Federal
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July 09, 2024
Dems Request Special Counsel To Probe Justice Thomas Gifts
Two Democratic senators have asked U.S. Attorney General Merrick Garland to appoint a special counsel to investigate whether U.S. Supreme Court Justice Clarence Thomas' failure to disclose various gifts received during his tenure on the high court amounts to chargeable ethics violations or tax crimes.
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July 09, 2024
IRS Errors Foul $51M Levy, Calif. Man's Estate Tells Tax Court
The Internal Revenue Service made a slew of errors in determining a California man's estate faces a $46.2 million estate tax deficiency and a $4.6 million penalty, the estate's executor told the U.S. Tax Court.
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July 09, 2024
Veriwave Telco Faces FCC Action Over 'Tax Relief' Robocalls
The Federal Communications Commission is moving to block robocalls about purported "tax relief" programs from a Delaware-based telecommunications company, announcing in an order Monday that Veriwave Telco had another 14 days to demonstrate compliance with the agency's rules or risk having downstream providers cut its traffic.
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July 09, 2024
Senate Tax Panel To Consider 3 Tax Court Nominees
The Senate Finance Committee is scheduled to hold a hearing Wednesday to consider three U.S. Tax Court judge nominees, Sen. Ron Wyden, D-Ore., the panel's chairman, said in a statement Tuesday.
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July 09, 2024
5 Firms Steer $513M Ryan-Altus Cross-Border Tax Deal
Dallas-based tax services and software provider Ryan said Tuesday it has inked a deal to acquire the property tax business of Altus Group Ltd. for CA$700 million ($513.4 million), enlisting three firms to assist on a deal that will expand its footprint in Canada, the U.S. and the U.K.
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July 09, 2024
Medical Office Manager Gets 5 Years For Tax, Mail Fraud
The former office manager of an Illinois medical practice was sentenced to five years in federal prison and ordered to pay $3 million in restitution — most of it to his former employer — after admitting to filing a false tax return and stealing from the practice.
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July 09, 2024
Companies Deliberate Pillar 2 Prep After OECD Signals Relief
Multinational corporations facing the Pillar Two global minimum tax in various jurisdictions are weighing comments from OECD officials that hint at more relief as they decide whether to prepare to comply with the rules now or gamble on the prospects of permanent safe harbors.
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July 08, 2024
IRS Details Steps To Take For Scam-Credit Letter Recipients
The Internal Revenue Service published a fact sheet Monday to help taxpayers respond to letters from the agency identifying tax returns as requiring authentication after the agency said that inaccurate advice from social media and a series of scams led to an increase in questionable refund claims.
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July 08, 2024
Continued Worker Credit Freeze Could Push Cos. To Court
More employers tired of waiting for the Internal Revenue Service to process their employee retention credit refund claims could decide to go to court to force the government to review their submissions following the IRS announcing that a moratorium on processing new claims would remain in place.
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July 08, 2024
Ways And Means To Vote On Section 529 Tax Bills
The House Ways and Means Committee is scheduled to vote Tuesday on several education-related tax bills, including legislation that would make additional elementary and secondary school expenses eligible for tax-advantaged education savings accounts.
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July 08, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin reported recently issued guidance on exceptions to the 10% additional tax for people who make permissible early retirement account withdrawals for emergency personal expenses and for victims of domestic abuse.
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July 08, 2024
IRS Failed To Analyze Storage Costs, TIGTA Says
The IRS didn't negotiate with the federal agency that stores its paper tax records, instead agreeing to pay a new monthly rate of $2.8 million without doing the required cost analysis, the Treasury Inspector General for Tax Administration said in a report released Monday.
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July 08, 2024
Top International Tax Cases Of 2024: Midyear Report
With a U.S. Supreme Court decision affirming a key 2017 tax provision on repatriation, millions of dollars in FBAR penalties upheld and a French ruling confirming the U.S. government's access to foreign bank accounts, the IRS stacked up important court victories on international enforcement in the first half of 2024. Here, Law360 reviews those and other significant rulings from the past six months.
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July 08, 2024
Atty Drops FOIA Suit Against IRS Over Partnership Audits
An Ohio attorney agreed to drop a public records suit against the Internal Revenue Service that had sought documents related to partnership audits after the agency released thousands of records he had requested, according to a D.C. federal court filing.
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July 08, 2024
IRS Must Produce Audit Records, Waste Co. Says
Garbage-hauling giant Waste Management Inc. asked a D.C. federal court to force the IRS to produce its tax files on the company for 2017, including audit records, saying the agency has been dragging its feet in violation of the Freedom of Information Act.
