Federal

  • September 03, 2024

    5th Circ. Rejects 4 Arguments Against $6K Tax Bill

    The U.S. Tax Court correctly determined a man owed over $5,000 in tax deficiencies as well as more than $1,000 in penalties plus interest, the Fifth Circuit ruled Tuesday, finding none of the taxpayer's four arguments persuasive.

  • September 03, 2024

    IRS Should Be Bound By $2M Bankruptcy Deal, Justices Told

    An Alabama real estate developer who sought bankruptcy protection and agreed to settle his tax debts for $2 million asked the U.S. Supreme Court to review a decision allowing the IRS to demand additional taxes from him, saying the agency shouldn't be allowed to back out of the deal.

  • September 03, 2024

    Ex-Defense Contractor Arrested In $350M Tax Evasion Case

    A former defense contractor who, with his wife, is facing a 30-count indictment alleging they were involved in a decades-long scheme to defraud the U.S. government and avoid taxes on more than $350 million in income was arrested Tuesday.

  • September 03, 2024

    9th Circ. Rejects Tax Lien Pro Rata Share In Bankruptcy Sale

    The bankruptcy court is not authorized to use the pro rata method to allocate proceeds between the IRS and an estate with a tax lien for unpaid taxes and penalties, the Ninth Circuit ruled Tuesday, saying there is nothing in bankruptcy law that explicitly allows this approach.

  • September 03, 2024

    Debtor's Late-Filing Case Should Be Reviewed, Justices Told

    Tax experts urged the U.S. Supreme Court to review a Ninth Circuit decision that found late-filed returns prevented a taxpayer from discharging his federal tax debt in bankruptcy, saying the case reflects a decades-long debate that has split the circuits three ways.

  • September 03, 2024

    Non-EU Cos. Need Clarity On Public Tax Reporting, Firms Say

    The European Union should clarify how multinational corporations headquartered outside the bloc need to format tax data they report under new public disclosure rules, global accounting firms said.

  • September 03, 2024

    IRS Issues More Edits For Foreign Currency Accounting Regs

    The Internal Revenue Service issued further corrections Tuesday to proposed rules that would adjust the timing for when companies can use certain accounting methods for gains or losses that arise from foreign currency transactions.

  • August 30, 2024

    Partnership Can't Save Premature Tax Court Appeal, Feds Say

    The IRS is urging the Eleventh Circuit to throw out a Tax Court appeal that a partnership formed by two former Atlanta Braves players filed over a slashed $47.6 million conservation easement deduction, since the appeal was improperly filed before a final decision was entered.

  • August 30, 2024

    3 Ways Justices' SEC Fraud Ruling Could Affect Tax Disputes

    The U.S. Supreme Court's groundbreaking decision to curb the U.S. Securities and Exchange Commission's in-house fraud enforcement could hamper the IRS' ability to assert certain penalties, including in contested conservation easement cases, and challenge the U.S. Tax Court's authority to review them. Here, Law360 examines three arenas in which the Supreme Court decision could shake up tax administration and litigation.

  • August 30, 2024

    Alvarez & Marsal Appoints Tax Experts As Managing Directors

    Alvarez & Marsal Tax LLC appointed tax experts from Anderson and Deloitte as its new managing directors, the firm announced.

  • August 30, 2024

    Danish Gov't Pledges No Ponzi Analogies At $2.1B Tax Trial

    The Danish tax authority won't compare pension funds, investors and attorneys it has accused of defrauding Denmark in a $2.1 billion tax refund scheme to a Ponzi scheme or infamous perpetrator Bernie Madoff, it said Friday in New York federal court.

  • August 30, 2024

    Whistleblower Seeks 2nd Bid At $690M Claim In DC Circ.

    A whistleblower denied up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program asked for a D.C. Circuit panel to rehear his case Friday, saying its original opinion included numerous mistakes and misunderstandings.

  • August 30, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included an announcement of the reopening of a voluntary disclosure program for businesses that think they improperly received COVID-19-era employee retention credits.

  • August 30, 2024

    Partnership Asks 11th Circ. To Restore $9M Easement Break

    A partnership asked the Eleventh Circuit to reinstate its nearly $9 million deduction for donating a conservation easement in Georgia, saying the U.S. Tax Court erroneously limited the deduction to its cost basis by claiming partners who contributed the property had held it as inventory.

  • August 30, 2024

    IRS Corrects Proposed Rules To Address Pillar 2 Losses

    The Internal Revenue Service issued corrections Friday to proposed rules that outline when foreign taxes under the Pillar Two international minimum tax agreement could trigger long-standing U.S. rules that aim to prevent companies from what is known as double-dipping the same economic loss.

