Federal

  • March 29, 2024

    Income From Schools' Reinsurance Excluded, IRS Says

    A nonprofit insurance company can exclude income received for providing reinsurance coverage for a conglomerate of public charter schools from its gross income as its work is "an essential government function," the Internal Revenue Service said in a ruling published Friday.

  • March 29, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, which included proposed regulations for claiming a tax credit for the production of qualified clean hydrogen.

  • March 28, 2024

    Tax Court Revokes Treasury's Easement Perpetuity Rule

    A divided U.S. Tax Court on Thursday invalidated Treasury rules regarding requirements for charitable donations of conservation easements to protect conservation purposes in perpetuity, granting a partial win to an Oklahoma partnership fighting to keep its $14.8 million conservation easement deduction.

  • March 28, 2024

    Corp. Transparency Act Overbroad, Mich. Group Tells Court

    The Corporate Transparency Act is overbroad and violates both the Fourth and Fifth Amendments of the U.S. Constitution, the Small Business Association of Michigan told a federal court in a case similar to one currently in the Eleventh Circuit.

  • March 28, 2024

    Abuse Of Discretion Claims Fall Flat In $13M Tax Court Case

    The federal government may proceed with collecting on a $13 million tax liability after a Colorado woman failed to prove that there was an abuse of discretion when the IRS sustained a levy against her, the U.S. Tax Court ruled Thursday.

  • March 28, 2024

    Musician's Trips To Japan Not Business, Tax Court Rules

    A musician who said he traveled to Japan to conduct market research and learn about the country's music culture cannot claim a deduction of nearly $20,000 in travel expenses, the U.S. Tax Court ruled Thursday.

  • March 28, 2024

    Canadian In Wash. Owes Over $1M FBAR Penalty, US Says

    A Canadian man living in Washington state owes more than $1 million in penalties for failing to report bank accounts he held in Montreal, the U.S. Department of Justice said in a complaint filed in an attempt to collect the money.

  • March 28, 2024

    Doctor Allowed To Withdraw NBA Fraud Plea, Gets June Trial

    A Manhattan federal judge will allow a Seattle-area doctor to pull back his guilty plea and go to trial in June, against prosecutors' objections, in a case alleging he assisted a cohort of retired NBA players to create fake invoices to submit to the league's healthcare plan.

  • March 28, 2024

    2nd Circ. Urged To Uphold Dual Citizen's FBAR Penalties

    A New York federal court correctly upheld tax penalties against a dual French citizen for hiding millions of dollars in six foreign accounts, the U.S. government told the Second Circuit, urging it to reject the woman's claims that American authorities violated the Hague Convention in pursuing her.

  • March 28, 2024

    IRS Floats Expanding Tax Info Disclosures To Census Bureau

    The Internal Revenue Service proposed rules Thursday that would expand what tax return information can be disclosed to the U.S. Census Bureau.

  • March 28, 2024

    IRS Investigated $9B In Potential COVID Aid Fraud

    The criminal investigation arm of the Internal Revenue Service investigated nearly $9 billion in potential fraud cases related to coronavirus relief funds, the agency said Thursday.

  • March 28, 2024

    Nev. Estate Owes Over $3.8M In FBAR Penalties, Court Rules

    The estate of a Nevada entrepreneur must pay over $3.8 million in penalties and interest for willfully failing to report his foreign bank accounts in Belize, the Bahamas and Panama, a federal district court ruled.

  • March 27, 2024

    Hunter Biden Judge Doubts Tax Charges Politically Motivated

    A California federal judge Wednesday appeared unpersuaded by Hunter Biden's claim that the special counsel's decision to file criminal tax charges after a plea deal collapsed was motivated by pressure from Republican lawmakers, remarking that "there really is no evidence to support that contention."

  • March 27, 2024

    Zaxby's Co-Founder's $43M Easement Fight Headed For Trial

    A trial will be needed to determine whether a co-founder of the Zaxby's restaurant chain and his wife are entitled to a $43.3 million tax refund for donations of conservation easements, a Georgia federal judge ruled Wednesday, saying the value of the easements remains in dispute.

  • March 27, 2024

    NY Couple Hid $1.4M In Dividends, Tax Court Says

    A New York man who pled guilty to healthcare fraud and his wife are liable for tax deficiencies after failing to report more than $1.4 million in constructive dividends, the U.S. Tax Court said Wednesday.

  • March 27, 2024

    Treasury Urged To Adjust Shift To Foreign Currency Rules

    The U.S. Treasury Department should let corporations take an aggregate approach regarding certain affiliates that conduct business in foreign currencies when transitioning to new rules for determining taxable income or loss, the American Bar Association's Tax Section recommended.

  • March 27, 2024

    IRS Delays Some Hawaii Deadlines Until August After Fires

    The Internal Revenue Service granted an additional extension of filing and payment deadlines for some Hawaii taxpayers affected by wildfires, the agency said Wednesday.

