Federal
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November 05, 2024
11th Circ. Says IRS Summons Doesn't Violate 5th Amendment
A Florida federal court didn't err when it upheld an Internal Revenue Service summons, the Eleventh Circuit said, saying it was unconvinced by a taxpayer's argument that the summons violated his Fifth Amendment rights against self-incrimination.
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November 05, 2024
CPA Group Urges IRS To Promote Digital Asset Basis Relief
The U.S. Treasury Department and Internal Revenue Service should promote a safe harbor for taxpayers that plan to allocate the unused basis of their digital assets before a Jan. 1 deadline for using the relief, a certified public accountants group said in a letter released Tuesday.
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November 05, 2024
Crypto Council Seeks Delay In Digital Asset Broker Regs
The IRS should delay the effective date of a requirement in the digital assets broker regulations that calls for identifying units of the assets in the broker's custody until the agency clarifies the provision, a global council of cryptocurrency companies said in a letter released Tuesday.
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November 05, 2024
2nd Circ. Urged To Rethink Dual Citizen's FBAR Penalties
A dual U.S.-French citizen found liable for tax penalties by the Second Circuit for hiding millions of dollars in foreign accounts asked the court Tuesday to reconsider, saying American authorities demanded she participate in a deposition that would have put her in legal jeopardy abroad.
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November 05, 2024
On The Ground: How Attorneys Safeguarded The Election
Attorneys worked tirelessly Tuesday to support citizens and election workers on the final day of voting in one of history's most contentious presidential contests.
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November 04, 2024
'Oh, Come On': 5th Circ. Doubts Intuit Ads Misled Consumers
The Fifth Circuit on Monday seemed skeptical that the company behind TurboTax duped customers into thinking they could file their tax returns for free, with judges engaging in a lengthy back-and-forth with the Federal Trade Commission over how noticeable disclosures on the ads had to be for the agency to consider them truthful.
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November 04, 2024
2nd Circ. Rejects Man's Challenge To IRS Lien For $4.2M
The U.S. Tax Court correctly found that the IRS appeals office didn't abuse its powers by approving the agency's federal tax lien to collect $4.2 million from a man with a court-ordered payment plan, the Second Circuit said.
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November 04, 2024
Ga. Tax Preparer Gets 28 Months In $5M Tax Scheme
A Georgia accountant was sentenced to more than two years in prison for his role in promoting syndicated conservation easements that resulted in a $5 million tax loss to the Internal Revenue Service, the U.S. Department of Justice announced.
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November 04, 2024
US Must Pay Legal Fees To Challenger Of IRS Guidance
A Michigan federal judge ordered the U.S. to pay roughly $220,000 in attorney fees to a construction company that won its challenge to Internal Revenue Service penalties and overturned underlying agency guidance, rejecting a magistrate judge's recommendation that the company foot its own bill.
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November 04, 2024
Ukrainian Pleads To $11M Tax Fraud, Immigration Scheme
A Ukrainian national charged for immigration fraud and money laundering has pled guilty and could face 20 years in prison, the U.S. Justice Department announced.
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November 04, 2024
Justices Won't Hear UBS Suit Over Disclosed Account Info
The U.S. Supreme Court declined Monday to hear a couple's suit accusing UBS of fraudulently flagging an account to the Internal Revenue Service in violation of civil provisions under the Racketeer Influenced and Corrupt Organizations Act.
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November 04, 2024
Justices Let Stand Bar On Late-Filed Returns In Bankruptcy
The U.S. Supreme Court said Monday it would let stand a Ninth Circuit decision finding late-filed returns prevented a taxpayer from discharging his federal tax debt in bankruptcy, rejecting the taxpayer's request to resolve what he described as a significant circuit split.
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November 04, 2024
IRS Finalizes Seized Property Rules To Include Online Sales
The Internal Revenue Service issued final rules Monday meant to modernize regulations governing the seizure of property by levy, including facilitating the online sale of a property and the agency's ability to maximize sale proceeds for the property owner's benefit.
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November 01, 2024
Previously Taxed Profit Rules Due By Year's End, Official Says
The Internal Revenue Service will publish the first tranche of long-awaited regulations on offshore earnings and profits previously taxed in the U.S. before the end of the year, an agency counsel said Thursday.
