Federal

  • October 22, 2021

    Naturalized Citizen Asks Justices To Review FBAR Penalties

    A naturalized citizen asked the U.S. Supreme Court on Friday to decide whether the procedure used to impose penalties on him for failing to report foreign bank accounts violated his due process rights, saying case law prescribes de novo review.

  • October 22, 2021

    Watchdog Says Treasury Must Dish On Trump Tax Whistleblower

    A watchdog group has asked a D.C. federal court to direct Treasury to provide documents related to its response to an IRS whistleblower's allegation of interference in the agency's audit processes for former President Donald Trump's tax returns.

  • October 22, 2021

    Tax Partner Rejoins Venable's Estate Planning Group

    A former tax partner at Venable LLP has rejoined the firm after a stint at Fox Rothschild LLP and will serve clients in the Los Angeles office, Venable announced.

  • October 22, 2021

    Crypto Emerges As IRS Criminal Arm's Key Focus, Official Says

    Cryptocurrency has become a primary focus for the Internal Revenue Service's Criminal Investigation division because the technology offers a convenient means to hide assets and income as well as facilitate other types of criminal activities, an agency official said.

  • October 22, 2021

    Trust's Stock Transfers To Charity Not Held By Foundation

    A public charity's business holdings will not be considered to be held by a foundation, because as a charitable organization it has no shareholders, the Internal Revenue Service said in a ruling released Friday.

  • October 22, 2021

    Man Not Owed Multiple Tax Refunds, DC Circ. Affirms

    The D.C. Circuit on Friday upheld the dismissal of a man's bid for a tax refund under innocent spouse protections, saying he failed to show the U.S. Tax Court erred by tossing his case.

  • October 22, 2021

    Subpart F Extension Applies To Entire Return, IRS Says

    The extension of the statute of limitations for failure to report Subpart F income applies to a taxpayer's entire return, not just the Subpart F-related items, the IRS said in an Office of Chief Counsel memorandum released Friday.

  • October 22, 2021

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin Friday with guidelines for creating and processing 2021 substitute tax forms.

  • October 22, 2021

    Education Tax Proposal Could Be Key To College Affordability

    House Democratic lawmakers in their budget reconciliation bill aim to allow students to use both federal Pell grants and the American opportunity tax credit for their educational costs, which could ameliorate a financial shortfall for hundreds of thousands of students.

  • October 21, 2021

    Voice Bots To Start Aiding Taxpayers In 2022, IRS Official Says

    The Internal Revenue Service plans to roll out voice bots in 2022 that will help callers get answers to non-case-specific questions and possibly help them set up simple installment agreements, an agency official said Thursday.

  • October 21, 2021

    Sen. Sinema Mum On Corporate Tax Hike, Rep. Neal Says

    Senate Democrat Kyrsten Sinema of Arizona supports expanding renewable energy, family leave and child care, but remains noncommittal on raising corporate rates to fund the Democrats' Build Back Better bill, House Ways and Means Chair Richard Neal said Thursday.

  • October 21, 2021

    GILTI Rate Above 15% Harms Manufacturers, Lobby Says

    Raising the U.S.'s version of a minimum corporate tax rate on foreign profits beyond the internationally agreed-upon floor of 15%, as House Democrats have proposed, would reduce the nation's competitiveness in manufacturing, the industry's largest lobby said.

  • October 21, 2021

    IRS Says Inventory In Transit Can Qualify For QOZ Program

    Inventory isn't barred from being considered qualified opportunity zone inventory by virtue of being transported, the Internal Revenue Service said in an updated set of FAQs.

  • October 21, 2021

    Rocky Road Ahead For Implementing Global Tax Deal In US

    President Joe Biden's administration hasn't committed to a specific procedural path for implementing aspects of a global corporate tax overhaul, which could face pushback from Republican lawmakers who say the changes would require a supermajority vote in the Senate.

  • October 21, 2021

    Couple Must Return $1.3M Foreign Tax Refund, Gov't Says

    A Texas federal court should order the return of a couple's nearly $1.3 million tax refund, which they obtained erroneously by claiming foreign tax credits through a partnership, according to a government complaint filed Thursday.

