Federal

  • June 03, 2024

    Vanguard Investors Want Class Cert. In Tax Liability Fight

    Investors accusing Vanguard and its top brass of violating its fiduciary duties by triggering a sell-off of assets in target retirement funds in an attempt to lower fees, leaving smaller investors with massive tax bills, asked a Pennsylvania federal court to certify them as a class.

  • June 03, 2024

    Taxes Take Center Stage In Pot Industry Amid Fed. Policy Shift

    The federal government's move to loosen restrictions on cannabis is expected to trigger a wave of mergers and acquisitions structured as asset deals in the industry, especially among struggling retail operations willing to restructure in order to raise profits and lower their tax liabilities.

  • June 03, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin, which included an updated list of procedures for taxpayer-initiated requests for changes in methods of accounting.

  • June 01, 2024

    Blockbuster Summer: 10 Big Issues Justices Still Must Decide

    As the calendar flips over to June, the U.S. Supreme Court still has heaps of cases to decide on issues ranging from trademark registration rules to judicial deference and presidential immunity. Here, Law360 looks at 10 of the most important topics the court has yet to decide.

  • May 31, 2024

    3M Tells 8th Circ. IRS Used Invalid Regs For $24M Allocation

    Multinational conglomerate 3M reiterated Friday its bid for the Eighth Circuit to reverse a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from the company's Brazilian affiliate, arguing the agency's adjustment relied on substantively invalid regulations.

  • May 31, 2024

    IRS Guidance Narrows Spinoffs Available For Preapproval

    Recent IRS guidance limiting the types of spinoff transactions that revenue officials will approve as tax-free ahead of time leaves practitioners and corporations to determine whether to pursue certain intercompany reorganizations without the agency's blessing.

  • May 31, 2024

    Ex-UBS Exec Owes $4.7M In FBAR Penalties, Court Told

    A former CEO of Swiss bank UBS' North American group faces a $4.7 million tax bill that the U.S. claims is due because he did not report his foreign bank accounts or assets, according to a suit filed in Connecticut federal court.

  • May 31, 2024

    IRS Can Seek Tax Beyond Bankruptcy Deal, 11th Circ. Affirms

    A deal between the IRS and an Alabama real estate developer to settle his tax debt for $2 million during Chapter 11 bankruptcy proceedings wasn't final, and the agency can demand additional taxes from him, the Eleventh Circuit affirmed Friday.

  • May 31, 2024

    US, Bulgaria Sign Country-By-Country Reporting Agreement

    The U.S. and Bulgaria signed an agreement Friday on the automatic exchange of country-by-country reports between the nations, Bulgaria's Ministry of Finance said.

  • May 31, 2024

    IRS Memo Backs Tax For Noninsurance Payments To Captives

    When the IRS determines that a company's payments to its foreign captive insurer were not for actual insurance, the agency can assert a 30% tax on the captive for the income it received under the arrangement, the IRS chief counsel's office said in a memo released Friday.

  • May 31, 2024

    Texan's Estate Owes $3.4M For Missed Tax Pays, Court Told

    A Texas man's estate owes over $3.4 million in unpaid taxes, interest and penalties because of missed payments stretching back over a decade, even after multiple extensions were granted to the two executors, the government told a federal district court.

  • May 31, 2024

    5 Tax Bills To Watch This Summer

    House and Senate lawmakers return to Washington, D.C., on Monday, where several tax-related bills await them in both chambers, including a stalled package that would restore business tax breaks and expand the child tax credit. Here, Law360 takes a look at five bills that could move through Congress this summer.

  • May 31, 2024

    Calif. Man Owes 6 Years Of FBAR Penalties, IRS Tells Court

    A Californian has failed to pay foreign bank account reporting penalties he was assessed that were tied to a business he owed in Mexico for six years, the Internal Revenue Service told a federal court.

