Federal

  • February 13, 2024

    Lawmakers Call On IRS For Lead Pipe Replacement Clarity

    Fifteen bipartisan members of Congress called on the Internal Revenue Service to clarify the tax treatment of lead pipe replacement grants in a letter released Tuesday.

  • February 12, 2024

    IRS Data Safeguards Still Lacking, GOP Leader Says

    A watchdog report shows the Internal Revenue Service doesn't appear to be doing much to better protect sensitive taxpayer data even after a contractor was found to have stolen thousands of tax returns, including former President Donald Trump's, the top House Republican tax writer said Monday.

  • February 12, 2024

    Ga. Attys Claim Fund Managers Organized Illegal Tax Shelter

    Managers of a fund profited by selling units in a "grossly inflated" tax shelter and then hid a federal criminal investigation into the arrangement from investors, partners in an Athens, Georgia, law firm said in a suit recently transferred to federal court.

  • February 12, 2024

    IRS To Float Requirements For Tax-Free Spinoffs, Official Says

    The Internal Revenue Service is planning to propose guidance that would replace regulations floated in 2016 to clarify when corporations can undertake spinoffs and other tax-free distributions without unlawfully distributing earnings and profits, an agency official said Monday.

  • February 12, 2024

    Cybergang Member Gets 16 Years For $45M Tax Scheme

    A Florida federal judge delivered the steepest sentence yet for a member of a cybergang that hacked the computers of accounting firms and stole thousands of client identities to siphon $45 million in tax refunds, ordering him to serve 16 years in prison.

  • February 12, 2024

    Head Of IRS Criminal Investigation Division To Retire

    The chief of the Internal Revenue Service's Criminal Investigation division will step down from his position April 6, the agency announced Monday.

  • February 12, 2024

    IRS Must Increase Closures Of High-Dollar Audits, GAO Says

    The Internal Revenue Service must take steps to close a higher percentage of audits for high-income returns, the U.S. Government Accountability Office said in a report published Monday.

  • February 12, 2024

    IRS Updates Employer Health Penalty Index For 2025

    The Internal Revenue Service published guidance Monday updating indexing adjustment amounts for calculating employer health coverage penalties in 2025.

  • February 09, 2024

    Pillar 2 Shouldn't Hit 'Double Dipping' Loss Rules, CPAs Say

    The Pillar Two international minimum tax agreement should not impact U.S. rules that are designed to prevent companies from "double dipping" with a single economic loss, the American Institute of Certified Public Accountants recommended in a letter made public Friday.

  • February 09, 2024

    Senate GOP Push For Tax Bill Changes Could Slow Progress

    Senate Republicans' desire to add their own priorities to the tax bill recently passed by the House, along with a jam-packed Senate agenda, could delay the proposal in its journey to President Joe Biden's desk.

  • February 09, 2024

    6th Circ. Backs Fine Against Doctor For Willful FBAR Violation

    A Michigan doctor clearly met the standard for a willful failure to file reports of foreign bank accounts, the Sixth Circuit said, confirming a lower court decision resulting in a $930,000 penalty against him.

  • February 09, 2024

    The Tax Angle: SALT, Housing Credits, Opportunity Zones

    House Democrats held their two-day legislative issues conference this week, formulating plans to win majority control of the chamber in November so they can shape the policy agenda next year when parts of the GOP's 2017 tax law expire. Here's a peek into a reporter's notebook at a few of the developing tax stories that Democrats discussed at their meeting.

  • February 09, 2024

    Jordan Calls For Investigation Into DOJ's Deal With IRS Leaker

    House Judiciary Committee Chairman Jim Jordan is investigating whether federal prosecutors were politically motivated to allow the former IRS contractor who leaked former President Donald Trump's tax returns to plead guilty to a single count of illegal disclosure, calling the arrangement "a sweetheart deal."

  • February 09, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, which included a ruling regarding the treatment of unused housing credit amounts allocated to a state.

  • February 09, 2024

    Taxation With Representation: Sullivan & Cromwell, Kirkland

    In this week's Taxation With Representation, California Resources Corp. acquires Aera Energy, ZeroFox Holdings goes private, and Acerinox purchases Haynes International.

  • February 08, 2024

    NJ, Ft. Lee Mayor Fail To Merge NY Congestion Pricing Suits

    A federal judge on Thursday rejected a bid to consolidate two lawsuits — one filed by New Jersey, the other by the mayor of a Garden State town — seeking to halt New York City's congestion pricing toll plan, ruling that the suits make similar claims but seek different remedies.

