Federal
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July 10, 2024
IRS Issues Electricity Credit Reference Price For Wind
The Internal Revenue Service released a 2024 reference price for determining the availability of the renewable electricity production credit for wind energy facilities in a notice issued Wednesday.
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July 10, 2024
House Dems Seek IRS Review Of Groups' Church Status
A group of House Democratic lawmakers asked the Internal Revenue Service to review the tax exemptions of conservative advocacy groups that they contend have improperly received tax-exempt status as churches, according to a letter released Wednesday.
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July 10, 2024
5th Circ. Told 'Pay To Litigate' Rule Doesn't Bar Refund Suit
A couple arguing the IRS failed to apply their tax overpayments to deficiencies claimed by the agency asked the Fifth Circuit to reverse a lower court's dismissal of their suit on the grounds that they hadn't paid their bill, saying the decision effectively asks them to pay twice.
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July 09, 2024
IRS Funding At Stake In 2025 Tax Cut Negotiations
Lawmakers are girding for battle over the soon-to-expire individual tax cuts in the 2017 tax law, and IRS funding will be central to the debate at a time when the agency may be in need of additional resources due to changes in law.
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July 09, 2024
House Panel OKs Tax Breaks For More Education Expenses
The House Ways and Means Committee sent several education-related tax bills to the full House of Representatives on Tuesday, including legislation that would make additional elementary and secondary school expenses eligible for tax-advantaged education savings accounts.
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July 09, 2024
Dems Request Special Counsel To Probe Justice Thomas Gifts
Two Democratic senators have asked U.S. Attorney General Merrick Garland to appoint a special counsel to investigate whether U.S. Supreme Court Justice Clarence Thomas' failure to disclose various gifts received during his tenure on the high court amounts to chargeable ethics violations or tax crimes.
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July 09, 2024
IRS Errors Foul $51M Levy, Calif. Man's Estate Tells Tax Court
The Internal Revenue Service made a slew of errors in determining a California man's estate faces a $46.2 million estate tax deficiency and a $4.6 million penalty, the estate's executor told the U.S. Tax Court.
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July 09, 2024
Veriwave Telco Faces FCC Action Over 'Tax Relief' Robocalls
The Federal Communications Commission is moving to block robocalls about purported "tax relief" programs from a Delaware-based telecommunications company, announcing in an order Monday that Veriwave Telco had another 14 days to demonstrate compliance with the agency's rules or risk having downstream providers cut its traffic.
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July 09, 2024
Senate Tax Panel To Consider 3 Tax Court Nominees
The Senate Finance Committee is scheduled to hold a hearing Wednesday to consider three U.S. Tax Court judge nominees, Sen. Ron Wyden, D-Ore., the panel's chairman, said in a statement Tuesday.
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July 09, 2024
5 Firms Steer $513M Ryan-Altus Cross-Border Tax Deal
Dallas-based tax services and software provider Ryan said Tuesday it has inked a deal to acquire the property tax business of Altus Group Ltd. for CA$700 million ($513.4 million), enlisting three firms to assist on a deal that will expand its footprint in Canada, the U.S. and the U.K.
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July 09, 2024
Medical Office Manager Gets 5 Years For Tax, Mail Fraud
The former office manager of an Illinois medical practice was sentenced to five years in federal prison and ordered to pay $3 million in restitution — most of it to his former employer — after admitting to filing a false tax return and stealing from the practice.
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July 09, 2024
Companies Deliberate Pillar 2 Prep After OECD Signals Relief
Multinational corporations facing the Pillar Two global minimum tax in various jurisdictions are weighing comments from OECD officials that hint at more relief as they decide whether to prepare to comply with the rules now or gamble on the prospects of permanent safe harbors.
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July 08, 2024
IRS Details Steps To Take For Scam-Credit Letter Recipients
The Internal Revenue Service published a fact sheet Monday to help taxpayers respond to letters from the agency identifying tax returns as requiring authentication after the agency said that inaccurate advice from social media and a series of scams led to an increase in questionable refund claims.
