Federal
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March 14, 2024
Absent Returns Justify Rejecting Offers, Tax Court Rules
The Internal Revenue Service properly sustained a collection action against a Maryland man with a record of failing to file his income tax returns, the U.S. Tax Court ruled Thursday.
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March 14, 2024
8th Circ. Questions IRS Ax Of Engineering Co.'s R&D Credit
Eighth Circuit judges probed claims by the IRS that a Minnesota engineering company didn't qualify for $276,000 in research and development tax credits, asking during oral arguments whether the agency may have overlooked the inherently specialized nature of the company's engineering work.
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March 14, 2024
Tax Court Judge John O. Colvin, Ex-Chief, Dead At 77
John O. Colvin, a senior judge of the U.S. Tax Court, has died, the court announced in a news release Thursday.
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March 14, 2024
IRS' Signals On Economic Substance Doctrine Draw Scrutiny
The Internal Revenue Service's recent legal success asserting a doctrine to invalidate transactions in tax law enforcement matters may embolden the government to broaden that argument's reach, and lawyers are concerned it doesn't properly apply to transfer pricing matters.
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March 13, 2024
Siemens Asks Tax Court To Toss $1.2B IRS Bill
A U.S. subsidiary of German technology company Siemens is pushing the U.S. Tax Court to throw out $1.16 billion in tax deficiencies and penalties the IRS has imposed, saying the agency relied on invalid rules in denying a deduction.
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March 13, 2024
Tax Court Calls CPA's Deduction Testimony 'Contradictory'
A California certified public accountant cannot deduct nearly $600,000 in assorted expenses — including more than $437,000 in net operating losses — after providing "contradictory" testimony and failing to present credible evidence, the U.S. Tax Court ruled Wednesday.
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March 13, 2024
Actuary Board Looks To End In-Person Learning Requirement
The Joint Board for the Enrollment of Actuaries has proposed eliminating a requirement that continuing education programs be attended in person, the Internal Revenue Service said Wednesday.
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March 13, 2024
Deputy To Take Over As IRS Criminal Investigation Chief
The deputy chief of the Internal Revenue Service's Criminal Investigation division will take the helm of the division when its current chief steps down April 6, the agency said Wednesday.
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March 13, 2024
2nd Circ. Affirms Barring Of Man's Appeal In Small Tax Case
The Second Circuit rejected a taxpayer's attempt to resurrect his dispute over a tax deficiency Wednesday, affirming that a statute prohibits appeals of U.S. Tax Court decisions in certain cases involving low dollar amounts.
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March 13, 2024
6th Circ. Told Woman Helped Life Partner Avoid $3M In Taxes
The federal government justifiably sold off the property of a woman who paid for it with money from her dead long-term life partner, the U.S. government told the Sixth Circuit on Wednesday, saying the purchase helped her partner skirt more than $3 million in tax liabilities.
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March 13, 2024
JCT Indicates Pillar 1 Is Bad Deal For US, GOP Lawmakers Say
An analysis of the Organization for Economic Cooperation and Development's Pillar One taxing rights overhaul by congressional scorekeepers makes clear the plan should not receive U.S. support because it would disadvantage U.S. multinationals and federal tax revenue, Republican leaders of Congress' taxwriting committees said Wednesday.
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March 13, 2024
Longtime Stradley Ronon Tax Partner Joins Grant Thornton
Following more than a quarter-century practicing law with Stradley Ronon Stevens & Young LLP, longtime tax attorney Chris Scarpa decided to change career paths, joining accounting firm Grant Thornton LLP.
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March 13, 2024
Ex-Super Bowl Champ Owes $15M Tax After Default, US Says
A California federal court should issue a default judgment for $15.5 million in federal income taxes against four-time Super Bowl champion Bill Romanowski and his wife, the U.S. government argued, saying the couple has failed to participate in a collection case against them.
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March 13, 2024
IRS Art Appraisal Panel Schedules April Meeting
The Internal Revenue Service committee that appraises art for tax purposes will hold its next meeting April 17, the agency said Wednesday.
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March 12, 2024
IRS Mulling Partnership Foreign Currency Rules, Official Says
The Internal Revenue Service will likely propose rules that would provide additional guidance to partnerships for determining taxable income or loss with respect to certain affiliates that conduct business in a foreign currency, an agency official said Tuesday.
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March 12, 2024
NC Software Execs Convicted Of Payroll Tax Crimes
Two former software executives in North Carolina were convicted Tuesday of failing to pay hundreds of thousands of dollars in employment taxes, but were absolved of charges that they lied on their individual tax returns, bringing to a close their five-day trial in Charlotte's federal courthouse.
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March 12, 2024
IRS Fully Opens Direct E-File Pilot Program In 12 States
The Internal Revenue Service's free electronic tax-return filing pilot program is now open to all 19 million eligible taxpayers in the 12 states where people can participate, agency Commissioner Daniel Werfel told reporters Tuesday.
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March 12, 2024
Calif. Man Agrees To Pay Nearly $500K In FBAR Penalties
A California man agreed to pay almost $500,000 in penalties, late fees and interest for failing to report his bank accounts in the Bahamas on his tax forms, according to a stipulated order entered by a California federal court.
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March 12, 2024
Wis. Firm Must Comply With IRS Search, Tax Court Says
A Wisconsin engineering firm must prove it is eligible for $240,000 in research tax credits by accommodating a broadened discovery initiated by the Internal Revenue Service, not just a sampling of the firm's data, the U.S. Tax Court ruled Tuesday.
