Federal

  • May 03, 2024

    US Resisting More Scoping On Amount B, Economist Says

    In negotiations over the streamlined transfer pricing approach for baseline marketing and distribution functions known as Amount B, the U.S. has resisted calls for additional scoping criteria that would exclude more companies from the safe harbor, a former U.S. Treasury economist said Friday.

  • May 03, 2024

    Sidley Liable For Ex-Partner's Tax Sheltering, Ga. Judge Told

    Counsel for a family of business magnates who say they were duped into an illegal tax shelter scheme over 25 years ago by Sidley Austin urged a Georgia federal judge Friday to let their suit against the firm continue, arguing its defense that the suit is time-barred should be done away with.

  • May 03, 2024

    Dems, GOP Favor Extending Pass-Through Break, Staff Says

    Democrats and Republicans are both interested in extending the 2017 tax law's pass-through deduction, which expires at the end of 2025, though Democrats would like to limit its availability to upper-income earners, a pair of congressional staffers said Friday.

  • May 03, 2024

    No Climate Law Corrections Bill Expected, Senate Staffer Says

    Congress is unlikely to pass a so-called technical corrections bill that would change noncontroversial and revenue-neutral tax provisions in the 2022 climate law known as the Inflation Reduction Act, a Senate Finance Committee Democratic staffer said Friday.

  • May 03, 2024

    Feds Can Introduce Prior Guilty Plea In Tax Fraud Case

    Federal prosecutors can introduce a man's prior admissions of tax evasion in a trial over separate tax crime charges because it could show his willingness and knowledge to commit the crime, a Pennsylvania federal judge ruled.

  • May 03, 2024

    Foreign Trust Reporting Rules Coming Soon, IRS Official Says

    The Internal Revenue Service is about to issue proposed regulations that will provide guidance on the reporting obligations for individuals who have transactions with foreign trusts, an agency official said Friday.

  • May 03, 2024

    IRS Details Penalty-Free Retirement Withdrawals For Disasters

    The Internal Revenue Service detailed procedures Friday for taking penalty-free withdrawals of up to $22,000 from Internal Revenue Code Section 401(k) retirement accounts and other retirement plans under the permanent disaster tax relief granted in the Secure 2.0 Act.

  • May 03, 2024

    HMRC Director Rejoins KPMG To Boost Tax Dispute Offering

    A former deputy director at HM Revenue & Customs has returned to KPMG as director of KPMG Law's tax disputes teams, the firm has announced.

  • May 03, 2024

    IRS Expects Updates To Hydrogen Credit Emissions Model

    The Internal Revenue Service expects the U.S. Department of Energy to update a model used to determine eligibility for the new clean hydrogen production tax credit under recently proposed rules, an IRS attorney said Friday.

  • May 03, 2024

    IRS Program In Miss. Delta Struggling, TIGTA Says

    Attempts by the Internal Revenue Service to expand operations to economically distressed areas in the Mississippi Delta have fallen well short of a goal of hiring 160 employees by the end of fiscal 2024, the Treasury Inspector General for Tax Administration said in a report.

  • May 03, 2024

    Medical Testing Co. Not In Health Field For Taxes, IRS Says

    A company that fills medical testing orders for its customers is nonetheless not a business involved in performing services in the health field for certain tax purposes, the Internal Revenue Service said in a private letter ruling released Friday.

  • May 03, 2024

    IRS May Again Extend Corp. AMT Penalty Relief, Official Says

    The Internal Revenue Service could again extend the penalty waiver for companies that fail to make estimated quarterly payments of the corporate alternative minimum tax, an agency official said Friday.

  • May 03, 2024

    US Trade Position Seen Contradicting Stance In Pillar 1 Talks

    The U.S. trade representative's withdrawal of support for digital trade proposals has caused tax policy observers to worry that the U.S. position on trade is undermining that of U.S. Treasury Department officials negotiating a taxing rights overhaul at the OECD known as Pillar One.

  • May 03, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, which included updated rates for foreign insurance company equations and an extension on excise tax relief for minimum plan distributions.

  • May 03, 2024

    Taxation With Representation: Skadden, Wachtell, Davis Polk

    In this week's Taxation With Representation, L'Occitane International said its executive director and chair is leading an offer to buy the company's shares he doesn't already own, UMB Financial agreed to purchase Heartland Financial USA, Medline said it agreed to acquire Ecolab's global surgical solutions business and The Mosaic Co. said it agreed to sell its stake in a phosphate production joint venture.

  • May 03, 2024

    IRS Can Assess Foreign Info Disclosure Penalty, DC Circ. Says

    The D.C. Circuit on Friday overturned a major U.S. Tax Court ruling that had struck down the Internal Revenue Service's authority to assess and administratively collect penalties from taxpayers for failing to file an information return on their interests in a foreign corporation.

  • May 03, 2024

    Final EV Tax Credit Regs Add New Battery Tracing Test

    The U.S. Treasury Department unveiled final regulations Friday for the up to $7,500 electric vehicle tax credit that include a more detailed process for automakers to trace the battery supply chain to qualify for the credit's domestic content requirements.