  • March 27, 2024

    Justices Grapple With Complex $3M Estate Tax Dispute

    The U.S. Supreme Court confronted a complicated dispute Wednesday over whether the estate of a deceased building supply company owner should be taxed on $3 million in life insurance proceeds the company used to buy his shares after his death, with two justices seeming to take opposing sides.

  • March 27, 2024

    Groups Urge IRS To Keep Strict Hydrogen Tax Credit Rules

    Some supporters of the Internal Revenue Service's proposed rules for the clean hydrogen production tax credit encouraged the agency Wednesday to maintain strict qualification criteria for the incentive to further discourage the use of fossil fuels in the manufacturing process and to reduce pollution.

  • March 27, 2024

    NY County Seeks To Bar NYC Congestion Prices As Illegal Tax

    A New York county with limited access to the Metropolitan Transportation Authority's service system jumped into the litigation fray against New York City's congestion pricing plan, arguing that the proposed charges for driving into portions of Manhattan are illegal taxes.

  • March 27, 2024

    Worker Credit Cutoff Seen As Harsh But Fair Potential Fix

    Tax legislation pending in the Senate would retroactively end the employee retention tax credit program and leave businesses with a legitimate need for the credit out in the cold, but lawmakers say the move is necessary given the magnitude of fraud in the program.

  • March 27, 2024

    Advice-Of-Counsel Defense Curbed From NC Tax Fraud Trial

    Two St. Louis attorneys and a North Carolina insurance agent can't fall back on advice-of-counsel defenses during their upcoming tax fraud trial after a federal judge found that they had failed to follow court orders requiring them to hand over information about the advice they sought.

  • March 26, 2024

    Meta Can't Escape Suit Over Collection Of Taxpayers' Data

    A California federal judge refused to release Meta from a consolidated class action accusing it of unlawfully collecting sensitive information from tax filing websites H&R Block, TaxAct and Tax Slayer, allowing state and federal wiretapping claims to move forward and permitting the plaintiffs to amend several deficient privacy allegations. 

  • March 26, 2024

    Adjusting To Amount B's Rules May Bring Growing Pains

    Countries designed a new tax framework known as Amount B to streamline the pricing of certain cross-border operations, but the criteria for determining whether transactions qualify for the regime, which negotiators recently made optional, may complicate the goal of simplicity.

  • March 26, 2024

    $4.5M Microcaptive Insurance Deduction Nixed By Tax Court

    An eye doctor can't deduct more than $4.5 million in insurance premiums that he paid to two microcaptive companies because the payments don't qualify as valid insurance purchases for federal income tax purposes, the U.S. Tax Court ruled Tuesday.

Expert Analysis

  • Enforcement Of International Tax Reporting Is Heating Up

    Author Photo

    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • How Gov't Agencies Will Fare In The Event Of A Shutdown

    Author Photo

    With a federal shutdown potentially set to begin at the end of this month, it may be useful to consider the approximate timelines that agencies such as the Federal Trade Commission and IRS have announced for curtailing operations, and potential strategies for mitigating challenges that may arise while agency functions are limited, say attorneys at Cleary.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

    Author Photo

    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

    Author Photo

    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

    Author Photo

    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

    Author Photo

    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

    Author Photo

    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

  • Kentucky Tax Talk: Taking Up The Dormant Commerce Clause

    Author Photo

    Attorneys at Frost Brown examine whether the U.S. Supreme Court is likely to review Foresight Coal Sales v. Kent Chandler to consider whether a Kentucky utility rate law discriminates against interstate commerce, and how the decision may affect dormant commerce clause jurisprudence.

  • Prevailing Wage Rules Complicate Inflation Act Tax Incentives

    Author Photo

    Nicole Elliott and Timothy Taylor at Holland & Knight discuss the intersection between tax and labor newly created by the Inflation Reduction Act, and focus on aspects of recent U.S. Department of Labor and U.S. Department of the Treasury rules that may catch tax-incentive seekers off guard.

  • Payroll Tax Evasion Notice Suggests FinCEN's New Focus

    Author Photo

    The Financial Crimes Enforcement Network’s recent notice advising U.S. financial institutions to report payroll tax evasion and workers' compensation schemes in the construction industry suggests a growing interest in tax enforcement and IRS collaboration, as well as increased scrutiny in the construction sector, say Andrew Weiner and Jay Nanavati at Kostelanetz.

  • How Taxpayers Can Prep As Justices Weigh Repatriation Tax

    Author Photo

    The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.

  • IRS Foreign Tax Credit Pause Is Welcome Course Correction

    Author Photo

    A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.

  • If Justices End Chevron Deference, Auer Could Be Next Target

    Author Photo

    If the U.S. Supreme Court decides next term to overrule its Chevron v. NRDC decision, it may open the door for a similar review of the Auer deference — the principle that a government agency can interpret, through application, ambiguous agency regulations, says Sohan Dasgupta at Taft Stettinius.

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