Federal

  • January 30, 2024

    Spencer Fane Adds Tampa Tax Partner From Gunster

    Spencer Fane LLP has added a partner focused on corporate and tax matters from Florida firm Gunster to its Tampa office.

  • January 30, 2024

    Higher Ed Group Urges Treasury To Clarify Bond Financing

    The U.S. Treasury Department should provide guidance clarifying the relationship between tax-exempt bond financing and student loan refinancing programs, a trade association representing higher education finance organizations said in a letter released Tuesday.

  • January 30, 2024

    Justices Asked To Affirm $10M Tax On Gulfstream Heirs

    The U.S. Supreme Court should let stand a decision allowing the Internal Revenue Service to impose personal liability for $10 million in unpaid estate taxes on the survivors of Gulfstream Aerospace Corp.'s founder, the federal government argued.

  • January 30, 2024

    Returned Credit Funds Not Bound To Same Zones, IRS Says

    The reallocation of certain returned housing tax credits is not restricted to projects located in qualified disaster zones, the Internal Revenue Service ruled Tuesday.

  • January 30, 2024

    IRS Deadlines Postponed In RI After Sept. Storms

    The Internal Revenue Service postponed certain deadlines for Rhode Island taxpayers affected by September's storms and flooding, the agency said Tuesday.

  • January 29, 2024

    Insurer-Backed Docs Must Show Tax Records For Bias Check

    A split Michigan appellate court panel has said a car crash victim seeking coverage for his injuries can force the medical examiners hired by his insurer to turn over tax documents, finding the records are relevant to determine potential bias that couldn't be discovered otherwise.

  • January 29, 2024

    H&R Block Inks $1.6M Deal With LA City Atty Over Free Filing

    H&R Block has agreed to pay $1.6 million to settle accusations it unfairly charged tens of thousands of taxpayers who were eligible to file federal tax returns for free by directing them toward its paid online commercial products, the Los Angeles city attorney announced Monday.

  • January 29, 2024

    Trump Assails Fraud Monitor For 'Misleading' Final Report

    Counsel for former President Donald Trump denounced the independent monitor overseeing his businesses on Monday, accusing her of seeking to extend her term and get more money by bolstering the New York attorney general's civil fraud case as a decision looms.

  • January 29, 2024

    Feds Can Sell Property Of NY Woman Who Owes $35M

    The U.S. government can sell 10 properties on New York's Long Island after their owner failed to defend herself against a claim she did not pay income taxes and penalties amounting to $35 million.

  • January 29, 2024

    Tax Group Of The Year: Sullivan & Cromwell

    Sullivan & Cromwell LLP's tax practice advised Abiomed on the tax aspects of its acquisition by Johnson & Johnson in the largest medtech deal in history last year, earning the firm a spot among Law360's 2023 Tax Groups of the Year.

  • January 29, 2024

    IRS Worker Gets 5 Years For Airing Tax Info On Trump, Others

    A former IRS contractor who copped to stealing the tax returns of thousands of wealthy people, including former President Donald Trump, and leaking them to the media will serve five years in prison.

  • January 29, 2024

    Werfel Says IRS Will Be Ready To Implement Tax Break Bill

    The Internal Revenue Service is updating its operations and will be ready to carry out tax legislation pending in the U.S. House that would expand the child tax credit and restore 100% bonus depreciation, Internal Revenue Commissioner Daniel Werfel told reporters Friday.

  • January 26, 2024

    Trump Org. Monitor Flags Financial 'Errors' As Ruling Looms

    An independent monitor overseeing the Trump Organization's finances amid the New York attorney general's civil fraud suit reported Friday she found multiple errors and misstatements in disclosures sent to third-party lenders, including underreporting the organization's liabilities by millions of dollars and hiding $40 million recently sent directly to the former president.

  • January 26, 2024

    US Proved Daughters Fraudulently Moved $1.4M, Court Says

    The U.S. government proved that two daughters fraudulently transferred $1.4 million to their U.S. bank accounts from their mother's Israeli bank, but it failed to name and support the amount of damages it seeks, a Florida federal court said.

  • February 08, 2024

    Law360 Seeks Members For Its 2024 Editorial Boards

    Law360 is looking for avid readers of its publications to serve as members of its 2024 editorial advisory boards.

  • January 26, 2024

    Wife Accused Of Tax Crimes Must Keep GPS Monitor, US Says

    A woman indicted with her husband on tax evasion charges relating to an abusive trust scheme should not be allowed to remove her ankle monitor, the U.S. government told a Colorado federal court, saying her previous tracking devices sustained suspicious damage.

  • January 26, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin Friday, which included a clarification of a religious-based filing exemption.

  • January 26, 2024

    Ariz. AG Asks IRS Not To Tax State Rebates

    Arizona's recently paid general welfare income tax rebates should not be subject to federal income tax, the state's attorney general said in a letter to the Internal Revenue Service.

  • January 26, 2024

    Bipartisan Tax Break Bill Faces Rocky Road To Passage

    A bipartisan tax bill that quickly cleared the House's tax panel faces a tumultuous path forward in the full chamber, where Speaker Mike Johnson, R-La., needs to either have robust bipartisan support to pass the bill or risk opening it up to changes.