  • May 31, 2024

    Fuel Producers Should Apply ASAP For Tax Credit, IRS Says

    Fuel producers hoping to start claiming the clean fuel production credit as soon as January should register with the Internal Revenue Service by July 15, the agency said Friday, warning that registration applications made after that date are less likely to go through in time.

  • May 31, 2024

    IRS Delays Deadlines For Mass. Taxpayers Hit By 2023 Storms

    Certain Massachusetts taxpayers impacted by severe storms and flooding that hit the state Sept. 11 now have until July 31 to file various individual and business tax returns and make payments, the Internal Revenue Service said Friday.

  • May 31, 2024

    Taxation With Representation: Cravath, Cleary, Fried Frank

    In this week's Taxation With Representation, T-Mobile buys United States Cellular Corp.'s wireless operations, Energy Transfer plans to buy WTG Midstream, ConocoPhillips acquires Marathon Oil, and Goldman Sachs Alternatives raises over $20 billion for its direct lending strategy.

  • May 30, 2024

    Chicago Kiosk Salesman Gets 1 Year For Filing False Returns

    An electronic-sweepstakes kiosk salesman from Chicago was sentenced to a year in prison for filing false tax returns that included more than $500,000 in inflated business expenses, according to Illinois federal court documents.

  • May 30, 2024

    IRS Adds 16 Tax Court Sessions To Calendar

    The Internal Revenue Service announced 16 U.S. Tax Court sessions in September and October and named calendar administrators for the sessions in a notice released Thursday.

  • May 30, 2024

    Tax Court Nixes $30M In Conservation Easement Deductions

    The U.S. Tax Court upheld on Thursday the IRS' rejection of more than $30 million in charitable contribution deductions for Alabama conservation easements for partnerships acting as test cases for a larger group that took $187 million in deductions.

  • May 30, 2024

    Tax Court Tosses Whistleblower Award Contest

    The U.S. Tax Court ruled Thursday that it cannot review a woman's roughly $1,700 whistleblower award from the Internal Revenue Service because it does not meet a threshold for mandatory awards.

  • May 30, 2024

    IRS Names New Chief Taxpayer Experience Officer

    The Internal Revenue Service has chosen an adviser in its Transformation and Strategy Office to serve as the agency's new chief taxpayer experience officer, according to a statement Thursday.

  • May 30, 2024

    Later Pillar 1 Due Date Set For June As Tax Talks Wrap Up

    Diplomats agreed this week to finalize a treaty for reallocating some of large companies' tax payments and setting standards to simplify some transfer pricing in lower-income countries by June 30 after having missed a March deadline, according to a statement published Thursday by the OECD.

  • May 30, 2024

    Ex-KPMG Manager Joins Davis+Gilbert As Tax Partner

    A former managing director at KPMG has joined New York law firm Davis+Gilbert LLP as a tax partner in its corporate and transactions practice, Davis+Gilbert announced.

  • May 30, 2024

    Black Business Owners Sue Over Impact Of Transparency Act

    The Corporate Transparency Act creates unique burdens on businesses owned by people of color, immigrants and other marginalized groups, the Black Economic Council of Massachusetts and several company owners said in the latest legal challenge to the anti-money laundering law.

  • May 30, 2024

    Russian Gas Ex-CFO Says $44M FBAR Penalty Is Excessive

    The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks told a Florida federal court that the $44 million in foreign account reporting penalties the government is seeking is illegally high.

Expert Analysis

  • States Must Align Distribution Age Rules With Secure 2.0

    Author Photo

    To prevent unintended escheatment of retirement benefits, states will need to undertake legislative efforts to amend unclaimed property standards that conflict with the Secure 2.0 Act's required minimum distribution age increases, says Michael Giovannini at Alston & Bird.

  • The IRS' APA Rulemaking Journey: There And Back Again

    Author Photo

    Attorneys at Dentons examine recent challenges in which taxpayers successfully argued Internal Revenue Service rulemaking was invalid under the Administrative Procedure Act, how tax exceptionalism and U.S. Supreme Court regulatory deference prompted such challenges, and similar challenges the agency will likely face following this line of cases.