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July 08, 2024
Continued Worker Credit Freeze Could Push Cos. To Court
More employers tired of waiting for the Internal Revenue Service to process their employee retention credit refund claims could decide to go to court to force the government to review their submissions following the IRS announcing that a moratorium on processing new claims would remain in place.
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July 08, 2024
Ways And Means To Vote On Section 529 Tax Bills
The House Ways and Means Committee is scheduled to vote Tuesday on several education-related tax bills, including legislation that would make additional elementary and secondary school expenses eligible for tax-advantaged education savings accounts.
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July 08, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin reported recently issued guidance on exceptions to the 10% additional tax for people who make permissible early retirement account withdrawals for emergency personal expenses and for victims of domestic abuse.
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July 08, 2024
IRS Failed To Analyze Storage Costs, TIGTA Says
The IRS didn't negotiate with the federal agency that stores its paper tax records, instead agreeing to pay a new monthly rate of $2.8 million without doing the required cost analysis, the Treasury Inspector General for Tax Administration said in a report released Monday.
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July 08, 2024
Top International Tax Cases Of 2024: Midyear Report
With a U.S. Supreme Court decision affirming a key 2017 tax provision on repatriation, millions of dollars in FBAR penalties upheld and a French ruling confirming the U.S. government's access to foreign bank accounts, the IRS stacked up important court victories on international enforcement in the first half of 2024. Here, Law360 reviews those and other significant rulings from the past six months.
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July 08, 2024
Atty Drops FOIA Suit Against IRS Over Partnership Audits
An Ohio attorney agreed to drop a public records suit against the Internal Revenue Service that had sought documents related to partnership audits after the agency released thousands of records he had requested, according to a D.C. federal court filing.
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July 08, 2024
IRS Must Produce Audit Records, Waste Co. Says
Garbage-hauling giant Waste Management Inc. asked a D.C. federal court to force the IRS to produce its tax files on the company for 2017, including audit records, saying the agency has been dragging its feet in violation of the Freedom of Information Act.
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July 08, 2024
Feds Seize $63M LA Estate Tied To Armenian Bribe Probe
The U.S. Department of Justice said Monday that it will seize a $63 million Los Angeles estate that it claims was bought with bribe payments for the family of a former Armenian government official.
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July 05, 2024
How Reshaped Circuit Courts Are Faring At The High Court
Seminal rulings from the U.S. Supreme Court's latest term will reshape many facets of American society in the coming years. Already, however, the rulings offer glimpses of how the justices view specific circuit courts, which have themselves been reshaped by an abundance of new judges.
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July 05, 2024
Breaking Down The Vote: The High Court Term In Review
The U.S. Supreme Court's lethargic pace of decision-making this term left the justices to issue a slew of highly anticipated and controversial rulings during the term's final week — rulings that put the court's ideological divisions on vivid display. Here, Law360 takes a data dive into the numbers behind this court term.
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July 05, 2024
High Court Flexes Muscle To Limit Administrative State
The U.S. Supreme Court's dismantling of a 40-year-old judicial deference doctrine, coupled with rulings stripping federal agencies of certain enforcement powers and exposing them to additional litigation, has established the October 2023 term as likely the most consequential in administrative law history.
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July 05, 2024
The Sharpest Dissents From The Supreme Court Term
The U.S. Supreme Court's session ended with a series of blockbuster cases that granted the president broad immunity, changed federal gun policy and kneecapped administrative agencies. And many of the biggest decisions fell along partisan lines.
Expert Analysis
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SVB Collapse Reinvigorates Bank Accounting Debate
Silicon Valley Bank's sudden collapse revives questions over whether fair value or amortized cost accounting is the most appropriate for banks' financial reporting — a controversy that's crucial for understanding what information could have helped market participants better understand SVB's financial condition, say consultants at Analysis Group.
