Federal

  • October 10, 2024

    IRS Announces 9 Tax Court Sessions Added To Calendar

    The Internal Revenue Service announced nine U.S. Tax Court sessions in February and March and named calendar administrators for the sessions.

  • October 10, 2024

    Estimated Tax Gap For 2022 Falls To $696B, IRS Says

    The projected federal gross tax gap between taxes owed and taxes paid for the 2022 tax year was $696 billion, a $12 billion decrease from 2021, according to a report published Thursday by the Internal Revenue Service.

  • October 10, 2024

    Partnership Challenges Denial Of $42M Easement Deduction

    The Internal Revenue Service failed to justify rejecting a Florida partnership's charitable contribution deduction for donating a $42 million conservation easement to a land conservancy, the partnership told the U.S. Tax Court.

  • October 10, 2024

    IRS Says It's Stepping Up Worker Credit Claims Processing

    The Internal Revenue Service said Thursday it's accelerating processing of claims for pandemic-era worker credits after a moratorium triggered by what the agency has said was widespread fraud.

  • October 10, 2024

    Pfizer Lone Holdout In Senate Pharma Tax Probe, Wyden Says

    Pfizer Inc. is the only company to withhold a country-by-country breakdown of its tax planning in the Senate Finance Committee's probe into how Republicans' 2017 tax package reduced the pharmaceutical industry's U.S. liabilities, according to a letter Chairman Ron Wyden released Thursday.

  • October 10, 2024

    Calif. Says FDIC Must Wait For $21M Tax Refund

    A California tax agency urged a New York federal court to toss a lawsuit by the FDIC seeking a $20.7 million tax refund on behalf of the shuttered Signature Bank, saying it's entitled to wait for a possible IRS audit before delivering the payment.

  • October 10, 2024

    IRS Keeping Co. In Dark On Carryback Refund, Court Told

    The Internal Revenue Service owes a $686,000 tax refund to a contractor for a carryback operating loss, the company told a Texas federal court, adding that the IRS hasn't responded to questions about a letter the agency claims it sent addressing the issue.

  • October 09, 2024

    Tax Court Rejects Levy On Convicted Atty Over $7B Scheme

    A U.S. Tax Court judge rejected an IRS levy for restitution owed by an ex-attorney serving time for orchestrating a $7 billion tax fraud scheme, saying the agency had made contradictory determinations about the alleged debt and wrongly involved the former attorney's wife, in an opinion released Wednesday.

  • October 09, 2024

    Army Reservist, Wife Lose Appeal Of Tax Debt And Penalty

    The Internal Revenue Service correctly determined a U.S. Army reservist and his wife were deficient on their taxes and liable for an accuracy-related penalty, the U.S. Tax Court said Wednesday, finding they failed to report income and didn't back up claimed deductions.

  • October 09, 2024

    OECD Should Clarify Pillar 2 Safe Harbor Timing, CPAs Say

    The OECD should clarify when exactly multinational corporations need to determine whether they qualify for a transitional safe harbor under an international minimum tax agreement, the American Institute of Certified Public Accountants recommended in a letter.

  • October 09, 2024

    3M Tax Ruling Must Fall Post-Chevron, Chamber Tells 8th Circ.

    The U.S. Supreme Court's ending of the Chevron doctrine calls for overturning a U.S. Tax Court ruling that let the IRS allocate $24 million of income to multinational conglomerate 3M from a Brazilian affiliate, the U.S. Chamber of Commerce told the Eighth Circuit on Wednesday.

  • October 09, 2024

    Masonry Cos. Demand $2.3M In Worker Credit Refunds

    The IRS brushed aside the requirements of a pandemic relief law by stalling on issuing $2.3 million in worker tax credits to two branches of a historic masonry company, the businesses told an Illinois federal court in a suit seeking refunds.

  • October 09, 2024

    Feds Seek 16 Months For Ex-BigLaw Partner's Tax Dodging

    Prosecutors told a Wisconsin federal judge that a former Husch Blackwell LLP and Dykema Gossett PLLC partner who pled guilty to tax evasion should be sentenced to 16 months in prison, saying he lied to IRS revenue officers to keep them at bay while spending lavishly on private planes, jewelry and golf club memberships.

