Federal

  • January 24, 2024

    Justices' Repatriation Tax Review May Disrupt Investor Levies

    The U.S. Supreme Court has signaled the possibility of a narrow ruling that upholds the one-time mandatory repatriation provision, but justices could still undermine certain capital markets measures if they question the constitutionality of taxes on unrealized income.

  • January 24, 2024

    IRS Wrongly Taxed Insurance Payout, Estate Tells Justices

    The Eighth Circuit wrongly allowed the IRS to tax a life insurance payout meant to maintain a family's control of its St. Louis building materials company, the estate of the company's deceased co-owner told the U.S. Supreme Court in an opening brief Wednesday.

  • January 24, 2024

    Simpson Thacher Appoints Tax Partner From Kirkland

    The Houston office of Simpson Thacher & Bartlett LLP has a new tax partner, formerly of Kirkland & Ellis LLP, the firm announced Wednesday.

  • January 24, 2024

    Fraud Extends Time Limit For IRS Assessment, Tax Court Says

    The Internal Revenue Service may assess tax outside a three-year time period in instances when a preparer intends to evade tax with a false return, the U.S. Tax Court ruled Wednesday.

  • January 24, 2024

    Dead Film Exec's IRS Summons Invalid, High Court Told

    The daughter of a dead film executive asked the U.S. Supreme Court to review a Ninth Circuit decision approving an IRS summons for her father's financial records, saying the documents stemmed from an illegal search of his home in Los Angeles triggered by Italian authorities.      

  • January 24, 2024

    GOP Reps. Urge Max Sentence For IRS Tax Info Leaker

    The IRS consultant who stole the tax returns of thousands of wealthy people, including Donald Trump, and leaked them to the media should receive the maximum sentence, House Ways and Means Committee Republicans told a D.C. federal judge in a letter released Wednesday.

  • January 24, 2024

    NJ Tax Preparer Admits $4M Conspiracy To Defraud IRS

    A New Jersey tax preparer has admitted that he conspired to employ an identity theft scheme to defraud the U.S. government of $4.49 million, the U.S. attorney announced Wednesday.

  • January 24, 2024

    Tax Group Of The Year: Cravath

    Cravath Swaine & Moore LLP attorneys provided tax advice to Johnson & Johnson on a landmark $41 billion spinoff of its consumer health business to Kenvue Inc. that led to a $4.37 billion initial public offering, earning the firm a spot among Law360's 2023 Tax Groups of the Year.

  • January 24, 2024

    Specialists In US, EU Say BEFIT Will Add Complexity

    A European Union proposal to provide for a common tax base for large multinational companies would make tax compliance more complex, specialists from the EU and U.S. said in published comments.

  • January 23, 2024

    Colo. Couple's Foreign Taxes Are Final, Tax Court Says

    A Colorado couple's attempts to exclude a closing agreement — in an attempt to be taxed under U.S. tax law after having elected to waive foreign-based income from U.S. law — did not establish a genuine dispute of fact, the U.S. Tax Court ruled Tuesday.

  • January 23, 2024

    Tax Court OKs Calif. Couple's S Corp. Flow-Through Loss

    A California couple are eligible to claim the entire flow-through loss resulting from transfers between two S corporations because the transfers were interests in equity, the U.S. Tax Court ruled Tuesday.

  • January 23, 2024

    6th Circ. Says Whistleblower Really Fired For 'Coup' Attempt

    A Sixth Circuit panel found Monday that a medical device company fired its president's son not because he ratted out his stepmother to the IRS, but because he tried to seize control of the family heating pad business.

  • January 23, 2024

    Beyoncé's $3M Tax Court Trial Set For May

    Pop star Beyoncé's dispute of a $3 million tax bill will head to trial in the U.S. Tax Court in May, according to a pretrial order filed Tuesday.

  • January 23, 2024

    IRS Launches Project To Simplify Hundreds Of Notices

    The Internal Revenue Service is launching a project to redesign hundreds of notices to make them clearer, starting with the most common notices sent to individual taxpayers, the agency announced Tuesday.

  • January 23, 2024

    Tax Group Of The Year: Baker McKenzie

    Baker McKenzie successfully represented FedEx in the first case in which a court struck down a regulation under the 2017 federal tax overhaul on substantive grounds, earning the firm a spot among Law360's 2023 Tax Groups of the Year.

  • January 23, 2024

    Tax Court Proposes Getting Rid Of Timely Petition Rule

    The U.S. Tax Court proposed eliminating a rule that requires the timely filing of a petition, saying that the court finds it "no longer appropriate" to address the topic in its formal rules.

  • January 22, 2024

    Feds Seek 2-Plus Years For 'Brazen' Philly Cheesesteak Duo

    The U.S. Attorney's Office in Philadelphia has asked a federal judge to impose a minimum prison sentence of three years on a father and two years on his son, after they admitted to running an $8 million tax-avoidance scheme at their iconic Tony Luke's cheesesteak shop in South Philly.

  • January 22, 2024

    FTC Rules Against Maker Of TurboTax In Deceptive Ad Case

    The Federal Trade Commission announced Monday that it has ruled against Intuit Inc., the maker of TurboTax, saying the company duped customers for years into thinking they could file their tax returns for free, in violation of a law against deceptive advertising.

  • January 22, 2024

    Top Treasury Tax Policy Official To Leave For NYU Law

    The U.S. Department of the Treasury's assistant secretary for tax policy will leave the role to return to New York University School of Law in the spring as a tax law professor, the school announced.

  • January 22, 2024

    Tax Court Calls Pa. Man's Arguments Frivolous

    The government may collect more than $12,000 in tax liabilities from a Pennsylvania man who failed to properly dispute the assessment, the U.S. Tax Court ruled Monday.

  • January 22, 2024

    Foley Adds Paul Hastings Tax Atty, Eyeing East Coast Growth

    Foley & Lardner LLP on Monday announced its latest lateral hire on the East Coast, welcoming a tax attorney from Paul Hastings LLP to its New York office.

  • January 22, 2024

    IRS Delays Deadlines For Victims Of Conn. Storms, Floods

    The Internal Revenue Service said Monday that it has postponed certain deadlines for Connecticut taxpayers affected by this month's storms and flooding.

  • January 22, 2024

    Justices Should Hold Off On Tax Tipster's Case, IRS Says

    The IRS told the U.S. Supreme Court it should wait to decide whether to review a tipster's claim that he was wrongly denied a whistleblower award, as his argument hinges on the justices' decision in another case about the deference courts should give federal agencies.

  • January 19, 2024

    Law360 Names Firms Of The Year

    Eight law firms have earned spots as Law360's Firms of the Year, with 55 Practice Group of the Year awards among them, steering some of the largest deals of 2023 and securing high-profile litigation wins, including at the U.S. Supreme Court.

  • January 19, 2024

    Law360 Names Practice Groups Of The Year

    Law360 would like to congratulate the winners of its Practice Groups of the Year awards for 2023, which honor the attorney teams behind litigation wins and major deals that resonated throughout the legal industry this past year.

Expert Analysis

  • 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.

  • 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.

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