Federal

  • September 25, 2024

    Puerto Rico Seeking Input On Implementing Global Min. Tax

    Puerto Rico's Department of the Treasury is looking for public comments regarding possible implementation of the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities.

  • September 24, 2024

    1st Circ. Affirms Tossing Of IRS Crypto Doc Seizure Case

    A New Hampshire federal court correctly dismissed a bitcoin investor's claim that the IRS violated his privacy and property rights when it seized his records from the cryptocurrency exchange Coinbase, the First Circuit ruled Tuesday, agreeing that he lacked a reasonable expectation that his account information would be kept private.

  • September 24, 2024

    Estate's Value Shouldn't Be Increased, Tax Court Says

    The estate of a Maryland doctor who died in a car accident does not have to increase its taxable value by more than $19 million to account for the proceeds of two life insurance policies held by a family trust, the U.S. Tax Court ruled Tuesday.

  • September 24, 2024

    Halliburton Tardy In Contesting $35M Deduction, US Says

    A Halliburton Co. lawsuit claiming a deduction for a $35 million payoff to a foreign country must be dismissed because the company waited too long to start its action, the U.S. told a Texas federal court.

  • September 24, 2024

    IRS Received $226K In Prohibited Levy Payments In 2023

    The Internal Revenue Service collected more than $226,000 in levy payments in the 2023 fiscal year in collection due process cases that involved prohibited levies, but affected taxpayers were made whole, according to a watchdog report released Tuesday.

  • September 24, 2024

    IRS Largely Complies With Levy Requirements, TIGTA Says

    A review of more than 48,000 levies issued by IRS field collection officers from July 2022 through June 2023 found that they were mostly compliant with both legal and administrative requirements, but the Treasury Inspector General for Tax Administration identified over 1,900 instances of noncompliance, it said Tuesday.

  • September 24, 2024

    Digital Asset Rules Coming By Year's End, Treasury Atty Says

    The U.S. Treasury Department and the Internal Revenue Service intend to release rules "later this year" on additional reporting requirements for brokers of digital assets such as cryptocurrency and nonfungible tokens, a senior Treasury attorney said Tuesday.

  • September 24, 2024

    Wyden, House Dem Float Small-Biz Wage, Investment Credits

    Senate Finance Committee Chairman Ron Wyden and a House Democratic tax writer proposed legislation that would provide small-business wage and investment tax credits, according to a Tuesday statement.

  • September 24, 2024

    Abbott Seeks $24M Refund Over Transfer Pricing Adjustments

    Healthcare products giant Abbott Laboratories is owed $24.3 million for overpaid taxes after the IRS incorrectly adjusted its intragroup income and payments this year, the company told the U.S. Tax Court in a petition.

  • September 24, 2024

    Defunct Cannabis Co. Says It's Owed $1.4M In Worker Credits

    A Seattle cannabis company that was administratively dissolved this year is entitled to roughly $1.4 million in tax credits for continuing to pay employees when its business dropped off during the COVID-19 pandemic, the company's receivership estate told a Washington federal court.

  • September 24, 2024

    IRS Wary Of Adding Complexity In Min. Tax Regs, Official Says

    The IRS opted to use existing tax rules in proposed guidance to address risks that the U.S. corporate alternative minimum tax could count offshore income twice, an agency official said Tuesday, noting a more precise method would increase complexity.

  • September 24, 2024

    Treasury To Allow 3 AMT Transition Methods, Official Says

    Final rules on the new corporate alternative minimum tax are expected to adopt the proposed regulations' three ways for companies to transition to the regime, and the U.S. Treasury Department is open to other ways as well, a department official said Tuesday.

  • September 24, 2024

    Insurer Wants Quick Appeal At 8th Circ. In DOL Tax Fight

    A health insurer will seek the Eighth Circuit's review after a federal judge refused to toss a suit from the U.S. Department of Labor claiming the company unlawfully took at least $66.8 million in Minnesota state tax liability from plans it administered to pay in-network providers.

  • September 24, 2024

    Exxon Claims It Beat Weak Defense In $1.8B Tax Trial

    Exxon Mobil urged a Texas federal judge to find that it defeated what it called a scattered defense by the U.S. government during a five-day bench trial in April when the company argued for a $1.8 billion tax refund on its natural gas deal with Qatar, according to newly released filings.