  • May 02, 2024

    Hahn Air To Pay Feds $26.8M To End FCA Travel Fees Suit

    Hahn Air Lines agreed to pay $26.8 million to resolve a whistleblower's allegations that the German airline-ticketing company violated the False Claims Act by intentionally failing to remit to the U.S. government certain travel fees the company collected from U.S. commercial airline passengers.

  • May 02, 2024

    Claimed Panama Papers Leaker Fights To Hide ID In €5M Suit

    A person claiming to be the Panama Papers leaker told a federal court they would fear for their life if the court made them disclose their identity in a €5 million ($6.3 million) suit against Germany, protesting a magistrate judge's suggestion that the suit be tossed because the person wouldn't identify themselves.

  • May 02, 2024

    Texas Tax Preparers Cop To $3.7M Tax Fraud Scheme

    The owner of a Texas tax preparation company and her two sisters who worked as employees all pled guilty Thursday to preparing nearly $3.7 million worth of false returns riddled with fraudulent credits, according to the U.S. Department of Justice.

  • May 02, 2024

    IRS To Boost Audit Rates By 50% On Wealthy, Werfel Says

    The Internal Revenue Service plans to nearly triple audit rates on corporations with assets over $250 million and increase audit rates by more than 50% on wealthy taxpayers with more than $10 million in total positive income by 2026, Commissioner Daniel Werfel said Thursday.

  • May 02, 2024

    Latest Stock Buyback Tax Rules May Still Have Wide Reach

    The U.S. Treasury Department recently floated regulations that narrow an earlier proposal aimed at preventing foreign-parented corporations from circumventing a new excise tax on stock buybacks, but the regulations still characterize avoidance in ways that could include routine intercompany transactions.

  • May 02, 2024

    Wyden Pushes Intuit To Help Users Get Refunds After Error

    The Senate's top tax writer told Intuit's CEO that the company needs to help taxpayers in Oregon, the senator's home state, receive the full refunds they're entitled to after a reported error in its TurboTax product caused some Oregonians to overpay their state taxes.

  • May 02, 2024

    Nixon Peabody Adds Two Community Finance Attys In DC

    Nixon Peabody LLP has hired two partners, who will focus their practices on helping nonprofits and other clients understand and obtain tax credits for a range of community development projects, to its community development finance practice in Washington, D.C., the firm announced Thursday.

  • May 02, 2024

    Feds Want Prison For Ex-Public Defender For Tax Fraud

    A former chief public defender in Minneapolis who in seeking leniency said he resigned in disgrace amid accusations that he failed to pay taxes for years on his private law firm should nonetheless spend eight months in prison after pleading guilty, prosecutors told a Minnesota federal court.

Expert Analysis

  • 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.

  • IRS' Cost Method Update Is Favorable For RE Developers

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    The Internal Revenue Service's recent update to its alternative cost method will allow real estate developers to accelerate their cost recovery of improvements in certain circumstances and make it easier for practitioners to satisfy the method's tax compliance requirements, says Benjamin Oklan at Weil.

  • The Key Issues Keeping Transfer Pricing A Top Tax Concern

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    Several challenges preventing a global economic reemergence from the pandemic era are making practitioners reevaluate commonly used transfer pricing models, and embrace new technologies and ways of doing business, say Farnaz Amini and Sophia Castro Jurado at Marcum.

  • Cannabis Cos. Must Heed Growing Federal Investigatory Risks

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    As state-regulated cannabis markets expand rapidly, so too does government oversight, and industry participants must plan ahead to avoid potential liabilities related to workplace health and safety requirements, tax audits, securities regulations and foreign bribery laws, say Alicia Corona and Amy Rubenstein at Dentons.

  • 5 Ways Taxpayers Can Spot Employee Retention Credit Scams

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    On Monday, the Internal Revenue Service added the employee retention credit to its list of prevalent tax scams because of ERC promoters seeking to take advantage of employers, but taxpayers who may qualify for the credit can protect themselves by recognizing certain red flags, say attorneys at Potomac Law and Stout Risius.

  • Could The Supreme Court Legalize Marijuana Federally?

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    Amid slow legislative and executive movement on cannabis reform, it’s worth examining whether the U.S. Supreme Court could provide a pathway to federal cannabis legalization — a decision that would surely require strange bedfellows given the court’s current ideological makeup, say Whitt Steineker and Mason Kruse at Bradley Arant.

  • Tax Pitfalls To Avoid In Employment Litigation Settlements

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    Downsizing companies should keep certain questions in mind when settling claims with departing employees to ensure they understand associated tax withholding and reporting obligations, and avoid costly interest and penalties down the road, says Matthew Meltzer at Flaster Greenberg.

  • Key Considerations For Taxpayers Deducting Crypto Losses

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    While a recent Internal Revenue Service memorandum is helpful in providing insight into how the agency is considering guidance related to cryptocurrency, questions remain with respect to whether a taxpayer can claim a tax deduction for cryptocurrency losses, say attorneys at McDermott.

  • Justices' MoneyGram Opinion Could Spur State Legislation

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    The U.S. Supreme Court’s recent decision that federal law governs the escheatment of over $250 million in unclaimed MoneyGram checks provides clarity for some issuers, but aspects of related common law remain uncertain and states may take the opportunity to pass multistate escheatment legislation, say attorneys at Alston & Bird.

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