Federal

  • March 07, 2024

    IRS Seeks Suggestions For Next Priority Guidance Plan

    The Internal Revenue Service is soliciting public suggestions for its 2024-25 priority guidance plan, the agency announced Thursday.

  • March 07, 2024

    Feds Look To Bar Advice-Of-Counsel Defense From Tax Trial

    Federal prosecutors have sought to prevent two attorneys and an insurance agent from relying on advice-of-counsel defenses in their upcoming tax fraud trial, telling a North Carolina federal judge the trio failed to give the court an adequate heads-up about their intended defense.

  • March 07, 2024

    IRS Halts Penalties On Dyed Diesel After Texas Wildfires

    The Internal Revenue Service will momentarily stop imposing penalties on the sale or highway use of dyed diesel fuel in parts of Texas in response to wildfires, the agency said.

  • March 07, 2024

    IRS' Taxpayer Advocacy Panel Schedules April Meeting

    The Internal Revenue Service's Taxpayer Advocacy Panel Joint Committee scheduled its next public meeting for April 22, the agency said Thursday.

  • March 07, 2024

    Biden Urges Higher Taxes On Wealthy Companies, Individuals

    President Joe Biden, in his Thursday night State of the Union address, urged Congress to make the U.S. tax code fairer by enacting higher rates on wealthy corporations and individuals and extending tax relief to working families.

  • March 06, 2024

    Software Execs Tried To Save Co. With Trust Taxes, Jury Told

    Prosecutors and defense attorneys on Wednesday painted competing pictures of two former software executives at the start of their tax fraud trial in North Carolina, with the government characterizing the pair as liars and cheaters while the defense claimed they were merely trying to right the ship as their business floundered.

  • March 06, 2024

    Impending Corp. Spinoff Guidance Could Refine Tax-Free Test

    Tax attorneys are watching to see if eagerly awaited corporate spinoff guidance will help determine whether transactions qualify for tax-free status with more clarity than current regulations, and without controversial bright-line rules that were floated several years ago.

  • March 06, 2024

    Startup Investors' Attys Want $1.5M In Fees On Disclosure Suit

    Lawyers for a class of investors have asked a New York federal court to approve their attorney fees of $1.5 million for a $4.5 million settlement with a Chinese analytics startup over claims the company misrepresented its tax liability before its initial public offering. 

  • March 06, 2024

    IRS Targeted Atty In Bank Records Suit, Justices Told

    The Internal Revenue Service violated an attorney's free speech rights by targeting him based on a tax analysis he posted online, he argued in asking the U.S. Supreme Court to consider overturning a ruling allowing the agency to obtain his bank account information.

  • March 06, 2024

    First Woman To Be Permanent Top IRS Atty Begins Tenure

    The first woman to permanently serve as chief counsel of the Internal Revenue Service began her tenure Wednesday.

  • March 05, 2024

    Goal Is Still For A Mandatory Amount B, Treasury Official Says

    Negotiators at the OECD made it optional for countries to adopt new simplified and streamlined transfer pricing rules, known as Amount B, but the goal is still for the framework to be mandatory, a U.S. Treasury Department official said Tuesday.

  • March 05, 2024

    Pillar 1 Would Have Cost US Gov't $1.4B In 2021, Study Says

    U.S. tax revenue would have been reduced by $1.4 billion in 2021 under a proposed system to reallocate a share of tax payments to where large multinational corporations have customers but lack a physical presence, the Joint Committee on Taxation said Tuesday.

  • March 05, 2024

    Appraiser Withholding Docs In $57M Case, Gov't Tells Court

    A Florida federal court should force an appraiser to hand over documents the IRS says it needs for an investigation into a partnership's $57 million tax deduction for a conservation easement donation, the U.S. argued in a petition Tuesday, saying the appraiser has refused to comply with a summons.

  • March 05, 2024

    Biz Owner Gets 10 Months For Evading Tax On Foreign Income

    The owner of a manufacturing company was sentenced in California federal court to 10 months in prison for avoiding taxes on almost $4.5 million in income by failing to report his foreign sales to the Internal Revenue Service, the U.S. Department of Justice said.