  • October 09, 2024

    Final Treasury Rules Shut Off Inclusion For Repatriated IP

    The U.S. Treasury Department adopted final rules Wednesday that shut off an annual income inclusion associated with intangibles for companies in certain situations that have transferred intellectual property back to the U.S. from overseas.

  • October 08, 2024

    Homeowners Again Seek Class Cert. In Tax Foreclosure Suit

    A group of former property owners has asked a Michigan federal judge to recertify a class action seeking to recover profits county treasurers made selling their tax-delinquent properties, saying the addition of class representatives fixes the flaw that dismantled the class. 

  • October 08, 2024

    Tax Court Cuts $16.7M Deduction For Conservation Donation

    A partnership that claimed a $16.7 million tax deduction for donating a conservation easement covering land in Georgia was trying to "fleece the public" with its claims that the land could be used for clay mining, a U.S. Tax Court judge said Tuesday in a decision slashing the deduction.

  • October 08, 2024

    IRS Seeks Feedback On Digital Asset Reporting Form

    The Internal Revenue Service is seeking comments by Nov. 6 on a draft of a 2025 form for digital asset transaction reporting, according to a notice.

  • October 08, 2024

    Tire Seller Counts As Importer, Owes $2M Tax, 5th Circ. Says

    A Houston truck sales company owes nearly $2 million in excise taxes because it qualifies as the importer of tires that it bought from a Chinese manufacturer, the Fifth Circuit ruled Tuesday in overturning the decision of a Texas federal judge.

  • October 08, 2024

    Tax Court Denies Ariz. Woman Spousal Relief

    The U.S. Tax Court denied an Arizona woman's request for relief from liability for a faulty return filed by her husband, saying on Tuesday that she failed to show she was a victim of abuse and incapable of challenging the filing.

  • October 08, 2024

    Loss Rule Carveouts Raise Challenges In Pillar 2, Official Says

    An IRS official flagged administrability concerns Tuesday with potential safe harbors that would, in some cases, carve out an international minimum tax agreement from interacting with long-standing domestic rules aimed at preventing companies from using the same economic loss twice.

  • October 08, 2024

    Calif. Tax Preparer Gets 6 Years For $28M Scheme

    The owner of a California tax preparation business who helped customers create sham companies was sentenced to six years in prison for a decadelong scheme that caused a tax loss of at least $28 million, according to the U.S. Department of Justice.

  • October 08, 2024

    Settlement Payments Not Deductible Alimony, 11th Circ. Told

    A divorced man who was ordered by a judge to make $3 million in payments on a past-due settlement to his ex-wife should not be allowed to shield them from tax, the U.S. government told the Eleventh Circuit, saying the payments don't qualify as alimony.

  • October 08, 2024

    7 Taxpayer Advocacy Panel Committees To Meet In November

    Seven Taxpayer Advocacy Panel committees will meet in November to discuss possible improvements to customer services, the Internal Revenue Service said Tuesday.

  • October 07, 2024

    Justices Won't Hear Man's FBAR Constitutionality Challenge

    The U.S. Supreme Court let stand Monday a Seventh Circuit decision dismissing a man's challenge to the constitutionality of the Bank Secrecy Act's requirement to report his foreign bank accounts, effectively ending the man's claim that the filings were an invasion of privacy.

  • October 07, 2024

    Jury Finds Professor Hid Foreign Bank Accounts

    An 86-year-old former college professor faces more than $500,000 plus interest in penalties after a jury found that he had deliberately failed to report his foreign bank accounts in Switzerland and Turkey, according to documents filed in a California federal court.

Featured Stories

  • Dems Weigh Extending 2017 Cuts To Maintain $400K Tax Vow

    Stephen K. Cooper

    Despite criticizing the 2017 Republican tax overhaul as a deficit-busting boon to the wealthy, congressional Democrats may feel pressure to support extending some of the law's individual and small-business provisions or risk breaking their pledge not to raise taxes on those earning $400,000 or less.

  • Election Uncertainty Hampers Companies' Tax Planning

    No Photo Available

    With the November election approaching, businesses are bracing for the potential impact of two very different sets of tax policies, with the resulting uncertainty making long-term tax planning increasingly difficult.

