Federal

  • April 19, 2024

    Atty In Tax Fraud Case Gets Supervised Release, $25K Fine

    A former Houston lawyer whose conviction in connection with an $18 million tax scheme was overturned told a federal judge Friday that not testifying in his 2019 trial was "one of the worst mistakes" of his life as he was sentenced to a year of supervised release as part of a plea deal.

  • April 19, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, featuring the federal income tax treatment of amounts paid for the purchase of energy efficient property and improvements under the Inflation Reduction Act.

  • April 19, 2024

    Miami Tax Prep Biz Should Be Shut Off For Fraud, DOJ Says

    A Miami tax preparation business and its owner should be permanently barred from preparing returns after illegally understating customers' liabilities and causing a $500,000 tax loss to the U.S. government for 2023, the U.S. Department of Justice told a Florida federal court.

  • April 19, 2024

    IRS Corrects Advanced Manufacturing Credit Rules

    The Internal Revenue Service issued a correction notice Friday, fixing a number of errors in final regulations concerning the elective payment election of the advanced manufacturing investment credit under a 2022 law that established the credit.

  • April 19, 2024

    Insurance Co's Shifting Payments Still Fixed Asset, IRS Says

    A stock life insurance company's fixed annuity contract involving structured settlement transactions can still qualify as a funding asset, even though the payment amounts increase with the market, the Internal Revenue Service said in a pair of private letter rulings released Friday.

  • April 19, 2024

    Taxation With Representation: Kirkland, Cleary, O'Melveny

    In this week's Taxation With Representation, Resideo Technologies Inc. announced plans to buy Snap One Holdings Corp., APi Group said it bought an elevator maintenance company, Prysmian said it agreed to purchase Encore Wire, and Sayari said it closed on an investment from TPG.

  • April 19, 2024

    Questions Loom Over China's Pillar 2 Participation

    Practical and political problems surrounding the Organization for Economic Cooperation and Development's 15% global minimum corporate tax raise questions about how China and its biggest companies could undermine that regime.

  • April 18, 2024

    Brothers Can't Deduct $3.8M Theft Loss, Tax Court Says

    Two brothers who claimed that a convicted fraudster stole from a holding company for their struggling savings and loan can't take a theft-loss deduction topping $3.8 million because they failed to prove a connection to the fraud, the U.S. Tax Court ruled Thursday.

  • April 18, 2024

    Donor Fund Rules Unlikely To Be Retroactive, Officials Say

    Proposed regulations from the U.S. Department of the Treasury and Internal Revenue Service on donor-advised funds will likely be changed so that they don't apply retroactively, government officials said Thursday.

  • April 18, 2024

    AbbVie Can't Get Deduction For $1.6B Merger Fee, IRS Says

    The IRS defended its denial of AbbVie's claimed deduction for a $1.6 billion payment to a biotechnology company over their failed merger, telling the U.S. Tax Court that the pharmaceutical giant is misconstruing an underlying statute to challenge the agency's decision.

  • April 18, 2024

    Clinic Head Gets 9 Years For Medicare Kickback, Tax Scheme

    A health clinic manager was sentenced to nine years in prison and ordered to pay $40 million in restitution to the government for participating in a multimillion-dollar healthcare kickback scheme that involved tax fraud, according to documents in a New York federal court.

  • April 18, 2024

    AICPA Offers Support For Disaster Tax Lookback Plan

    A House proposal that would allow for those affected by disasters to extend the period for claiming tax credits or refunds when granted postponements for filing tax returns received support from the American Institute of Certified Public Accountants.

  • April 18, 2024

    IRS Updates Rates For Foreign Insurance Company Equations

    The Internal Revenue Service published updated domestic asset/liability and yields percentages Thursday that foreign life insurance companies as well as foreign property and liability insurance companies need to compute their minimum effectively connected net investment income for tax years starting in 2023.

  • April 18, 2024

    $32B More In Tax Yielded In Fiscal '23 Closed Audits, IRS Says

    The Internal Revenue Service closed nearly 583,000 tax return audits in fiscal year 2023, resulting in $31.9 billion of recommended additional tax after examination, the agency said Thursday in its annual data book.     

  • April 18, 2024

    Atty In Tax Fraud Must Pay Full $2.5M Per Plea Deal, Feds Say

    A former Houston attorney set to be sentenced Friday for his role in an $18 million offshore tax scheme is trying to limit the government's ability to collect $2.5 million in restitution he promised to pay in a plea agreement last year, prosecutors told a Texas federal court Thursday.

  • April 18, 2024

    IRS Seeks Advisory Council Noms, Creates Fairness Panel

    The Internal Revenue Service is seeking nominations for the council that advises the agency's commissioner, the IRS said Thursday, while the council is also launching a new subcommittee on fairness in tax administration.

  • April 18, 2024

    Transfer Pricing And Dancing: Recalling KPMG's Sean Foley

    Sean Foley, who died suddenly in September, was a devoted husband, father, brother and friend and a brilliant colleague. He was one of the world's top experts in an area of international tax known as transfer pricing, where he became the global leader of KPMG's practice.

