Federal

  • March 13, 2024

    Tax Court Calls CPA's Deduction Testimony 'Contradictory'

    A California certified public accountant cannot deduct nearly $600,000 in assorted expenses — including more than $437,000 in net operating losses — after providing "contradictory" testimony and failing to present credible evidence, the U.S. Tax Court ruled Wednesday.

  • March 13, 2024

    Actuary Board Looks To End In-Person Learning Requirement

    The Joint Board for the Enrollment of Actuaries has proposed eliminating a requirement that continuing education programs be attended in person, the Internal Revenue Service said Wednesday.

  • March 13, 2024

    Deputy To Take Over As IRS Criminal Investigation Chief

    The deputy chief of the Internal Revenue Service's Criminal Investigation division will take the helm of the division when its current chief steps down April 6, the agency said Wednesday.

  • March 13, 2024

    2nd Circ. Affirms Barring Of Man's Appeal In Small Tax Case

    The Second Circuit rejected a taxpayer's attempt to resurrect his dispute over a tax deficiency Wednesday, affirming that a statute prohibits appeals of U.S. Tax Court decisions in certain cases involving low dollar amounts.

  • March 13, 2024

    6th Circ. Told Woman Helped Life Partner Avoid $3M In Taxes

    The federal government justifiably sold off the property of a woman who paid for it with money from her dead long-term life partner, the U.S. government told the Sixth Circuit on Wednesday, saying the purchase helped her partner skirt more than $3 million in tax liabilities.

  • March 13, 2024

    JCT Indicates Pillar 1 Is Bad Deal For US, GOP Lawmakers Say

    An analysis of the Organization for Economic Cooperation and Development's Pillar One taxing rights overhaul by congressional scorekeepers makes clear the plan should not receive U.S. support because it would disadvantage U.S. multinationals and federal tax revenue, Republican leaders of Congress' taxwriting committees said Wednesday.

  • March 13, 2024

    Longtime Stradley Ronon Tax Partner Joins Grant Thornton

    Following more than a quarter-century practicing law with Stradley Ronon Stevens & Young LLP, longtime tax attorney Chris Scarpa decided to change career paths, joining accounting firm Grant Thornton LLP.

  • March 13, 2024

    Ex-Super Bowl Champ Owes $15M Tax After Default, US Says

    A California federal court should issue a default judgment for $15.5 million in federal income taxes against four-time Super Bowl champion Bill Romanowski and his wife, the U.S. government argued, saying the couple has failed to participate in a collection case against them.

  • March 13, 2024

    IRS Art Appraisal Panel Schedules April Meeting

    The Internal Revenue Service committee that appraises art for tax purposes will hold its next meeting April 17, the agency said Wednesday.

  • March 12, 2024

    IRS Mulling Partnership Foreign Currency Rules, Official Says

    The Internal Revenue Service will likely propose rules that would provide additional guidance to partnerships for determining taxable income or loss with respect to certain affiliates that conduct business in a foreign currency, an agency official said Tuesday.

  • March 12, 2024

    NC Software Execs Convicted Of Payroll Tax Crimes

    Two former software executives in North Carolina were convicted Tuesday of failing to pay hundreds of thousands of dollars in employment taxes, but were absolved of charges that they lied on their individual tax returns, bringing to a close their five-day trial in Charlotte's federal courthouse.

  • March 12, 2024

    IRS Fully Opens Direct E-File Pilot Program In 12 States

    The Internal Revenue Service's free electronic tax-return filing pilot program is now open to all 19 million eligible taxpayers in the 12 states where people can participate, agency Commissioner Daniel Werfel told reporters Tuesday.

  • 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.

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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