  • IRS Appeals Office's Easement Deals May Sap Independence

    Kat Lucero

    The IRS Independent Office of Appeals plans to settle certain conservation easement cases with similar terms offered by other IRS divisions, but these upcoming offers might be challenging for taxpayers to navigate and could undermine the office's independence from the rest of the agency.

Expert Analysis

  • 8 Childhood Lessons That Can Help You Be A Better Attorney

    Author Photo

    A new school year is underway, marking a fitting time for attorneys to reflect on some fundamental life lessons from early childhood that offer a framework for problems that no legal textbook can solve, say Chris Gismondi and Chris Campbell at DLA Piper.

  • How The 2025 Tax Policy Debate Will Affect The Energy Sector

    Author Photo

    Regardless of the outcome of the upcoming U.S. election, 2025 will bring a major tax policy debate that could affect the energy sector more than any other part of the economy — so stakeholders who could be affected should be engaging now to make sure they understand the stakes, say attorneys at Mayer Brown.

  • This Election, We Need To Talk About Court Process

    Author Photo

    In recent decades, the U.S. Supreme Court has markedly transformed judicial processes — from summary judgment standards to notice pleadings — which has, in turn, affected individuals’ substantive rights, and we need to consider how the upcoming presidential election may continue this pattern, says Reuben Guttman at Guttman Buschner.

  • Mental Health First Aid: A Brief Primer For Attorneys

    Author Photo

    Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.

  • The Trade And Tax Issues Behind US-Canada Digital Tax Clash

    Author Photo

    The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.

  • Litigation Inspiration: Honoring Your Learned Profession

    Author Photo

    About 30,000 people who took the bar exam in July will learn they passed this fall, marking a fitting time for all attorneys to remember that they are members in a specialty club of learned professionals — and the more they can keep this in mind, the more benefits they will see, says Bennett Rawicki at Hilgers Graben.

  • AI May Limit Key Learning Opportunities For Young Attorneys

    Author Photo

    The thing that’s so powerful about artificial intelligence is also what’s most scary about it — its ability to detect patterns may curtail young attorneys’ chance to practice the lower-level work of managing cases, preventing them from ever honing the pattern recognition skills that undergird creative lawyering, says Sarah Murray at Trialcraft.

  • A Look At How De Minimis Import Rules May Soon Change

    Author Photo

    The planned implementation of executive actions focused on the de minimis rule as it applies to shipments means companies should use this interval to evaluate the potential applicability and impact of Section 301, Section 201 or Section 232 duties on their products, say attorneys at Holland & Knight.

  • Ruling On Foreign Dividend Break Offers 2 Tax Court Insights

    Author Photo

    In Varian v. Commissioner, the U.S. Tax Court allowed a taxpayer's deduction for dividends from foreign subsidiaries, providing clarity on how the U.S. Supreme Court’s Loper Bright decision may affect challenges to Treasury regulations, and revealing a potential disallowance of foreign tax credits, say attorneys at Davis Polk.

  • Why Now Is The Time For Law Firms To Hire Lateral Partners

    Author Photo

    Partner and associate mobility data from the second quarter of this year suggest that there's never been a better time in recent years for law firms to hire lateral candidates, particularly experienced partners — though this necessitates an understanding of potential red flags, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.

  • Considering Possible PR Risks Of Certain Legal Tactics

    Author Photo

    Disney and American Airlines recently abandoned certain litigation tactics in two lawsuits after fierce public backlash, illustrating why corporate counsel should consider the reputational implications of any legal strategy and partner with their communications teams to preempt public relations concerns, says Chris Gidez at G7 Reputation Advisory.

  • It's No Longer Enough For Firms To Be Trusted Advisers

    Author Photo

    Amid fierce competition for business, the transactional “trusted adviser” paradigm from which most firms operate is no longer sufficient — they should instead aim to become trusted partners with their most valuable clients, says Stuart Maister at Strategic Narrative.

  • Avoid Getting Burned By Agencies' Solar Financing Spotlight

    Author Photo

    Recently coordinated reports and advisories from the U.S. Department of the Treasury, the Consumer Financial Protection Bureau and the Federal Trade Commission maximize the spotlight on the consumer solar financing market and highlight pitfalls for lenders to avoid in this burgeoning field, says Mercedes Tunstall at Cadwalader.