Federal

  • February 06, 2024

    Man Can Top $25 Monthly To Pay Off Debt, Tax Court Rules

    It is not unreasonable to assume an Arkansas man has the potential to pay more than $25 per month to settle more than $100,000 in unpaid income taxes, the U.S. Tax Court ruled Tuesday.

  • February 06, 2024

    IRS Sets Additional Depreciation Deduction For Some Vehicles

    Certain vehicles placed in service in 2024 will be eligible for an additional depreciation deduction up to $20,400 for the first tax year, the Internal Revenue Service said Tuesday.

  • February 06, 2024

    Estate Of Hilton Founder's Son Challenges $1.2B Tax Bill

    The Internal Revenue Service incorrectly rejected charitable contribution deductions for bequests by the son of the Hilton hotel chain founder, the son's estate told the U.S. Tax Court as it challenged the IRS' determination of a $1.16 billion estate tax deficiency.

  • February 06, 2024

    IRS Needs Clear Goals For Special Fund, GAO Finds

    The Internal Revenue Service should establish goals for its special compliance fund to optimize the fund's performance, the Government Accountability Office said in a report published Tuesday.

  • February 06, 2024

    IRS Funding Boost Could Raise $497B, Agency Says

    The Inflation Reduction Act's investment in the Internal Revenue Service could raise $497 billion over a decade, marking a significant increase over the agency's previous estimates of how much revenue the law's funding boost would generate, the agency said Tuesday.

  • February 06, 2024

    Thomas' Yacht Trips May Be Tax Scam, Senate Probe Finds

    Billionaire Republican donor Harlan Crow may have taken illegal tax deductions for a yacht he used to entertain family and friends, including Justice Clarence Thomas of the U.S. Supreme Court, the leader of the Senate Finance Committee said Tuesday, citing new evidence.

  • February 06, 2024

    Man Gets 41 Months, Will Pay $1.3M For Foreign Tax Evasion

    A Texas man who pled guilty in 2023 to evading more than $1 million in taxes on foreign income will serve 41 months in prison and pay fines and restitution of $1.3 million, a Texas federal court ruled.

  • February 06, 2024

    Bills Would Widen Limits On Donations Of Appreciated Assets

    A pair of bills introduced in Congress on Tuesday would extend tax break restrictions on donations of appreciated assets to certain organizations.

  • February 06, 2024

    IRS Opens Applications For Taxpayer Advocacy Panel

    The Internal Revenue Service is accepting applications for its Taxpayer Advocacy Panel, the agency said Tuesday.

  • February 05, 2024

    Jackson Hewitt To Settle No-Poach Suit Over Its Franchises

    Jackson Hewitt Inc. told a New Jersey federal court that it has reached a settlement in principle with its former workers who brought a proposed class action alleging that the company's franchisees entered into an anti-competitive no-poach agreement despite the firm's previous pledge to not have or enforce such arrangements.

  • February 05, 2024

    2nd Circ. Judges Skeptical Over IRS Penalties In $380M Case

    Second Circuit judges were skeptical of the IRS' claim during oral arguments Monday that it wasn't required to verify that a supervisor had signed off on penalties for six companies in a $380 million tax scheme case, saying a plain reading of the law seemed to demand it.

  • February 05, 2024

    Colo. Woman Accused Of Tax Crimes Must Keep GPS Monitor

    A woman indicted on charges of evading $2 million in taxes must continue wearing her ankle monitor as a condition of release, a Colorado federal court ruled, after the U.S. government noted that she has a permit to work in Dubai.

  • February 05, 2024

    Tax Court Sustains 12 IRS Determinations Against Couple

    An Arkansas couple are liable for more than $800,000 in unpaid taxes and penalties after they failed to make a convincing case against Internal Revenue Service determinations, the U.S. Tax Court said Monday.

  • February 05, 2024

    Tax Court Unswayed By Man's Estoppel Claims In $13M Suit

    A California man is liable for more than $13 million after failing to prove that the Internal Revenue Service does not meet the requirements to recast a certain transaction, the U.S. Tax Court ruled Monday.

  • February 05, 2024

    Ex-Baker Botts Tax Atty Returns To Morgan Lewis In San Fran

    Morgan Lewis on Monday announced the return of a state and local tax expert as a partner who will be based out of the firm's San Francisco office.

  • February 05, 2024

    IRS Delays Maine Tax Deadlines After Floods

    The Internal Revenue Service said Monday that it has delayed a variety of tax deadlines for Maine taxpayers following storms and flooding in the state.

  • February 05, 2024

    3rd Circ. Upholds Property Sale In $16M Tax Row

    A family trust's New Jersey office park was properly sold off by the government to satisfy the $16.2 million tax debt of a trustee, the Third Circuit ruled Monday, finding the trustee substantially controlled the property even though he didn't hold the title.

  • February 05, 2024

    GOP Lawmakers' Concerns Spur Talks On German Royalty Tax

    House Ways and Means Committee Republicans have been in touch with U.S. Treasury Department officials to address the lawmakers' concerns about a German withholding tax imposed on intellectual property registered in the country, a GOP lawmaker told Law360.