  • April 18, 2024

    IRS Adds 2nd Public Hearing Day On Donor-Advised Regs

    The Internal Revenue Service has added a second, telephone-only public hearing in May on proposed regulations on excise taxes on certain taxable distributions made from donor-advised funds, the agency announced Thursday.

  • April 17, 2024

    'I Am Mad': Client Regrets Trusting Atty Accused Of Tax Fraud

    Emotions ran high Wednesday in a North Carolina federal courtroom as former clients unwittingly roped into an alleged tax fraud scheme took the stand, one of whom was openly exasperated at learning he'd been misled by the two attorneys and an insurance agent who are on trial.

  • April 17, 2024

    Damages Still Possible In Lease Tax Reimbursement Row

    A Court of Federal Claims judge has ruled that the General Services Administration could unilaterally adjust the real estate tax reimbursement methodology under a lease for the Defense Health Agency's headquarters building, but the building owner may still be owed damages.

  • April 17, 2024

    EV Tax Credit Restrictions, Trade Bills Advance In House

    The House Ways and Means Committee advanced several trade bills Wednesday that would impose more restrictions for new electric vehicles to qualify for a federal tax credit, assert congressional authority in agreements with foreign governments, and renew the country's largest and oldest trade preferences program.

  • April 17, 2024

    $22B In Earned Income Tax Credits Wrongly Handed Out

    The U.S. Treasury Department improperly allowed an estimated $22 billion in earned income tax credits during fiscal year 2023, according to a report made public Wednesday by the Government Accountability Office.

  • April 17, 2024

    EmblemHealth Pushes IRS To Hand Over $6.7M Tax Refund

    Not-for-profit insurance company EmblemHealth asked a New York federal court Wednesday to grant it a nearly $6.7 million tax refund, saying the Internal Revenue Service left a voicemail accepting its refund claim in February but still hasn't delivered the money.

  • April 17, 2024

    Utility Energy Subsidies Not Eligible For Credits, IRS Says

    A taxpayer may not claim certain clean energy credits for the amount of a subsidy provided by a public utility for the purchase or installation of energy conservation measures, the Internal Revenue Service said Wednesday.

  • April 17, 2024

    Tax Court Rejects NJ Lawyer's Protest Of IRS Collection

    The Internal Revenue Service didn't abuse its discretion when it denied a New Jersey lawyer's request for collection alternatives, the U.S. Tax Court ruled Wednesday.

Expert Analysis

  • Demystifying IRS' Claims Of $851B Return On Investment

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    The IRS' recently released analysis, estimating a $851 billion return on the government’s $80 billion investment in the agency, represents a huge increase over its 2022 estimate and that of the Congressional Budget Office and may be best viewed as a best-case scenario, says Joyce Beebe at the Baker Institute.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • A Proposal For Fairer, More Efficient Innocent Spouse Relief

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    Adding a simple election to the current regulatory framework for innocent spouse claims would benefit both taxpayers and the Internal Revenue Service by alleviating the undue burdens placed on those the program was intended to help and improving agency collections in such cases, says Laurie Kazenoff at Kazenoff Tax.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • Proposed Hydrogen Tax Credit Regs May Be Legally Flawed

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    While the recently proposed regulations for the new clean hydrogen production tax credit have been lauded by some in the environmental community, it is unclear whether they are sufficiently grounded in law, result from valid rulemaking processes, or accord with other administrative law principles, say Hunter Johnston and Steven Dixon at Steptoe.

  • Navigating ACA Reporting Nuances As Deadlines Loom

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    Stephanie Lowe at Liebert Cassidy walks employers through need-to-know elements of Affordable Care Act reporting, including two quickly approaching deadlines, the updated affordability threshold, strategies for choosing an affordability safe harbor, and common coding pitfalls.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • Why Biz Groups Disagree On Ending Chevron Deference

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    Two amicus briefs filed in advance of last month's U.S. Supreme Court oral arguments in Loper Bright Enterprises v. Raimondo highlight contrasting views on whether the doctrine of Chevron deference promotes or undermines the stable regulatory environment that businesses require, say Wyatt Kendall and Sydney Brogden at Morris Manning.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Look Ahead For The Electric Vehicle Charging Industry

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    This will likely be an eventful year for the electric vehicle market as government efforts to accelerate their adoption inevitably clash with backlash from supporters of the petroleum industry, say Rue Phillips at SkillFusion and Enid Joffe at Green Paradigm Consulting.

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

  • Planning A Defense As IRS Kicks Off Sports Losses Campaign

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    Sports team owners and partnerships face potential examination under the Internal Revenue Service’s recently announced sports industry losses campaign, and should be preparing to explain what drove their reported losses and assembling documentation to support their tax return positions and accounting methods, say Sheri Dillon and Jennifer Breen at Morgan Lewis.

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