  • October 21, 2021

    IRS Summons On Spanish Bank Must Be Quashed, Court Told

    An Internal Revenue Service summons issued to a Spanish bank for information on tax liabilities claimed against a man in the Dominican Republic should be quashed because he isn't subject to U.S. taxation, he told a Florida federal court.

  • October 21, 2021

    All Members Of Tax-Exempt LLCs Must Qualify, IRS Says

    A limited liability company must require that all its members be tax-exempt organizations, governmental units or extensions of such a unit to be recognized as tax-exempt, the Internal Revenue Service said Thursday.

  • October 21, 2021

    IRS Names Calendar Administrators For 21 Tax Court Sessions

    The Internal Revenue Service named calendar administrators for 21 U.S. Tax Court sessions in January and February, according to a notice released Thursday.

  • October 20, 2021

    Senate GOP Blasts Budget's Permanent ACA Credit Expansion

    Republican members of the Senate Finance Committee said Wednesday that the expanded health care subsidies proposed under the Democrats' Build Back Better Act would be expensive tax incentives that would raise unemployment and increase federal red ink.

  • October 20, 2021

    Tax Court Says Man Owes Nearly $11K In Additions To Tax

    A Colorado man is liable for nearly $11,000 in additions to tax for not filing or paying his 2016 income taxes on time or paying estimated taxes for that year, the U.S. Tax Court said Wednesday.

  • October 20, 2021

    'Potty LLC' Pandemic Loan Adds To IndyCar Exec's Rap Sheet

    An IndyCar Grand Prix event promoter who is slated to plead guilty to fraud and tax charges was hit with new allegations Wednesday that he scored $676,000 in pandemic relief funds through purported business entities including "Now Potty LLC," with the money allegedly used for personal expenses like luxury hotels and a 3-carat diamond ring.

  • October 20, 2021

    Policy Groups, 20 States Back Ohio's ARPA Fight In 6th Circ.

    Three limited-government advocacy organizations and 20 states urged the Sixth Circuit to uphold an injunction barring the federal government from enforcing a law against Ohio that requires states to return coronavirus aid used to offset tax cuts.

  • October 20, 2021

    Pension Plan Segment Rates Drop Again In October

    All three segment rates for calculating pension plan funding decreased again in October, the Internal Revenue Service said Wednesday.

  • October 20, 2021

    Pot Business Owner Gets 4 Years For Illegal Delivery Service

    A Massachusetts federal judge has sentenced the owner of a multimillion-dollar pot business to four years in prison for running an illegal shop and dodging taxes.

  • October 20, 2021

    9th Circ. Urged To Rethink $3.7M Tax Debt Ruling

    A Guam man has asked the Ninth Circuit to reconsider its ruling that the territory properly assessed $3.7 million in taxes against him before seeking to foreclose on his properties, arguing testimony failed to prove the assessment was timely.

Featured Stories

  • Education Tax Proposal Could Be Key To College Affordability

    David van den Berg

    House Democratic lawmakers in their budget reconciliation bill aim to allow students to use both federal Pell grants and the American opportunity tax credit for their educational costs, which could ameliorate a financial shortfall for hundreds of thousands of students.

  • Rocky Road Ahead For Implementing Global Tax Deal In US

    No Photo Available

    President Joe Biden's administration hasn't committed to a specific procedural path for implementing aspects of a global corporate tax overhaul, which could face pushback from Republican lawmakers who say the changes would require a supermajority vote in the Senate.

  • Dems Eye Manufacturing Tax Breaks To Boost Budget Support

    Alan K. Ota

    Congressional Democrats are promoting incentives for domestic production of semiconductors, green energy technology and other items as a way to broaden support for a streamlined version of the budget reconciliation bill containing President Joe Biden's domestic agenda.

Expert Analysis

  • The Infrastructure Bill Should Not Target Cryptocurrency

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    Congress should excise a provision in the pending infrastructure bill that would require anyone who accepts $10,000 in cryptocurrency for goods or services to report the transferring party's personal information to the Internal Revenue Service — this would be unnecessary, ill-advised and possibly unconstitutional, says James Burnham at Jones Day.