  • February 02, 2024

    NYC Sues FDIC For $7M Of First Republic's Back Taxes

    New York City sued the Federal Deposit Insurance Corp. in D.C. federal court in the agency's capacity as receiver for failed First Republic Bank, alleging the bank understated its rent and income taxes it owed to the city for several years and now owes more than $7 million.

  • February 02, 2024

    Interest From Gov't Bonds Qualifies Corp. As A REIT

    A publicly traded corporation may use income and interest from government bonds to help it qualify as a real estate investment trust, the Internal Revenue Service said Friday in a private letter ruling.

  • February 02, 2024

    Couple Owe Reduced FBAR Penalty Of $400K, Court Says

    An Oregon couple must pay almost $400,000 in fines, interest and penalties for failing to report their foreign bank accounts to the Internal Revenue Service, a federal court said.

  • February 02, 2024

    Google, H&R Block Ask Court To Toss Tax Data RICO Suit

    Google and H&R Block asked a California federal court to toss a suit accusing them of scheming to intercept the private data of a man who used H&R Block's tax preparation software, saying there was no evidence the companies conspired.

  • February 02, 2024

    Eaton Asks Court To Agree To Block IRS Summons

    Multinational power management company Eaton Corp. urged an Ohio federal court to adopt a magistrate judge's recommendation to allow the company to buck an IRS summons for confidential performance evaluations of its foreign employees, saying the government's objection underplays the documents' sensitivity.

  • February 02, 2024

    Texas Man Owes Tax On $307K After 'Frivolous' Claims Fail

    More than $307,000 of a Texas man's 2018 income is subject to tax, the U.S. Tax Court ruled Friday, calling his arguments against being taxed "frivolous."

  • February 02, 2024

    Filing Return Unnecessary For Govt. Trust, IRS Rules

    An unnamed trust is not required to file an income tax return because its income accrues to the government of a U.S. territory, the Internal Revenue Service said in a private letter ruling released Friday.

Expert Analysis

  • Mallory Ruling Doesn't Undermine NC Sales Tax Holding

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    Contrary to the conclusion reached in a recent Law360 guest article, the U.S. Supreme Court’s recent Mallory ruling shouldn't be read as implicitly repudiating the North Carolina Supreme Court’s sales tax ruling in Quad Graphics v. North Carolina Department of Revenue — the U.S. Supreme Court could have rejected Quad by directly overturning it, says Jonathan Entin at Case Western Reserve.

  • IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

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    The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.

  • IRS Announcement Will Aid Cos. In Buyback Tax Planning

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    Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Mallory Opinion Implicitly Overturned NC Sales Tax Ruling

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    The U.S. Supreme Court recently declined to review Quad Graphics v. North Carolina Department of Revenue, but importantly kicked the legs from under Quad's outcome a week later, stating in its Mallory decision that the high court has the prerogative to overrule its own decisions, says Richard Pomp at the University of Connecticut.

  • How NIL Collectives Could Be Tax-Exempt After IRS Curveball

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    Since the Internal Revenue Service recently announced that numerous collectives creating paid name, image and likeness deals for collegiate student-athletes do not qualify for tax exemption, for-profit entities and alternative collective structures with incidental student-athlete benefits may be considered to fund NIL ventures, says David Kaufman at Thompson Coburn.

  • Is This Pastime A Side-Gig? Or Is It A Hobby?

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    The recent U.S. Tax Court decision in Sherman v. Commissioner offers important reminders for taxpayers about the documentation and business practices needed to successfully argue that expenses can be deducted as losses from nonhobby income, says Bryan Camp at Texas Tech.

  • Recent Provider Relief Fund Audits Are Just The Beginning

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    Though the Health Resources and Services Administration's initial audits of the Provider Relief Fund program appear to be limited in scope, fund recipients should prepare for additional oversight, scrutiny and disallowances as the HRSA ramps up its efforts, say Brian Lee and Christopher Frisina at Alston & Bird.

  • Flawed Analysis Supports Common Law Tax Deficiency Ruling

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    The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.

  • Review Of Repatriation Tax Sets Justices On Slippery Slope

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    The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.

  • IRS Guidance Powers Up Energy Tax Credit Transfers

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    Recent IRS guidance on the monetization of energy tax credits provides sufficient clarity for parties to start negotiating transfer agreements, but it is unclear when the registration process required for credits to change hands will be up and running, say attorneys at Shearman.

  • Using Agreements To Cover Gaps In Hydrogen Storage Regs

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    The Inflation Reduction Act's incentives for energy storage have spurred investment in hydrogen storage and production, but given the lack of comprehensive regulations surrounding the sector, developers should carefully craft project and financing agreements to mitigate uncertainties, say Omar Samji and Sarah George at Weil, and attorney Manushi Desai.

  • Secure 2.0 Takeaways From DOL's 2024 Budget Proposal

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    The U.S. Department of Labor’s fiscal year 2024 budget proposal provides insight into the most pressing Secure 2.0 implementation issues, including establishment of a search database for finding lost retirement savings and developing guidance on the execution of newly authorized emergency savings accounts, say attorneys at Maynard Nexsen.

  • Avoiding Negative Tax Consequences In Loan Modifications

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    Borrowers who may be caught in the dramatic uptick in nonperforming commercial real estate loans should consider strategies to avoid income and capital gains tax that may be triggered by loan modifications, says Aman Badyal at Glaser Weil.

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