  • March 05, 2024

    Retiree's Bid For $284K FBAR Refund Thrown Out

    Federal district courts lack jurisdiction to refund penalties for failing to report foreign accounts, which means a Georgia man must refile in the U.S. Court of Federal Claims to try to recover $284,000 that he was penalized, a Georgia federal court said in dismissing his case.

  • March 05, 2024

    Treasury Finalizes Direct Pay Rules For Energy Tax Credits

    The U.S. Department of the Treasury on Tuesday finalized regulations governing direct payments of several clean energy tax credits provided by the Inflation Reduction Act but said it was still mulling how to address so-called chaining of payments and co-ownership arrangements.

  • March 04, 2024

    Former DOJ Assistant Chief Joins Bird Marella

    The assistant chief in the fraud section of the Department of Justice's Criminal Division joined Bird Marella Rhow Lincenberg Drooks & Nessim LLP, the firm announced Tuesday.

  • March 04, 2024

    Corporate Transparency Act Unconstitutional, Ala. Judge Says

    An Alabama federal judge has found that the Corporate Transparency Act is unconstitutional, dealing a blow to proponents of the anti-money laundering law, who anticipate the ruling will be appealed to the Eleventh Circuit.

  • March 04, 2024

    TCJA To Reduce Corporate Tax Revenue By 40%, Study Says

    The 2017 Tax Cuts and Jobs Act is expected to reduce corporate tax revenue by about 40% over a decade after increased investment in the U.S. is accounted for, according to a study published Monday by the National Bureau of Economic Research. 

  • March 04, 2024

    Former IRS Commissioner Joins Chamberlain Hrdlicka

    Former IRS Commissioner Charles "Chuck" Rettig joined Chamberlain Hrdlicka White Williams & Aughtry as a shareholder in Los Angeles, following in the footsteps of his former acting chief of staff, whom the firm hired last year.

  • March 04, 2024

    Justices Won't Review $10M Tax On Gulfstream Heirs

    The U.S. Supreme Court declined Monday to review the Internal Revenue Service's imposition of personal liability for $10 million in unpaid estate taxes on the survivors of Gulfstream Aerospace Corp.'s founder, letting stand a Ninth Circuit ruling.

  • March 04, 2024

    1st Circ. Grapples With Crypto Exchange Tax Docs Seizure

    First Circuit judges grappled Monday with an investor's claim that the IRS violated his privacy and property rights when it seized his account records from cryptocurrency exchange Coinbase, trying to establish during oral arguments to what extent the exchange was different from a traditional bank.

  • March 04, 2024

    Trump's Former Finance Chief Pleads Guilty To Perjury

    Allen Weisselberg, the longtime former financial chief of Donald Trump's real estate business empire, admitted Monday to lying under oath in the New York attorney general's civil fraud case as part of a plea deal to serve five months in jail.

  • March 01, 2024

    IRS Turning To Experts, AI For Complex Returns, Werfel Says

    The Internal Revenue Service is using a blend of newly hired subject-matter experts and artificial intelligence technology to increase scrutiny of complex tax returns filed by wealthy corporations and individuals, agency Commissioner Daniel Werfel said Friday.

  • March 01, 2024

    Tax Break Bill Could Still Pass After Tax Season, Aide Says

    If Senate lawmakers haven't voted on the bipartisan House-passed tax bill by the end of the 2024 tax filing season, that doesn't necessarily mean the bill won't get to President Joe Biden's desk this year, an aide to Democrats on the House Ways and Means Committee said Friday.

Expert Analysis

  • How Gov't Agencies Will Fare In The Event Of A Shutdown

    Author Photo

    With a federal shutdown potentially set to begin at the end of this month, it may be useful to consider the approximate timelines that agencies such as the Federal Trade Commission and IRS have announced for curtailing operations, and potential strategies for mitigating challenges that may arise while agency functions are limited, say attorneys at Cleary.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

    Author Photo

    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

    Author Photo

    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

    Author Photo

    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.