Federal

  • March 28, 2024

    Canadian In Wash. Owes Over $1M FBAR Penalty, US Says

    A Canadian man living in Washington state owes more than $1 million in penalties for failing to report bank accounts he held in Montreal, the U.S. Department of Justice said in a complaint filed in an attempt to collect the money.

  • March 28, 2024

    Doctor Allowed To Withdraw NBA Fraud Plea, Gets June Trial

    A Manhattan federal judge will allow a Seattle-area doctor to pull back his guilty plea and go to trial in June, against prosecutors' objections, in a case alleging he assisted a cohort of retired NBA players to create fake invoices to submit to the league's healthcare plan.

  • March 28, 2024

    2nd Circ. Urged To Uphold Dual Citizen's FBAR Penalties

    A New York federal court correctly upheld tax penalties against a dual French citizen for hiding millions of dollars in six foreign accounts, the U.S. government told the Second Circuit, urging it to reject the woman's claims that American authorities violated the Hague Convention in pursuing her.

  • 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.

  • 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.

  • 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.

  • 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."

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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. 

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

Expert Analysis

  • Get Ready For IRS Criminal Crackdown On Crypto

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    Recent developments at the IRS, from a new operating plan to the announcement of a centralized data center, signal that the agency is ramping up criminal enforcement against those using digital assets to evade tax liabilities — and given its high conviction rate, companies and individuals must prioritize compliance, say attorneys at BakerHostetler.

  • NFT Tax Guidance Shows IRS Interest In Crypto Enforcement

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    The IRS' first ever guidance addressing the federal income tax treatment of NFTs indicates the agency could take a potentially aggressive stance in enforcing U.S. tax laws in the NFT and crypto spaces, which could have a significant impact on the self-directed IRA market, say attorneys at BakerHostetler.

  • Substantiation Is Key When Gifting Crypto To Charity

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    A recent Internal Revenue Service memorandum makes clear that the agency will require substantiation when gifting cryptocurrency to charity, even for relatively small amounts, so donors need to be aware of the important differences between crypto and typical cash donations, says Sheryl Morrison at Lathrop GPM.

  • Senate Credit Suisse Report Puts Attention On Banks, Trusts

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    The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.

  • Seeking IRS Accountability For Faulty Microcaptive Notice

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    Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.

  • Biden Admin. Proposals Both Encourage And Thwart EV Adoption

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    While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.

  • Heed PCAOB's Warning On Proof-Of-Reserves Reports

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    While directed at investors, the Public Company Accounting Oversight Board's recent advisory on proof-of-reserves reports is a timely and stark warning to crypto entities, as well as their customers and accounting firms, to tread carefully in their reliance on these reports as proof of financial stability, say Patrick Bryan and Deborah Meshulam at DLA Piper.

  • Cos. Should Heed IRS Warnings About Employee Tax Credit

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    The IRS has recently been cautioning employers claiming the pandemic-related employee retention credit to carefully review all the eligibility requirements and be wary of relying on third-party advisers regarding their qualification for the credit, say Eric Pearson and Timothy Voigtman at Foley & Lardner.

  • Renewable Energy M&A Is Still Strong, Despite Challenges

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    The recent history of renewable energy has included ongoing supply chain issues, legislative challenges and rising interest rates — but mergers and acquisitions in the sector are expected to remain robust this year, fueled by growing demand and Inflation Reduction Act incentives, say consultants at FTI Consulting.

  • Issues And Opportunities In Hydrogen Fuel Cell Development

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    A variety of tax incentives, funding opportunities and state programs have the potential to provide value across the hydrogen fuel cell business chain and alleviate existing hurdles, establishing a stronger business case for the continued development of hydrogen infrastructure, says Pamela Wu at Morgan Lewis.

  • IRS Green Energy Tax Credit Notice Provides Needed Clarity

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    Recent IRS guidance clarifying how the government will determine energy community locations for purposes of bonus clean energy tax credits should help resolve risk allocation disagreements among financing parties and parties to merger and acquisition transactions, say Casey August and Paul Gordon at Morgan Lewis.

  • SVB Collapse Highlights Ch. 11 Issues With Bank Holding Cos.

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    Amid recent banking turmoil, including Silicon Valley Bank's collapse and subsequent Chapter 11 filing of its parent company, distressed debt investors and board members must understand the distinct rules in bank holding company bankruptcies, including Bankruptcy Code provisions granting significant advantages to federal regulatory agencies like the FDIC, say attorneys at Skadden.

  • 9th Circ. Ruling Legitimizes Classwide Injury In Predominance

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    The Ninth Circuit's recent ruling that vacated class certification in Van v. LLR makes clear that the question of injury is highly relevant to the predominance analysis, and underscores the importance of making a persuasive argument that injury is individualized within the class, say attorneys at Skadden.

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