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March 12, 2024
GOP's Crapo Wants Quick Resolution Of Tax Relief Package
The Senate Finance Committee's top Republican tax writer said Tuesday that he wants to quickly resolve sticking points in pending bipartisan tax legislation that contains key incentives for families and businesses in order to advance a bill that would boost U.S. manufacturing.
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March 12, 2024
Businessman Hid $20M In Swiss Accounts, US Says
A Brazilian-American businessman hid $20 million from the Internal Revenue Service over 35 years using accounts at Swiss banks including UBS and Credit Suisse, the U.S. government said in a criminal complaint that accuses him of conspiring to defraud the U.S. and lying to authorities.
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March 12, 2024
US, Turkey Extend Digital Services Tax Deal
Turkey will continue to apply its digital services tax as negotiations over the Pillar One international profit reallocation agreement continue, the country said Tuesday in a joint statement with the U.S. government
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March 11, 2024
'I Made A Huge Mistake,' Software Exec Says In Tax Fraud Trial
Two former software executives in North Carolina took the stand Monday in the government's tax fraud trial against them, where they portrayed a company in extreme distress as hundreds of thousands of dollars in employment taxes went unpaid and their personal lives crumbled.
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March 11, 2024
FedEx Says Gov't Can't Redo $85M Foreign Tax Credit Case
The U.S. government is trying to relitigate a Tennessee federal court's decision that sided with FedEx in a foreign tax credit dispute, the company said in asking the court to rule that it's entitled to a refund of nearly $85 million.
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March 11, 2024
Electronics Co. Disputes $187M Income Tax Bill From IRS
The Internal Revenue Service erroneously increased the income tax liability of an audio electronics company by $187 million, the business argued in a U.S. Tax Court petition.
Expert Analysis
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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.
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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.
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IRS' Tax Gap Statistics Don't Paint A Full Compliance Picture
The Internal Revenue Service's recent report indicating a widening tax gap sheds important light on tax compliance, underlines key pressure points and provides insights into how tax administration could be improved; but tax gap estimates also have their limits, says Joyce Beebe at Rice University.
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Labor Rules Will Unlock IRA Tax Credits' Full Value
Companies that make sure to follow the Inflation Reduction Act's unique labor rules will be in the best position to unlock the law's tremendous tax incentives aimed at promoting renewable energy, lowering greenhouse gas emissions and encouraging carbon sequestration, say Nicole Elliott and Timothy Taylor at Holland & Knight.
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Making The Most Of New Tax Credits For EV Charging Stations
The Inflation Reduction Act recently extended, expanded and renewed the tax credits available for electric vehicle charging station projects — but developers must navigate new challenges, including geographic and prevailing wage requirements, to take full advantage of the updated credits, says James English at Clark Hill.
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Key Income Tax Issues Triggered By Remote Employees
A host of fact-specific tax determinations arise in connection with remote work arrangements, from defining working-condition fringe benefit exclusions to nexus-dependent state withholding obligations, complicating compliance for corporate tax counsel and human resources professionals, say Thomas Cryan and Spencer Walters at Ivins Phillips.
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An Evaluation Of New Solar Energy Opportunities For REITs
The Inflation Reduction Act's changes to investment tax credit rules will make it possible for real estate investment trusts to own solar facilities and also benefit economically from tax credits, but certain limitations remain, say attorneys at Mayer Brown.
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Cases Show Real-World Laws Likely Apply In Metaverse
Although much has been written about the so-called unprecedented legal issues raised by the metaverse, recent federal cases demonstrate that companies can expect metaverse activities to be policed and enforced much like they would be in the physical world, say attorneys at Crowell & Moring.
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Justices Poised To Reject Narrowing Unclaimed Property Law
After U.S. Supreme Court oral arguments in the so-called MoneyGram case — a dispute between Delaware and several other states over which has the right to about $300 million in unclaimed property — the court seems ready to rule against Delaware, but nuances of the court's reasoning will have a broader sweep, say attorneys at Alston & Bird.
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How High Court Could Change FBAR Penalty Landscape
On Wednesday, the U.S. Supreme Court will hear Bittner v. U.S., a case that will affect many people penalized for failing to file a Report of Foreign Bank and Financial Accounts, and there are important procedural implications should the government's position be reversed, say Reuben Muller and Andreas Apostolides at Cole Schotz.
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IRS Memo May Change IP Royalty Tax Prepayment Planning
A recent Internal Revenue Service advice memorandum finding a taxpayer was not permitted to prepay tax on contingent royalties after contributing intellectual property offshore is a noteworthy departure from earlier guidance that highlights potential differences between actual and deemed licenses, says William Skinner at Fenwick.
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What IRS Funding Increase Means For Taxpayers
The Internal Revenue Service will first use the influx of funding from the Inflation Reduction Act to address customer support and personnel issues, but with over half the money allocated to enforcement, corporations and high-net-worth individuals will face increased scrutiny, say Patrick McCann Jr. and Jasen Hanson at Chamberlain Hrdlicka.
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6 Tax Considerations For Life Sciences Collaboration Deals
Given recent IRS guidance and changes to certain tax rates and deductions, biotech and life sciences companies entering into collaboration agreements should assess several unique taxation issues affecting matters ranging from research and development expenditures to profit-sharing terms, say attorneys at Orrick and Andersen Tax.