Federal

  • March 15, 2024

    Direct Hit On Tax Regs Unlikely If Justices Ditch Chevron

    A decision from the U.S. Supreme Court later this year on two cases challenging the so-called Chevron doctrine, which gives federal agencies wide latitude to interpret ambiguous laws, isn't likely to immediately affect tax regulations.

  • March 15, 2024

    Taxation With Representation: Freshfields, Kirkland

    In this week's Taxation with Representation, AstraZeneca acquires Amolyt Pharma, XCF Global Capital goes public and EQT Corp. merges with Equitrans Midstream Corp.

  • March 15, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, featuring updated tax treatment for certain public utility debt.

  • March 14, 2024

    Tupperware Pans Investor Suit Over 'Small' Accounting Errors

    Tupperware wants to dismiss a proposed class action accusing it of damaging investors by knowingly issuing misleading financial reports, arguing the suit fails to show it acted with ill intent when releasing the allegedly inaccurate information to the public, and that its restatements did not actually hurt shareholders.

  • March 14, 2024

    Man Who Hid Income Had Fraudulent Intent, Tax Court Says

    An Arizona man who hid self-employment income from the Internal Revenue Service in a sham partnership of family trusts owes additional taxes for fraudulently failing to file returns, the U.S. Tax Court ruled Thursday.

  • March 14, 2024

    Ariz. Reps. Urge IRS To Scrap Tax On State Rebates

    Arizona's one-time state tax rebates should not be subject to federal income tax, members of the state's congressional delegation told the Internal Revenue Service, saying the rebates should be exempt under agency guidance issued last year.

  • March 14, 2024

    Israel Tax Authority Claims Owner Of US Biz Underpaid Tax

    A Jerusalem man is suspected of failing to report 50 million Israeli new shekels ($13.7 million) of his income from companies in Israel and abroad, the Israel Tax Authority said Thursday.

  • March 14, 2024

    Absent Returns Justify Rejecting Offers, Tax Court Rules

    The Internal Revenue Service properly sustained a collection action against a Maryland man with a record of failing to file his income tax returns, the U.S. Tax Court ruled Thursday.

  • March 14, 2024

    8th Circ. Questions IRS Ax Of Engineering Co.'s R&D Credit

    Eighth Circuit judges probed claims by the IRS that a Minnesota engineering company didn't qualify for $276,000 in research and development tax credits, asking during oral arguments whether the agency may have overlooked the inherently specialized nature of the company's engineering work.

  • March 14, 2024

    Tax Court Judge John O. Colvin, Ex-Chief, Dead At 77

    John O. Colvin, a senior judge of the U.S. Tax Court, has died, the court announced in a news release Thursday.

  • March 14, 2024

    IRS' Signals On Economic Substance Doctrine Draw Scrutiny

    The Internal Revenue Service's recent legal success asserting a doctrine to invalidate transactions in tax law enforcement matters may embolden the government to broaden that argument's reach, and lawyers are concerned it doesn't properly apply to transfer pricing matters.

  • March 13, 2024

    Siemens Asks Tax Court To Toss $1.2B IRS Bill

    A U.S. subsidiary of German technology company Siemens is pushing the U.S. Tax Court to throw out $1.16 billion in tax deficiencies and penalties the IRS has imposed, saying the agency relied on invalid rules in denying a deduction.

  • March 13, 2024

    Tax Court Calls CPA's Deduction Testimony 'Contradictory'

    A California certified public accountant cannot deduct nearly $600,000 in assorted expenses — including more than $437,000 in net operating losses — after providing "contradictory" testimony and failing to present credible evidence, the U.S. Tax Court ruled Wednesday.

  • March 13, 2024

    Actuary Board Looks To End In-Person Learning Requirement

    The Joint Board for the Enrollment of Actuaries has proposed eliminating a requirement that continuing education programs be attended in person, the Internal Revenue Service said Wednesday.

  • March 13, 2024

    Deputy To Take Over As IRS Criminal Investigation Chief

    The deputy chief of the Internal Revenue Service's Criminal Investigation division will take the helm of the division when its current chief steps down April 6, the agency said Wednesday.

  • March 13, 2024

    2nd Circ. Affirms Barring Of Man's Appeal In Small Tax Case

    The Second Circuit rejected a taxpayer's attempt to resurrect his dispute over a tax deficiency Wednesday, affirming that a statute prohibits appeals of U.S. Tax Court decisions in certain cases involving low dollar amounts.

  • March 13, 2024

    6th Circ. Told Woman Helped Life Partner Avoid $3M In Taxes

    The federal government justifiably sold off the property of a woman who paid for it with money from her dead long-term life partner, the U.S. government told the Sixth Circuit on Wednesday, saying the purchase helped her partner skirt more than $3 million in tax liabilities.

  • March 13, 2024

    JCT Indicates Pillar 1 Is Bad Deal For US, GOP Lawmakers Say

    An analysis of the Organization for Economic Cooperation and Development's Pillar One taxing rights overhaul by congressional scorekeepers makes clear the plan should not receive U.S. support because it would disadvantage U.S. multinationals and federal tax revenue, Republican leaders of Congress' taxwriting committees said Wednesday.

  • March 13, 2024

    Longtime Stradley Ronon Tax Partner Joins Grant Thornton

    Following more than a quarter-century practicing law with Stradley Ronon Stevens & Young LLP, longtime tax attorney Chris Scarpa decided to change career paths, joining accounting firm Grant Thornton LLP.

  • March 13, 2024

    Ex-Super Bowl Champ Owes $15M Tax After Default, US Says

    A California federal court should issue a default judgment for $15.5 million in federal income taxes against four-time Super Bowl champion Bill Romanowski and his wife, the U.S. government argued, saying the couple has failed to participate in a collection case against them.

  • March 13, 2024

    IRS Art Appraisal Panel Schedules April Meeting

    The Internal Revenue Service committee that appraises art for tax purposes will hold its next meeting April 17, the agency said Wednesday.

  • March 12, 2024

    IRS Mulling Partnership Foreign Currency Rules, Official Says

    The Internal Revenue Service will likely propose rules that would provide additional guidance to partnerships for determining taxable income or loss with respect to certain affiliates that conduct business in a foreign currency, an agency official said Tuesday.

  • March 12, 2024

    NC Software Execs Convicted Of Payroll Tax Crimes

    Two former software executives in North Carolina were convicted Tuesday of failing to pay hundreds of thousands of dollars in employment taxes, but were absolved of charges that they lied on their individual tax returns, bringing to a close their five-day trial in Charlotte's federal courthouse.

  • March 12, 2024

    IRS Fully Opens Direct E-File Pilot Program In 12 States

    The Internal Revenue Service's free electronic tax-return filing pilot program is now open to all 19 million eligible taxpayers in the 12 states where people can participate, agency Commissioner Daniel Werfel told reporters Tuesday.

  • March 12, 2024

    Calif. Man Agrees To Pay Nearly $500K In FBAR Penalties

    A California man agreed to pay almost $500,000 in penalties, late fees and interest for failing to report his bank accounts in the Bahamas on his tax forms, according to a stipulated order entered by a California federal court.

Expert Analysis

  • IRS Announcement Will Aid Cos. In Buyback Tax Planning

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    Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Mallory Opinion Implicitly Overturned NC Sales Tax Ruling

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    The U.S. Supreme Court recently declined to review Quad Graphics v. North Carolina Department of Revenue, but importantly kicked the legs from under Quad's outcome a week later, stating in its Mallory decision that the high court has the prerogative to overrule its own decisions, says Richard Pomp at the University of Connecticut.

  • 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.

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