Federal

  • 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.

  • January 31, 2024

    Serbian Dual Citizen Must Pay $5.3M FBAR Penalty

    A man with dual citizenship in the U.S. and Serbia will have to pay $5.3 million in penalties and interest for willful failure to report a Swiss bank account, according to a judgment a New York federal judge issued Wednesday.

  • January 31, 2024

    Feds Urged To Adopt EV Battery Tracing For Tax Credit Rules

    A mechanism to trace the source of battery materials in electric vehicles would help enforce manufacturers' compliance with the domestic content requirements that are now linked to the EV consumer tax credit, stakeholders told U.S. Treasury Department and IRS officials Wednesday.

  • January 31, 2024

    Ex-Ga. Tech Prof Gets Home Confinement For Tax Fraud

    A former Georgia Institute of Technology professor was sentenced to a year of home confinement and three years' probation on Wednesday for shirking hundreds of thousands of dollars in federal taxes by inflating his charitable deductions through a scheme involving Chinese nationals' donations to the university.

  • January 31, 2024

    GILTI Succeeds While FDII, BEAT Struggle, Think Tank Says

    The three main international tax provisions of 2017's Tax Cuts and Jobs Act — GILTI, FDII and the BEAT — have had mixed success, but lawmakers should be careful to retain the beneficial parts while considering any changes to better fit into the global tax structure, the Tax Foundation said Wednesday.

  • January 31, 2024

    Eyewear Seller Owes For Unreported Income, Tax Court Says

    An eyewear seller must pay nearly $85,000 after failing to dispute claims of unreported gross income, the U.S. Tax Court ruled Wednesday.

  • January 31, 2024

    Senate Tax Panel Approves Biden's IRS Chief Counsel Pick

    The Senate Finance Committee approved President Joe Biden's pick for chief counsel of the Internal Revenue Service on Wednesday, sending her nomination to the full Senate for consideration.

  • January 31, 2024

    Calif. Says FDIC Owes Signature Bank's Unpaid Taxes

    California's state tax collection agency asked a New York federal court to force the Federal Deposit Insurance Corp. to pay five years' worth of unpaid taxes on behalf of the shuttered Signature Bank, saying the FDIC is responsible for the debt as the bank's receiver.

  • January 31, 2024

    Treasury Aims To Finish Credit Monetization Rules In 2024

    The U.S. Department of the Treasury aims to issue final rules this year on two new ways to monetize tax credits tied to clean energy construction projects, known as the direct pay and transferability methods, an official said.

  • January 30, 2024

    Wife Who Ran Sailing Apparel Co. Owes $60K, Tax Court Says

    A California woman who ran a sailing apparel company is on the hook for taxes she and her late husband owed, the U.S. Tax Court ruled Tuesday, saying she failed to prove she couldn't pay the $60,000 bill.

  • January 30, 2024

    French Court Won't Revive Case Against FATCA Transfers

    France's highest administrative court on Tuesday upheld a decision from the country's data protection agency, which had tossed a challenge against the transfer of financial information about certain individuals to U.S. tax authorities under the Foreign Account Tax Compliance Act.

  • January 30, 2024

    Investor Says He's Owed Damages For Stocks Seized By IRS

    The IRS should pay a Los Angeles investor more than $500,000 in damages for improperly seizing and selling off his stocks to satisfy a $7.2 million late penalty that the agency mistakenly assessed against him, he told a California federal court.

  • 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.

Expert Analysis

  • 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.

  • 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.

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