S. Treasury Department improperly allowed an estimated $22 billion in earned income tax credits during fiscal year 2023, according to a report made public Wednesday by the Government Accountability Office.
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April 17, 2024
EmblemHealth Pushes IRS To Hand Over $6.7M Tax Refund
Not-for-profit insurance company EmblemHealth asked a New York federal court Wednesday to grant it a nearly $6.7 million tax refund, saying the Internal Revenue Service left a voicemail accepting its refund claim in February but still hasn't delivered the money.
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April 17, 2024
Utility Energy Subsidies Not Eligible For Credits, IRS Says
A taxpayer may not claim certain clean energy credits for the amount of a subsidy provided by a public utility for the purchase or installation of energy conservation measures, the Internal Revenue Service said Wednesday.
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April 17, 2024
Tax Court Rejects NJ Lawyer's Protest Of IRS Collection
The Internal Revenue Service didn't abuse its discretion when it denied a New Jersey lawyer's request for collection alternatives, the U.S. Tax Court ruled Wednesday.
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April 17, 2024
9th Circ. Tosses $3.9M Tax Foreclosure Appeal As Premature
The Ninth Circuit dismissed a man's challenge to a court order that he believed allowed the government to foreclose on his property to pay his son's tax liabilities of more than $3.9 million, saying Wednesday that the appeal was premature because the order wasn't final.
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April 17, 2024
Judge Delays Trial Over $20M Allegedly Hidden From IRS
A Florida federal judge agreed Wednesday to delay the trial of a Brazilian-American businessman accused of hiding $20 million from the Internal Revenue Service by using Swiss bank accounts, but told the defendant the new deadlines are firm.
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April 17, 2024
Loeb & Loeb Adds 2 Corporate Partners From Morrison Cohen
Loeb & Loeb LLP has announced the latest in a string of corporate hires from Morrison Cohen LLP's ranks, touting two new partners with domestic and international experience with strategic transactions.
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April 17, 2024
4th Circ. Affirms No Shield From IRS For Home In Bankruptcy
A North Carolina man who filed for bankruptcy protection and owes federal tax debt cannot shield the house he owns with his wife from the Internal Revenue Service, which is pursuing the asset as a creditor in the proceedings, the Fourth Circuit affirmed Wednesday.
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April 17, 2024
Financial Planner Gets Prison For Tax Shelter Fraud Scheme
A Cleveland financial planner who colluded with a Florida attorney to promote an illegal tax scheme using fake charitable donations to score deductions for his company's high-income clients was sentenced Tuesday to 20 months in prison for his part in the fraud.
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April 17, 2024
IRS Finds Success Against 'Ghost Employers,' TIGTA Says
The Internal Revenue Service has successfully prosecuted 33 cases against employers who issue W-2 forms to workers but fail to remit payroll taxes, the Treasury Inspector General for Tax Administration said Wednesday.
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April 16, 2024
Corp. Transparency Act A Valid Use Of Powers, 11th Circ. Told
The U.S. Department of Treasury told the Eleventh Circuit that a federal district court erred in finding the Corporate Transparency Act unconstitutional, saying the lower court misunderstood the law's scope and relation to efforts to curb financial crime.
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April 16, 2024
Nothing 'Sinister' About Attys, Broker's Tax Plan, NC Jury Told
Two St. Louis attorneys and a North Carolina insurance agent on Tuesday tried to poke holes in an undercover IRS agent's investigation of what the government has characterized as a criminal tax avoidance scheme, which defense counsel sought to paint for the jury as a legal interpretation of federal tax law.
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April 16, 2024
Biden Pushes For Permanent Premium Tax Credit Expansion
President Joe Biden said Tuesday that should he be reelected one of his first actions would be to seek to make permanent the expansions that were made to the health insurance premium tax credit to increase eligibility and lower premiums.
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April 16, 2024
Ex-Mich. Speaker, Wife Charged With Embezzlement
Former Michigan House Speaker Lee Chatfield was charged Tuesday with criminally misusing money from his nonprofit to pay for family trips and designer clothing while in office, as the state attorney general called on lawmakers to beef up Michigan's "worthless" campaign finance laws.
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April 16, 2024
Veteran's Signature On IRS Doc Not Forged, Tax Court Finds
U.S. Air Force veteran and his wife failed to convince the U.S. Tax Court on Tuesday that their signatures were forged on an agreement to pay federal income taxes while working in Australia for defense contractor Raytheon.
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April 16, 2024
GOP Senators Call IRS' E-File Program Too Costly
Senate Republicans continued to criticize the Internal Revenue Service's free tax filing pilot program during a Finance Committee hearing Tuesday, saying the program has not followed best practices and will be costly to implement long term.
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April 16, 2024
IRS Publishes 2024 Average Residence Purchase Price Data
The Internal Revenue Service published data Tuesday on the average purchase price for U.S. residences in different areas, which is used to determine whether bond interest can be excluded from gross income.
