Federal

  • 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.

  • February 02, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin Friday, which included guidance on pension-linked emergency savings accounts.

  • February 02, 2024

    Taxation With Representation: Simpson, Wachtell Lipton

    In this week's Taxation With Representation, Rise Growth Partners receives a $250 million investment, a group of investors led by Carlyle Group co-founder David Rubenstein acquires a controlling stake in MLB's Baltimore Orioles, The Cigna Group sells multiple Medicare businesses to Health Care Service Corp., and WillScot Mobile buys McGrath RentCorp.

  • February 01, 2024

    GOP AGs Press Treasury To Halt IRS Direct File Program

    The U.S. Department of the Treasury should stop the Internal Revenue Service's direct file pilot program because it is unconstitutional and unnecessary, 13 Republican attorneys general told Treasury Secretary Janet Yellen in a letter.

  • February 01, 2024

    Kemp Klein Brings On Tax Attorney From Foster Swift

    Kemp Klein Law Firm said Thursday that it added a shareholder to its team who was formerly with Foster Swift Collins & Smith PC and counsels clients in tax planning.

  • February 01, 2024

    IRS Violated Rights In Coinbase Doc Seizure, 1st Circ. Told

    The IRS violated an investor's property rights when it seized his financial records from the cryptocurrency exchange Coinbase, he told the First Circuit on Thursday, saying the government defended the violation by wrongly focusing on what it claims are the investor's lack of privacy protections.

  • February 01, 2024

    Biden Names 3 Tax Court Nominees

    A senior staffer at the Joint Committee on Taxation and an Internal Revenue Service attorney are two of three public servants President Joe Biden picked as nominees to the U.S. Tax Court, the White House announced Thursday.

  • February 01, 2024

    Texas Couple Can't Deduct $1M In Premiums, Tax Court Rules

    A Texas couple who bought insurance policies from agencies controlled by themselves cannot deduct more than $1 million in premiums, the U.S. Tax Court ruled Thursday.

  • February 01, 2024

    Ex-Trump Org. CFO Faces Possible Perjury Charge, Mulls Plea

    Donald Trump's longtime top financial officer Allen Weisselberg is in plea negotiations related to potential perjury charges stemming from his testimony in the New York attorney general's civil fraud trial, according to a source familiar with the matter.

  • February 01, 2024

    US Won't Ask Justices To Review States' Win In ARPA Row

    The U.S. Treasury Department opted not to appeal an Eleventh Circuit ruling in favor of 13 states that challenged the American Rescue Plan Act's limitations on using federal pandemic aid to pay for tax cuts, the agency said in a letter disclosed Thursday.

  • February 01, 2024

    Justices Asked To Stop Trustee From Recovering Taxes

    The federal government asked the U.S. Supreme Court to stop the bankruptcy trustee of a Utah company from being allowed to recoup federal tax payments, saying the issue is the subject of a growing circuit split and stands to deplete the federal purse illegally.

  • February 01, 2024

    House Panel Readies 2023 SALT Cap Relief Bill

    Proposed legislation that would raise the cap on state and local tax deductions for 2023 for married couples with adjusted gross incomes below $500,000 advanced to the full House of Representatives on Thursday following a House panel vote.

  • February 01, 2024

    NYC Music Venue Gets 'Last Shot' At Ch. 11 Reorg

    A New York bankruptcy judge Thursday gave a New York City music venue what he said was one last chance to get caught up on its state and federal back taxes before it faces a conversion of its Chapter 11 reorganization to a liquidation.

  • January 31, 2024

    House Sends Bipartisan Tax Break Package To Senate

    The House of Representatives passed a bipartisan bill Wednesday night that would extend the full tax break for research and development costs and expand the child tax credit for multiple years, sending the deal to the Senate for consideration.

  • January 31, 2024

    Estate, Wife Owe Gift Tax On Sale To Son, Tax Court Says

    The estate of the former president of an aerospace parts company, and his wife, owe gift taxes in connection with the couple's sale of company shares to their son, the U.S. Tax Court ruled Wednesday.

Expert Analysis

  • 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.

  • Benefits And Beyond: Fixing Employee Contribution Failures

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    Employers must address employee contribution failures promptly in order to avoid losing significant tax benefits of 401(k) or 403(b) plans, but the exact correction procedures vary depending on whether contributions were less than or greater than intended, say attorneys at Seyfarth Shaw.

  • Now Is The Time For State And Local Sales Tax Simplification

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    In the five years since the U.S. Supreme Court’s landmark decision in South Dakota v. Wayfair, state and local governments increasingly rely on sales tax, but simple changes are needed to make compliance more manageable for taxpayers, wherever located, without unduly burdening interstate commerce, says Charles Maniace at Sovos.

  • Recent Bills Show Congress' Growing Maturity On Cannabis

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    Though two recently introduced cannabis reform bills, the Prepare Act and the Small Business Tax Equity Act, are unlikely to pass in this Congress, they demonstrate a new level of focus and sophistication on the part of lawmakers as it relates to cannabis at the federal level, says Irina Dashevsky at Greenspoon Marder.

  • What To Make Of IRS' New Advance Pricing Guidance

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    Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.

  • Compliance Obligations Still Murky For Superfund Excise Tax

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    Comments on the IRS' reinstatement of the Superfund chemicals excise tax show that, given taxpayers' lack of institutional knowledge and the government's previous failure to finalize clarifying guidance, further regulatory action is needed to help taxpayers understand their obligations, say Nicole Elliott and Mary Kate Nicholson at Holland & Knight.

  • The Reciprocal Tax Bill Is A Warning Shot At Pillar 2

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    A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.

  • 3 Developments That May Usher In A Nuclear Energy Revival

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    A recent advancement in nuclear energy technology, targeted provisions in the Inflation Reduction Act and a new G7 agreement on nuclear fuel supply chains may give nuclear power a seat at the table as a viable, zero-carbon energy source, say attorneys at Vinson & Elkins.

  • What Tax-Exempt Orgs. Need From Energy Credit Guidance

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    Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.

  • Unconventional Profits Interest Structures Find New Support

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    A recent U.S. Tax Court ruling should provide comfort that less-than-plain-vanilla profits interest structures, created to achieve complicated economic arrangements, can succeed in generating more optimal tax outcomes, provided the terms are properly drafted, says Daren Shaver at Hanson Bridgett.

  • Roadblocks For Cannabis Employers Setting Up 401(k) Plans

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    Though the Internal Revenue Code and the Employee Retirement Income Security Act generally allow cannabis businesses to establish 401(k) plans for their employees, companies must still pick their way through uncertainties around tax deductions and recruiting reliable vendors, say attorneys at Shipman & Goodwin.

  • How Foreign Info Return Penalty Case May Benefit Taxpayers

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    The U.S. Tax Court's recent decision that the Internal Revenue Service cannot penalize taxpayers for failing to file foreign corporation information returns may give similarly situated taxpayers an opportunity to also avoid penalties, provided they protect their rights before the decision is overturned or mooted by legislation, say attorneys at Arnold & Porter.

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