  • August 30, 2024

    Dow Seeks To Add 7 Chemicals To IRC Taxable Substances

    The Internal Revenue Service said Friday that it is looking for public comments on proposals by Dow Chemical to add seven chemicals to the Internal Revenue Code's list of taxable substances.

  • August 30, 2024

    Taxation With Representation: Kirkland, Paul Weiss, Squire

    In this week's Taxation With Representation, Oneok reaches two agreements with energy infrastructure companies worth a total $5.9 billion, McKesson inks a $2.49 billion deal for a cancer center, and First Busey and CrossFirst Bankshares agree to a $917 million merger.

  • August 30, 2024

    Rule Aims To Widen Low-Income Green Electricity Tax Credits

    Geothermal, hydropower, nuclear fusion and nuclear fission projects would be among the types of electricity facilities that could be eligible for clean electricity low-income community bonus credit amounts starting in 2025, the Internal Revenue Service and U.S. Treasury Department said in proposed rules released Friday.

  • August 29, 2024

    9th Circ. Says IRS Properly Rejected Payment Compromise

    A man who owed $50 million in taxes and offered to settle part of his debt was correctly denied a compromise, the Ninth Circuit affirmed Thursday, rejecting his argument that his offer should have been deemed accepted because the agency missed the two-year deadline for rejecting it.

  • August 29, 2024

    Tax Court Rejects Bid To Change Ruling Post-Chevron

    The U.S. Supreme Court's recent overturning of the Chevron standard of judicial deference to agencies when interpreting statutes does not justify reconsidering a Cayman Islands partnership's tax liability, the U.S. Tax Court ruled.

  • August 29, 2024

    4th Circ. Won't Revive Whistleblower's Credit Suisse Tax Suit

    The Fourth Circuit upheld the dismissal of a former Credit Suisse employee's whistleblower case that alleged the Swiss bank continued to help clients evade taxes after it made a related plea deal with the U.S., saying a 2023 U.S. Supreme Court decision on the False Claims Act could not save the case.

  • August 29, 2024

    Convicted Drexel Prof Says Records Would've Swayed Jury

    A Drexel University accounting professor convicted on charges of tax evasion and filing false tax returns after the government accused him of failing to report $3.3 million in income from a Trenton pharmacy has asked a New Jersey federal judge for a new trial.

  • August 29, 2024

    IRS Lacking In Limiting Below-$400K Audits, TIGTA Says

    The IRS has made only partial progress toward complying with a U.S. Treasury Department directive to develop methodology to ensure the agency doesn't increase the audit rate for businesses and households with annual incomes below $400,000, the Treasury Inspector General for Tax Administration reported Thursday.

  • August 29, 2024

    GAO Suggests IRS Improve Retirement Account Oversight

    The Internal Revenue Service needs to beef up its oversight of conflicts of interest between fiduciaries and individual retirement account investors, according to a U.S. Government Accountability Office report.

  • August 29, 2024

    Applications Open For $6B In Advanced Energy Tax Credits

    Full applications are now open for manufacturers seeking a share of a second-round $6 billion tax-credit allocation for their development projects that support the clean energy industry, the Internal Revenue Service and U.S. Department of Energy said Thursday.

Expert Analysis

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

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    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

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    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.

  • Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks

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    Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

  • IRS Sings New Tune: Whistleblower Form Update Is Welcome

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    In a significant reform at the Internal Revenue Service's Whistleblower Office, the recently introduced revisions to the Form 211 whistleblower award application use new technology and a more intuitive approach to streamline the process of reporting allegations of tax fraud committed by wealthy individuals and companies, says Benjamin Calitri at Kohn Kohn.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.

  • Energy Community Tax Credit Boost Will Benefit Wind Sector

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    Recent Internal Revenue Service guidance broadening tax credit eligibility to more parts of offshore wind facilities in so-called energy communities is a win for the industry, which stands to see more projects qualify for a particularly valuable bonus in the investment tax credit context due to the capital-intensive nature of offshore wind projects, say attorneys at Troutman Pepper.

  • Weisselberg's Perjury At Trial Spotlights Atty Ethics Issues

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    Former Trump Organization executive Allen Weisselberg’s recent guilty plea for perjury in the New York attorney general's civil fraud trial should serve as a reminder to attorneys of their ethical duties when they know a client has lied or plans to lie in court, and the potential penalties for not fulfilling those obligations, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • Practicing Law With Parkinson's Disease

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    This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.

  • Why Supreme Court Should Allow Repatriation Tax To Stand

    If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.

  • Trump's NY Civil Fraud Trial Spotlights Long-Criticized Law

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    A New York court’s recent decision holding former President Donald Trump liable for fraud brought old criticisms of the state law used against him back into the limelight — including its strikingly broad scope and its major departures from the traditional elements of common law fraud, say Mark Kelley and Lois Ahn at MoloLamken.

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

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    A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.

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