Federal

  • 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.

  • 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.

  • 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.

  • 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.

  • 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

  • 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.

  • 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.

  • 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.

  • March 11, 2024

    Biden Proposes Increased Wealth Taxes In $7.3T Budget Plan

    The White House unveiled its $7.3 trillion budget plan for fiscal 2025 on Monday, proposing higher taxes on wealthy corporations and individuals, expanding tax relief for Americans making under $400,000 per year and cutting the federal deficit by $3 trillion over the next decade.

  • March 11, 2024

    US Appeals Corporate Transparency Act Ruling To 11th Circ.

    The U.S. Department of the Treasury is moving quickly to appeal an Alabama federal judge's ruling that the Corporate Transparency Act is unconstitutional, filing a notice of appeal to the Eleventh Circuit on Monday.

  • March 11, 2024

    Tax Court Turns Down Late-Filed Spousal Petition

    The U.S. Tax Court ruled Monday that it lacked authority to hear a man's case for innocent spouse relief because he failed to file a petition within the 90-day deadline, holding that Congress clearly stated the deadline is jurisdictional.

  • March 11, 2024

    DC Circ. Mulls Tax-Exempt Status For Ayahuasca Church

    A D.C. Circuit panel on Monday pushed counsel for an Iowa church that uses the psychedelic substance ayahuasca in its ceremonies to explain why the Internal Revenue Service erred in denying it tax-exempt status.

  • March 11, 2024

    Chippewa Lawyer Owes Taxes Despite Treaty, 8th Circ. Told

    An attorney who belongs to the Minnesota Chippewa Tribe is not exempt from federal self-employment taxes under an 1837 treaty allowing Native Americans to earn money from hunting and gathering on their traditional lands, the U.S. government told the Eighth Circuit.

  • March 11, 2024

    CPAs Call For Broad Guidance On Excess Business Losses

    The Internal Revenue Service is past due for issuing guidance clarifying the limitation on excess business losses of noncorporate taxpayers, the American Institute of Certified Public Accountants said in a letter made public Monday.

  • March 11, 2024

    Tax Court Cuts Majority Of Ohio Tax Preparer's Biz Deductions

    An Ohio tax preparer will receive less than half of the $18,000 in deductions she claimed on her personal income taxes after failing to substantiate a portion of them as business expenses, the U.S. Tax Court ruled Monday.

  • March 11, 2024

    Fla. Tax Law Firm Fights Class Cert. In Wisconsin Fraud Row

    A Florida-based tax law firm has asked a Wisconsin federal judge to trim a proposed class action fraud suit launched by former customers claiming the firm solicited fees without performing work.

  • March 11, 2024

    Senate Finance Panel To Meet Tuesday On Manufacturing

    The Senate Finance Committee is scheduled to meet Tuesday to discuss congressional efforts for encouraging progress and investment in domestic manufacturing, according to a notice Monday.

  • March 08, 2024

    IRS Leaker Should Be Deposed Without All Docs, Judge Says

    Attorneys for a hedge fund executive should question the former IRS contractor who admitted to stealing the tax returns of him and others, even though the IRS hasn't finished producing evidence in the case seeking to hold the agency responsible for the leak, a Florida federal judge said Friday.

  • March 08, 2024

    Hunter Biden's Trump Conspiracy Theory Baseless, US Says

    Hunter Biden's claim that former President Donald Trump is improperly driving his criminal prosecution on nine counts of tax violations is nothing more than a baseless conspiracy theory, the U.S. government told a California federal court Friday, arguing against Biden's efforts to get the case tossed.

  • March 08, 2024

    ​​​​​​​Certain Tax Policy Can Improve Taxpayer Incentives, JCT Says

    Tax policy affecting marginal tax rates can enhance taxpayers' incentives to work, save and invest their earnings, the Joint Committee on Taxation said in a report published Friday.

  • March 08, 2024

    Taxation With Representation: Fried Frank, Latham

    In this week's Taxation with Representation, Viavi acquires Spirent, Cadence Design Systems purchases Beta Cae Systems International, and United Rentals buys Yak.

  • March 08, 2024

    Direct Pay Regs Would Lift Major Barrier For Energy Projects

    A U.S. Treasury Department proposal to give partnerships access to direct payments of tax credits for green energy projects would lift a significant barrier that has prevented tribes, municipalities, schools and nonprofits from capitalizing on joint ownership arrangements. 

  • March 08, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin, which included information on the tax treatment of certain lead pipe replacement projects.

  • March 07, 2024

    Don't Let Pillar 1 Die, Policy Experts Tell House Tax Panel

    Tax policy experts encouraged a U.S. House subcommittee Thursday to continue negotiations at the Organization for Economic Cooperation and Development over the taxing rights overhaul known as Pillar One and advocate for stronger double taxation relief and tougher language eliminating digital service taxes.

  • March 07, 2024

    Ex-Mass. Senator's Aide Gets Short Prison Term For Tax Fraud

    The former chief of staff to a Massachusetts state senator was sentenced Wednesday in federal court to 30 days in prison for failing to report income she was receiving from a business she owned and other jobs while collecting her state salary.

Expert Analysis

  • 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.

  • 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.

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