  • Tax Court Ruling Should Allay Post-Boechler Concerns

    Author Photo

    An unusually long U.S. Tax Court ruling in Hallmark Research Collective v. Commissioner, confirming that deficiency deadlines are jurisdictional, should reassure practitioners concerned about the statutory time limit implications of last year's U.S. Supreme Court Boechler v. Commissioner ruling and reaffirm the vital role of the Tax Court itself, says James Creech at Baker Tilly.

  • Unpacking The Interim Guidance On New Stock Buyback Tax

    Author Photo

    The U.S. Department of the Treasury and Internal Revenue Service's recent notice on applying the newly effective excise tax on stock repurchases provides much-needed clarity on the tax's scope, which is much broader than anticipated given its underlying policy rationale, say attorneys at Eversheds Sutherland.

  • The Cryptocurrency Law And Policy Outlook For 2023

    Author Photo

    The digital asset sector saw significant losses in 2022, amid a continuing lack of guidance about how such assets should be taxed, but new government regulation, growing participation by traditional financial players and other factors should spur recovery in the coming year, says Joshua Smeltzer at Gray Reed.

  • IRS Will Use New Resources To Increase Scrutiny In 2023

    Author Photo

    The new year promises to be a busy one for the Internal Revenue Service, which is poised to apply the boost in funding provided by the Inflation Reduction Act to bolster and expand its enforcement capability, and there are four areas to watch, say attorneys at Skadden.

  • How Cos. Can Prep For Alcohol Beverage Excise Tax Changes

    Author Photo

    The Craft Beverage Modernization Act will soon undergo a transition in administration to the Alcohol and Tobacco Tax and Trade Bureau, and importers or producers should address any issues that may arise under the act, such as foreign producers not being familiar with the mechanics of the TTB, say Louis Terminello and Bradley Berkman at Greenspoon Marder.

  • New R&E Capitalization A Costly Change For Companies

    Author Photo

    Unless modified by legislation in the coming weeks, radical new capitalization rules for research and experimentation costs mean companies should brace for the loss of a major tax break starting with their 2022 tax returns, says Nancy Dollar at Hanson Bridgett.

  • Congress Is Right To Advance Comprehensive Retirement Bill

    Author Photo

    As 2022 comes to a close, Congress' move to include the Secure 2.0 Act, a comprehensive retirement bill, in its omnibus spending package will bring retirees and those nearing retirement more peace of mind regarding their 401(k)s, IRAs and pensions, while reducing red tape for employers, says Andy Banducci at the ERISA Industry Committee.

  • 10 Pre-Deal Considerations In Cross-Border M&A Transactions

    Excerpt from Practical Guidance
    Author Photo

    Sergio Galvis and Benjamin Kent at Sullivan & Cromwell discuss steps that can be taken to preemptively address important issues that acquirers of foreign businesses encounter in cross-border M&A transactions, including tax planning and political risk.

  • Clean Hydrogen Developers Should Track Incentives, Risks

    Author Photo

    Clean hydrogen project developers and investors should be aware of new funding opportunities from the U.S. Department of Energy and tax benefits under the Inflation Reduction Act, but must also guard against risks associated with new and evolving technologies, say Pamela Wu and Kirstin Gibbs at Morgan Lewis.

  • IRS Starts Clock On Energy Projects' Labor Rule Exemption

    Author Photo

    A U.S. Department of the Treasury notice published this week started the 60-day clock for clean energy projects seeking to be grandfathered from having to meet new labor requirements to qualify for enhanced tax credits, and uncertainty about how the provisions will apply should be incentive for some investors to begin construction soon, say attorneys at Eversheds Sutherland.

  • Foreign Tax Credit Proposal Is Some Help, But More Is Needed

    Author Photo

    New foreign tax credit regulations proposed by the U.S. Treasury Department provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the 2021 final foreign tax credit regulations, but the final regulations are still harmful to many taxpayers, making litigation inevitable, say attorneys at Fenwick.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.