  • Opportunity Zone Regulations Require More Fine Tuning

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    Problems with the latest revisions to the qualified opportunity zone investment rules reinforce a recurring theme of regulatory hiccups that may prevent investors and communities from actualizing the program's potential benefits, unless we have more guidance, says Mitchell Goldberg at Berger Singerman.

  • Preserving Disgorgement Tax Deductibility In SEC Settlements

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    The U.S. Securities and Exchange Commission recently added language to its enforcement orders that could affect a settling party's ability to deduct certain disgorgement payments, but proper planning can help them satisfy Internal Revenue Service prerequisites, say attorneys at Sidley.

  • How The Global Tax Agreement Could Backfire For Biden

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    If the $3.5 trillion spending package fails, the federal tax code will not conform to the recent 15% global minimum tax agreement spearheaded by the U.S., which would embarrass the Biden administration and could lead to retaliatory tax measures by other nations, says Alex Parker at Capitol Counsel.

  • Tax-Exempt Orgs, Beware This 403(b) Plan Compliance Pitfall

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    A recent Internal Revenue Service publication puts 403(b) retirement plan sponsors on notice about a contribution aggregation compliance failure often identified in audits of government and tax-exempt entities, but risk can be minimized by ensuring plan documents and communications address the issue directly, say Greg Needles and Michael Gorman at Morgan Lewis.

  • Pandora Papers Reveal Need For Greater Tax Enforcement

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    The recent Pandora Papers leak is a reminder of the importance of transparency laws and proper funding for enforcement efforts against tax evasion as bad actors increasingly operate in the shadows, says Daren Firestone and Kevin Crenny at Levy Firestone.

  • Telehealth Providers Must Beware Of Fraud As Industry Grows

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    A recent fraud charge against a telehealth executive highlights the rise we're seeing in telefraud scams during the industry's pandemic growth, and there are some steps that all health providers should take to stay clear of potentially illegal arrangements, says LaTawnda Moore at Dinsmore.

  • Parsing New Int'l Tax Reporting Rules For Pass-Throughs

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    Attorneys at Grant Thornton unpack the Internal Revenue Service’s new pass-through entity reporting requirements for international tax matters and the accompanying guidance for penalty relief, and suggest how companies should prepare for what may be the most significant change to the partnership compliance function in decades.

  • A Look At Global Tax Enforcement Developments: Part 2

    Excerpt from Practical Guidance
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    Sean Craig at LexisNexis examines recent investigations by the Joint Chiefs of Global Tax Enforcement and their impact on U.S. taxpayers, as well as the growing significance of transfer pricing disputes and policies for future enforcement.

  • A Look At Global Tax Enforcement Developments: Part 1

    Excerpt from Practical Guidance
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    Sean Craig at LexisNexis looks at how international initiatives, such as the Joint Chiefs of Global Tax Enforcement, are addressing cryptocurrency-related tax evasion, and how the COVID-19 pandemic and increasing demands for governmental welfare programs are driving global tax policy.

  • What The Judiciary's Font Recommendations Can Teach Us

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    The D.C. Circuit's recent soft prohibition on Garamond and the ensuing debates about courts' font preferences should serve as a helpful reminder of a larger point — every departure from convention in legal writing carries some level of risk, says Spencer Short at Stradley Ronon.

  • 2 Income Tax Loopholes Congress Should Close

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    To raise revenue for proposed infrastructure improvements and make the tax law fairer, the Biden administration and Congress should close an income tax loophole that allows an asset owner to bypass capital gains tax upon death and another that essentially allows taxpayers to make tax‑free gifts to grantor trusts, says Richard Kinyon at Shartsis Friese.

  • High Points Of IRS' New Employee Retention Credit Guidance

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    Dana Fried at CohnReznick examines recent IRS guidance on the employee retention credit, which includes a helpful new rule enabling more employers to qualify for the credit by allowing them to exclude some pandemic relief from gross receipts, but its exclusion of related individuals' wages from qualified wages for certain corporate owners is disappointing.