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April 16, 2024
IRS Extends Excise Tax Relief For Min. Plan Distribution
Plans that fail to make certain required minimum distributions in 2024 will not be assessed an excise tax under changes made to retirement plan legislation, the Internal Revenue Service said in guidance released Tuesday.
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April 16, 2024
3 Key Takeaways From The IRS' Latest Pricing Pact Snapshot
The IRS finalized a record number of advance pricing agreements in 2023, signaling the agency's increased effectiveness at completing accords at a time when its approach to transfer pricing litigation could fuel corporate taxpayers' urgency for seeking APAs. Here, Law360 breaks down three key takeaways from the agency’s latest APA report.
Expert Analysis
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Key Considerations For Seeking Relief From Double Taxation
Caroline Setliffe and E. Miller Williams at Eversheds Sutherland lay out the Organization for International Cooperation and Development’s mutual agreement procedure for settling double-taxation disputes, and discuss six factors U.S. taxpayers doing business in multiple countries should consider when determining the most advantageous form of relief.
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High Court Could Resolve Thorny Atty-Client Privilege Issue
The U.S. Supreme Court recently granted review in a federal grand jury proceeding that presents a rare opportunity to clarify — and possibly significantly expand — the scope of the attorney-client privilege for complex mixed-purpose communications with counsel, says David Greenwald at Jenner & Block.
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2 Tax Decisions Hold Key Transfer Pricing Takeaways
Richard Slowinski and Stefanie Kavanagh at Alston & Bird discuss two recent decisions in cases against the IRS — Eaton Corp. from the Sixth Circuit and Medtronic from the Tax Court — that may help clarify when the agency can cancel an advance pricing agreement, but leave unanswered questions about which pricing method applies to high-value intercompany licensing transactions.
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Patagonia's Succession Plan Is A Blueprint For Biz Owners
While not every business owner is interested in giving their company away to a charitable purpose like Patagonia's founder recently did, the outdoor apparel company's unique situation highlights the considerations that should go into any succession plan, says Abosede Odunsi at Freeborn & Peters.
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The CHIPS Act: Key Takeaways For Semiconductor Industry
The Biden administration’s recently signed CHIPS Act signals that the U.S. is making progress toward bolstering the domestic semiconductor industry, and manufacturers must prepare by understanding the requirements of the act and associated Department of Commerce guidance, say attorneys at Miller & Chevalier.
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Digital Taxation Is Necessary, But Tough To Manage
The U.S. government has started to tackle complex new tax laws as the digital economy continues to grow, but this demands guidelines that will facilitate the growth while protecting investors and the government's finances, say attorneys at Cadwalader.
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5 Considerations When Seeking Federal EV Funding
A recent White House fact sheet shows how federal efforts to support the full scope of the electric vehicle industry have moved the needle, but some details about how to use those funds are still being ironed out, and there are a few issues to watch, say attorneys at Morgan Lewis.
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Unpacking The Inflation Reduction Act's Energy Tax Credits
Provisions in the recently enacted Inflation Reduction Act that affect how taxpayers can monetize clean energy tax credits will change how clean energy projects are financed, but taxpayers that may not be allowed multiple credits need to determine which type of credit will be the most advantageous, say attorneys at BakerHostetler.
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How COVID Has Changed Project Development And Finance
Two and a half years into the pandemic, some COVID-19-specific provisions are now common in the project development and finance markets, while others are still undergoing negotiation, say Nate Galer and Katy McNeil at Mayer Brown.
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Unpacking The Shift In DOJ Corporate Enforcement Policy
Attorneys at Paul Hastings provide takeaways for companies seeking to mitigate increased enforcement risks from the U.S. Department of Justice's recent corporate prosecution policy changes, including greater focus on individuals, requirements for cooperation credits, evaluations of prior misconduct, expectations for compliance programs and factors for determining whether to impose a monitor.
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What AML Bill Could Mean For Firms, Funds And FinCEN
If passed, an amendment within Congress’ annual defense bill would expand the list of institutions subject to anti-money laundering regulations, from law firms to investment funds, creating potential rulemaking and enforcement challenges for the Financial Crimes Enforcement Network, say attorneys at Arnold & Porter.
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How Inflation Reduction Act Will Lift Offshore Wind Projects
The Inflation Reduction Act should promote the development of offshore wind energy in multiple ways — including by improving the planning and permitting process for transmission infrastructure, expanding potential lease areas and making beneficial changes to the tax credits available for renewable energy developers, say attorneys at Day Pitney.
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CORRECTED: New Tax Credits For Renewables Should Offer Investors Relief
The Inflation Reduction Act's changes to tax credits for renewable energy projects should finally liberate tax equity investors from the restraints of the complex and onerous federal anti-abuse regime, says Kay Hobart at Parker Poe. Correction: Because of an editing error, a previous version of this article incorrectly characterized tax enforcement regimes in North Carolina and other states. This error has been corrected.