  • January 26, 2024

    Tax Group Of The Year: Mayer Brown

    Mayer Brown LLP secured local and global victories in 2023, from a Washington state appellate court's decision in a novel sales tax case to an energy company's $307 million merger resulting in a business with an Africa exploration and production focus, earning the firm a spot among Law360's Tax Groups of the Year.

  • January 26, 2024

    Senate Panel Schedules Vote On IRS Chief Counsel Nominee

    The Senate Finance Committee will vote next week on President Joe Biden's pick for chief counsel of the Internal Revenue Service, the committee announced.

  • January 26, 2024

    Calendar Administrators Named For 36 Tax Court Sessions

    The Internal Revenue Service named calendar administrators for 36 U.S. Tax Court sessions in March, April and May, according to a notice released Friday.

  • January 26, 2024

    US Expatriations Rise In 4th Quarter, IRS Says

    The number of people who expatriated from the U.S. jumped nearly 45% during the fourth quarter of 2023 compared with the previous quarter, the Internal Revenue Service said in a notice published Friday.

  • January 25, 2024

    US Fights Trustee's Demand Of Avenatti's Tax Return Info

    The U.S. government asked a California federal judge Thursday to allow it to appeal a bankruptcy court's decision ordering disgraced attorney Michael Avenatti's tax returns to be released to the trustee overseeing the estate of Eagan Avenatti LLP's bankruptcy, arguing that disclosing them undermines Congress' interest in protecting the confidentiality of the information.

  • January 25, 2024

    John Hancock Clients Owed Tax Credit Perk, 11th Circ. Told

    John Hancock Life Insurance Co. clients urged an Eleventh Circuit panel on Thursday to reverse a lower court's ruling that the company didn't breach a fiduciary duty when $100 million worth of foreign tax credits wasn't passed through to them, saying the transaction diminished the value of their retirement accounts.

Expert Analysis

  • How Cities Can Tackle Post-Pandemic Budgeting Dilemmas

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    Due to increasing office vacancies around the country, cities may consider politically unpopular actions to avoid bankruptcy, but they could also look to the capital markets to ride out the current real estate crisis and achieve debt service savings to help balance their budgets, say attorneys at Cadwalader.

  • Guidance Adds Clarity To Energy Communities Bonus Credits

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    Recent IRS guidance on the Inflation Reduction Act's changes to tax credits for renewable energy projects offers much-needed pointers for developers and financing parties, and should allow them to more comfortably incorporate special bonus credits for projects in energy communities into their transactions, say Jorge Medina and Ira Aghai at Shearman.

  • Taxing The Digital Economy: The Good, The Bad And The Ugly

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    U.S. tech companies should watch for important developments in international taxation, including the resolution of Apple's decade-old state aid case, growing frustration with the Organization for Economic Cooperation and Development's global tax plan and adoption of the digital services tax instead, says Joyce Beebe at Rice University's Baker Institute for Public Policy.

  • Big Tax Changes For Multinational Cos. In Budget Proposal

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    The Biden administration’s fiscal year 2024 budget proposes changes that would materially alter decades-old Internal Revenue Code provisions, requiring a shift in multinational corporations' tax planning strategies comparable to that required after enactment of the Tax Cuts and Jobs Act, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • SVB Collapse Reinvigorates Bank Accounting Debate

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    Silicon Valley Bank's sudden collapse revives questions over whether fair value or amortized cost accounting is the most appropriate for banks' financial reporting — a controversy that's crucial for understanding what information could have helped market participants better understand SVB's financial condition, say consultants at Analysis Group.

  • Brownfield Renewables Guidance Leaves Site Eligibility Murky

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    Recent IRS guidance sheds some light on the Inflation Reduction Act's incentives for renewable energy development on contaminated sites — but the eligibility of certain sites for brownfield status remains uncertain, say Megan Caldwell and Jon Micah Goeller at Husch Blackwell.

  • Get Ready For IRS Criminal Crackdown On Crypto

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    Recent developments at the IRS, from a new operating plan to the announcement of a centralized data center, signal that the agency is ramping up criminal enforcement against those using digital assets to evade tax liabilities — and given its high conviction rate, companies and individuals must prioritize compliance, say attorneys at BakerHostetler.

  • NFT Tax Guidance Shows IRS Interest In Crypto Enforcement

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    The IRS' first ever guidance addressing the federal income tax treatment of NFTs indicates the agency could take a potentially aggressive stance in enforcing U.S. tax laws in the NFT and crypto spaces, which could have a significant impact on the self-directed IRA market, say attorneys at BakerHostetler.

  • Substantiation Is Key When Gifting Crypto To Charity

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    A recent Internal Revenue Service memorandum makes clear that the agency will require substantiation when gifting cryptocurrency to charity, even for relatively small amounts, so donors need to be aware of the important differences between crypto and typical cash donations, says Sheryl Morrison at Lathrop GPM.

  • Senate Credit Suisse Report Puts Attention On Banks, Trusts

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    The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.

  • Seeking IRS Accountability For Faulty Microcaptive Notice

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    Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.

  • Biden Admin. Proposals Both Encourage And Thwart EV Adoption

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    While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.

  • 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.

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