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November 01, 2024
NOL Rules May Retain Favorable Approach, IRS Counsel Says
New proposed regulations governing business net operating losses that could retain a popular provision allowing some businesses expanded use of those losses are a priority to be published next year, a top Internal Revenue Service lawyer said.
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November 01, 2024
Brazil Should Adopt Latest Pillar 2 Safe Harbor, NFTC Says
Brazil should include the latest updates to globally agreed-upon safe harbors in its legislation to enact an international minimum tax agreement known as Pillar Two, according to the National Foreign Trade Council, which said these measures help prevent double taxation.
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November 01, 2024
Couple Tries To Block IRS Summons Issued For Spain
A couple asked a California federal court to block an IRS summons for their financial information issued on behalf of Spain, saying the demand is tantamount to a fishing expedition meant to help the foreign government prosecute them.
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November 01, 2024
Taxation With Representation: Kirkland, Davis Polk, Wachtell
In this week's Taxation with Representation, BC Partners sells its majority equity interest in GardaWorld, Lone Star Funds sells specialty chemicals company AOC to Nippon Paint Holdings, Crescent Biopharma takes GlycoMimetics private, and Francisco Partners buys AdvancedMD from Global Payments.
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November 01, 2024
Danish Tax Agency To Settle With Atty In $2.1B Tax Fraud Suit
Denmark's tax authority has agreed to settle with an attorney whom it has accused of helping clients claim fraudulent tax refunds in a sprawling $2.1 billion case, according to a letter by its attorney in New York federal court.
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November 01, 2024
GOP Gains Could Prompt Push For Endowment Tax Hike
If Republicans make significant gains in the upcoming elections, it could clear the way for GOP lawmakers to push to boost taxes on the endowments of some private colleges and universities.
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November 01, 2024
IRS Ups Contribution Limit For 401(k), Other Plans
The annual amount that employees can contribute to various retirement plans has been increased to $23,500 from $23,000 as part of cost-of-living adjustments released Friday by the IRS.
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November 01, 2024
CFC Dividend Tax Issue Brewing In Exams, IRS Official Says
A memorandum from the IRS chief counsel explaining why a controlled foreign corporation cannot claim a 100% deduction for certain foreign-based earnings was necessary to inform field agents dealing with the issue in the exam process, an agency official said Thursday.
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November 01, 2024
Accountant Gets 1 Year For Failing To Report Stolen Income
An accountant for a manufacturing company who embezzled more than $800,000 and failed to report it on his tax returns was sentenced to just over a year in prison and ordered to pay $1 million in restitution, according to New Jersey federal court documents.
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November 01, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the annual inflation adjustments to over 60 tax provisions.
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October 31, 2024
Man Didn't Justify His Claims He Couldn't Pay, Tax Court Says
The Internal Revenue Service didn't abuse its discretion when it upheld levies to collect over $58,000 in outstanding tax liabilities, including penalties and interest, after a man failed to substantiate his claims of medical hardship, the U.S. Tax Court said Thursday.
Expert Analysis
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Why Biz Groups Disagree On Ending Chevron Deference
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.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
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.
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A Look Ahead For The Electric Vehicle Charging Industry
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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A Post-Mortem Analysis Of Stroock's Demise
After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.
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SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
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Planning A Defense As IRS Kicks Off Sports Losses Campaign
Sports team owners and partnerships face potential examination under the Internal Revenue Service’s recently announced sports industry losses campaign, and should be preparing to explain what drove their reported losses and assembling documentation to support their tax return positions and accounting methods, say Sheri Dillon and Jennifer Breen at Morgan Lewis.
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What New Calif. Strike Force Means For White Collar Crimes
The recently announced Central District of California strike force targeting complex corporate and securities fraud — following the Northern District of California's model — combines experienced prosecutorial leadership and partnerships with federal agencies like the IRS and FBI, and could result in an uptick in the number of cases and speed of proceedings, say attorneys at MoFo.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.
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As Promised, IRS Is Coming For Crypto Tax Evaders
The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.
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5 Reasons Associates Shouldn't Take A Job Just For Money
As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.
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Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules
Regulations recently proposed by the IRS and the U.S. Department of the Treasury concerning two types of tax credits for clean hydrogen production facilities should resolve many of the most pressing questions around qualification for the credits — albeit in a relatively stringent manner, say attorneys at Morgan Lewis.