Federal

  • 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.

  • 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.

Expert Analysis

  • 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.

  • If Justices End Chevron Deference, Auer Could Be Next Target

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    If the U.S. Supreme Court decides next term to overrule its Chevron v. NRDC decision, it may open the door for a similar review of the Auer deference — the principle that a government agency can interpret, through application, ambiguous agency regulations, says Sohan Dasgupta at Taft Stettinius.

  • Tax Court Ruling Provides Helpful Profits Interest Guidance

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    A recent U.S. Tax Court decision holding that a partnership may exclude interests in a company that it indirectly received sheds light on related IRS guidance, including the proper valuation method for such interests, though the court's application of the method to the facts of this case appears flawed, say attorneys at Kramer Levin.

  • 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.

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