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Brownfield Renewables Guidance Leaves Site Eligibility Murky
Recent IRS guidance sheds some light on the Inflation Reduction Act's incentives for renewable energy development on contaminated sites — but the eligibility of certain sites for brownfield status remains uncertain, say Megan Caldwell and Jon Micah Goeller at Husch Blackwell.
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Get Ready For IRS Criminal Crackdown On Crypto
Recent developments at the IRS, from a new operating plan to the announcement of a centralized data center, signal that the agency is ramping up criminal enforcement against those using digital assets to evade tax liabilities — and given its high conviction rate, companies and individuals must prioritize compliance, say attorneys at BakerHostetler.
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NFT Tax Guidance Shows IRS Interest In Crypto Enforcement
The IRS' first ever guidance addressing the federal income tax treatment of NFTs indicates the agency could take a potentially aggressive stance in enforcing U.S. tax laws in the NFT and crypto spaces, which could have a significant impact on the self-directed IRA market, say attorneys at BakerHostetler.
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Substantiation Is Key When Gifting Crypto To Charity
A recent Internal Revenue Service memorandum makes clear that the agency will require substantiation when gifting cryptocurrency to charity, even for relatively small amounts, so donors need to be aware of the important differences between crypto and typical cash donations, says Sheryl Morrison at Lathrop GPM.
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Senate Credit Suisse Report Puts Attention On Banks, Trusts
The Senate Finance Committee's recent finding that Credit Suisse violated a plea agreement struck over its role in enabling offshore tax evasion has important ramifications for banks and trusts, including how they onboard, document and report on transactions relevant to U.S. reporting requirements, say Will Barry and Ian Herbert at Miller & Chevalier.
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Seeking IRS Accountability For Faulty Microcaptive Notice
Like the taxpayers in Standard Insurances v. U.S. seeking to expand earlier wins in microcaptive insurance cases that limit IRS use of improperly obtained information, others should consider ways to hold the agency accountable and provide incentive for it to follow the law going forward, says Joshua Smeltzer at Gray Reed.
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Biden Admin. Proposals Both Encourage And Thwart EV Adoption
While the Biden administration has been aggressively focused on promoting electric vehicles from the start, its recently issued guidance on EV tax credits and its restrictive new auto emissions proposal create a sense of implementation whiplash that may frustrate manufacturers and consumers, says Levi McAllister at Morgan Lewis.
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Heed PCAOB's Warning On Proof-Of-Reserves Reports
While directed at investors, the Public Company Accounting Oversight Board's recent advisory on proof-of-reserves reports is a timely and stark warning to crypto entities, as well as their customers and accounting firms, to tread carefully in their reliance on these reports as proof of financial stability, say Patrick Bryan and Deborah Meshulam at DLA Piper.
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Cos. Should Heed IRS Warnings About Employee Tax Credit
The IRS has recently been cautioning employers claiming the pandemic-related employee retention credit to carefully review all the eligibility requirements and be wary of relying on third-party advisers regarding their qualification for the credit, say Eric Pearson and Timothy Voigtman at Foley & Lardner.
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Renewable Energy M&A Is Still Strong, Despite Challenges
The recent history of renewable energy has included ongoing supply chain issues, legislative challenges and rising interest rates — but mergers and acquisitions in the sector are expected to remain robust this year, fueled by growing demand and Inflation Reduction Act incentives, say consultants at FTI Consulting.
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Issues And Opportunities In Hydrogen Fuel Cell Development
A variety of tax incentives, funding opportunities and state programs have the potential to provide value across the hydrogen fuel cell business chain and alleviate existing hurdles, establishing a stronger business case for the continued development of hydrogen infrastructure, says Pamela Wu at Morgan Lewis.
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IRS Green Energy Tax Credit Notice Provides Needed Clarity
Recent IRS guidance clarifying how the government will determine energy community locations for purposes of bonus clean energy tax credits should help resolve risk allocation disagreements among financing parties and parties to merger and acquisition transactions, say Casey August and Paul Gordon at Morgan Lewis.