  • September 24, 2024

    Applications For Low-Income Energy Tax Breaks Due In Oct.

    With more than 50,000 applications for the low-income communities clean energy bonus credit program submitted, three U.S. government agencies announced Tuesday that they will be accepting applications on a rolling basis for most categories through Oct. 10 to make sure they are timely processed.

  • September 24, 2024

    Tax Data Consent Practices Need Shoring Up, TIGTA Says

    The Internal Revenue Service must take steps to make sure any tax software companies that collect taxpayer information include consent statements that are clear about the intended purpose of the disclosure of that information and the specific recipients of it, the Treasury Inspector General for Tax Administration said.

  • September 24, 2024

    Miller & Chevalier Adds Federal Tax Expert From White & Case

    Miller & Chevalier Chtd. announced that it added a former partner at White & Case LLP to its tax controversy and litigation practice.

  • September 23, 2024

    Clean Energy Safe Harbor Applies To Direct Pay, Official Says

    The safe harbor for the bonus clean energy tax credits' domestic content rules applies to all applicable project owners, including tax-exempt entities that are eligible to get a direct cash payment of the credits, a U.S. Treasury Department attorney said Monday.

  • September 23, 2024

    Energy Bonus Credit Penalty Guidance Coming, Atty Says

    The U.S. Treasury Department will soon release additional guidance on penalties for clean energy developers that initially failed to meet the prevailing wage requirements tied to claiming bonus tax credits on their development projects, a Treasury attorney said Monday.

  • September 23, 2024

    Some Former IRS Contractors Not Purged From Systems

    An analysis of over 1,800 former Internal Revenue Service contractors who were incorrectly listed as active found a number of them still possessed network permissions, IRS hardware or identification cards giving them access to agency facilities, the Treasury Inspector General for Tax Administration said Monday.

  • September 23, 2024

    3 IRS Divisions Not Heeding Customer Surveys, TIGTA Says

    The Internal Revenue Service's Wage and Investment, Small Business/Self-Employed and Tax Exempt and Government Entities divisions are generally not using the results of their customer service surveys to make improvements to their operations, the Treasury Inspector General for Tax Administration said Monday.

  • September 23, 2024

    Couple Didn't Report Business Income, Tax Court Says

    A couple whose mortgage company managed two LLCs failed to report income received from the company, the U.S. Tax Court ruled Monday in upholding most of the roughly $1.3 million in deficiency notices for 2009 and 2010 issued by the Internal Revenue Service.

  • September 23, 2024

    The Tax Angle: Corporate Inversions, SALT Cap

    From a look at criticisms that the 2017 federal tax law failed to stop corporations from moving overseas to GOP efforts to navigate the SALT cap ahead of the November elections, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • September 23, 2024

    Sysco Allowed $324M Dividend Deduction After Varian Ruling

    Sysco Corp. can deduct $324 million in foreign dividends after agreeing with the Internal Revenue Service that a decision in a similar case brought by Varian Medical Systems resolved their dispute, the U.S. Tax Court said in an order.

  • September 23, 2024

    More Needed On Energy Tax Credit Monetization, TIGTA Says

    The Internal Revenue Service has taken steps to facilitate the sale or transfer of the Inflation Reduction Act's clean energy tax credits, but it must develop more processes to accommodate the credits, the Treasury Inspector General for Tax Administration reported.

Expert Analysis

  • The Corporate Transparency Act Isn't Dead Yet

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    After an Alabama federal court's ruling last week rendering the Corporate Transparency Act unconstitutional, changes to the law may ultimately be required, but ongoing compliance is still the best course of action for most, says George Singer at Holland & Hart.

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.

  • Employers, Prep For Shorter Stock Awards Settlement Cycle

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    Companies that provide equity compensation in the form of publicly traded stock will soon have one less day to complete such transactions under U.S. Securities and Exchange Commission and Nasdaq rules — so employers should implement expedited equity compensation stock settlement and payroll tax deposit procedures now, say attorneys at Morgan Lewis.

  • 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.

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