  • February 08, 2024

    3M Tells 8th Circ. IRS Used Invalid Regs To Allocate Income

    Multinational conglomerate 3M urged the Eighth Circuit to reverse a U.S. Tax Court decision upholding regulations that the IRS had used to disregard Brazilian legal restrictions when allocating the company's income, contending that the rules contravene an underlying transfer pricing statute.

  • February 08, 2024

    First Returns Submitted Using IRS Free E-File Pilot Program

    Early testers of the Internal Revenue Service's free electronic tax return pilot program successfully filed the first returns using the system, an agency official said Thursday.

  • February 08, 2024

    Tax Court Frees Woman From Ex's Omitted Income

    Meeting the criteria for innocent spouse relief, a Wisconsin woman is not liable for a portion of a tax liability from the year her divorce was finalized, the U.S. Tax Court ruled Thursday.

  • February 08, 2024

    Tax Court Rejects Guardian's Claims For Tweaked Treatment

    An Illinois woman is ineligible for head-of-household status as well as the earned income tax credit because her dependent spent most of the year living elsewhere, the U.S. Tax Court ruled Thursday.

  • February 08, 2024

    US Grantor Trusts Need Int'l Reporting Clarity, Treasury Told

    The U.S. Treasury Department should clarify that domestic grantor trusts aren't required to file international information returns, the American Institute of Certified Public Accountants said in a letter made public Thursday, claiming that current uncertainty has led to redundant reporting.

  • February 08, 2024

    DC Circ. Skeptical Of 5-Hour Energy Partner's Tax Challenge

    D.C. Circuit judges seemed skeptical of a Canadian citizen's argument that $6.5 million in gains she received from selling a share of a U.S. partnership that sold 5-Hour Energy drinks shouldn't be federally taxed, grappling to understand her reasoning during oral arguments Thursday.

  • February 08, 2024

    IRS Mostly Compliant With Purchase Card Rules, TIGTA Says

    The Internal Revenue Service is mostly compliant with regulations on purchase card spending, the Treasury Inspector General for Tax Administration said in a report published Thursday.

  • February 08, 2024

    Idaho Woman Contests Lien Over Foreign Tax Form

    The Internal Revenue Service cannot unilaterally impose penalties for failing to timely file a tax form for U.S. citizens involved with certain foreign corporations, an Idaho woman told a federal court, asking it to declare invalid a $350,000 lien placed on her family home.

  • February 08, 2024

    IRS Electronic Tax Committee Schedules Meeting For March

    The Internal Revenue Service's Electronic Tax Administration Advisory Committee will hold its next meeting March 20, the IRS said Thursday.

Expert Analysis

  • Maximizing Law Firm Profitability In Uncertain Times

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    As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • How Gov't Agencies Will Fare In The Event Of A Shutdown

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    With a federal shutdown potentially set to begin at the end of this month, it may be useful to consider the approximate timelines that agencies such as the Federal Trade Commission and IRS have announced for curtailing operations, and potential strategies for mitigating challenges that may arise while agency functions are limited, say attorneys at Cleary.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

  • Kentucky Tax Talk: Taking Up The Dormant Commerce Clause

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    Attorneys at Frost Brown examine whether the U.S. Supreme Court is likely to review Foresight Coal Sales v. Kent Chandler to consider whether a Kentucky utility rate law discriminates against interstate commerce, and how the decision may affect dormant commerce clause jurisprudence.

  • Prevailing Wage Rules Complicate Inflation Act Tax Incentives

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    Nicole Elliott and Timothy Taylor at Holland & Knight discuss the intersection between tax and labor newly created by the Inflation Reduction Act, and focus on aspects of recent U.S. Department of Labor and U.S. Department of the Treasury rules that may catch tax-incentive seekers off guard.

  • Payroll Tax Evasion Notice Suggests FinCEN's New Focus

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    The Financial Crimes Enforcement Network’s recent notice advising U.S. financial institutions to report payroll tax evasion and workers' compensation schemes in the construction industry suggests a growing interest in tax enforcement and IRS collaboration, as well as increased scrutiny in the construction sector, say Andrew Weiner and Jay Nanavati at Kostelanetz.

  • How Taxpayers Can Prep As Justices Weigh Repatriation Tax

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    The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.

  • IRS Foreign Tax Credit Pause Is Welcome Course Correction

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    A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.

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