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July 08, 2024
Feds Seize $63M LA Estate Tied To Armenian Bribe Probe
The U.S. Department of Justice said Monday that it will seize a $63 million Los Angeles estate that it claims was bought with bribe payments for the family of a former Armenian government official.
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July 05, 2024
How Reshaped Circuit Courts Are Faring At The High Court
Seminal rulings from the U.S. Supreme Court's latest term will reshape many facets of American society in the coming years. Already, however, the rulings offer glimpses of how the justices view specific circuit courts, which have themselves been reshaped by an abundance of new judges.
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July 05, 2024
Breaking Down The Vote: The High Court Term In Review
The U.S. Supreme Court's lethargic pace of decision-making this term left the justices to issue a slew of highly anticipated and controversial rulings during the term's final week — rulings that put the court's ideological divisions on vivid display. Here, Law360 takes a data dive into the numbers behind this court term.
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July 05, 2024
High Court Flexes Muscle To Limit Administrative State
The U.S. Supreme Court's dismantling of a 40-year-old judicial deference doctrine, coupled with rulings stripping federal agencies of certain enforcement powers and exposing them to additional litigation, has established the October 2023 term as likely the most consequential in administrative law history.
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July 05, 2024
The Sharpest Dissents From The Supreme Court Term
The U.S. Supreme Court's session ended with a series of blockbuster cases that granted the president broad immunity, changed federal gun policy and kneecapped administrative agencies. And many of the biggest decisions fell along partisan lines.
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July 05, 2024
5 Moments That Shaped The Supreme Court's Jan. 6 Decision
When the high court limited the scope of a federal obstruction statute used to charge hundreds of rioters who stormed the Capitol, the justices did not vote along ideological lines. In a year marked by 6-3 splits, what accounts for the departure? Here are some moments from oral arguments that may have swayed the justices.
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July 05, 2024
The Funniest Moments Of The Supreme Court's Term
In a U.S. Supreme Court term teeming with serious showdowns, the august air at oral arguments filled with laughter after an attorney mentioned her plastic surgeon and a justice seemed to diss his colleagues, to cite just two of the term's mirthful moments. Here, we look at the funniest moments of the term.
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July 05, 2024
H&R Block Users Must Arbitrate Meta Privacy Claims
Two H&R Block customers must arbitrate their claims that the company shared their private data with Meta Platforms Inc. and Google, a Pennsylvania federal court ruled, saying they agreed to arbitrate any disputes under the tax services provider's terms of agreement.
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July 05, 2024
The Firms That Won Big At The Supreme Court
This U.S. Supreme Court term featured high-stakes oral arguments on issues including gerrymandering, abortion and federal agency authority, and a hot bench ever more willing to engage in a lengthy back-and-forth with advocates. Here's a look at the law firms that argued the most cases and how they fared.
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July 05, 2024
7th Circ. Asked To Weigh Chevron's End In Cubs Sale Tax Suit
The Seventh Circuit should consider last week's U.S. Supreme Court ruling overturning the Chevron deference doctrine to scrutinize the IRS' claim that it has the authority to tax gains from Tribune Media Co's sale of the Chicago Cubs, a Tribune attorney urged.
Expert Analysis
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Review Of Repatriation Tax Sets Justices On Slippery Slope
The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.
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IRS Guidance Powers Up Energy Tax Credit Transfers
Recent IRS guidance on the monetization of energy tax credits provides sufficient clarity for parties to start negotiating transfer agreements, but it is unclear when the registration process required for credits to change hands will be up and running, say attorneys at Shearman.
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Using Agreements To Cover Gaps In Hydrogen Storage Regs
The Inflation Reduction Act's incentives for energy storage have spurred investment in hydrogen storage and production, but given the lack of comprehensive regulations surrounding the sector, developers should carefully craft project and financing agreements to mitigate uncertainties, say Omar Samji and Sarah George at Weil, and attorney Manushi Desai.
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Secure 2.0 Takeaways From DOL's 2024 Budget Proposal
The U.S. Department of Labor’s fiscal year 2024 budget proposal provides insight into the most pressing Secure 2.0 implementation issues, including establishment of a search database for finding lost retirement savings and developing guidance on the execution of newly authorized emergency savings accounts, say attorneys at Maynard Nexsen.
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Avoiding Negative Tax Consequences In Loan Modifications
Borrowers who may be caught in the dramatic uptick in nonperforming commercial real estate loans should consider strategies to avoid income and capital gains tax that may be triggered by loan modifications, says Aman Badyal at Glaser Weil.
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Benefits And Beyond: Fixing Employee Contribution Failures
Employers must address employee contribution failures promptly in order to avoid losing significant tax benefits of 401(k) or 403(b) plans, but the exact correction procedures vary depending on whether contributions were less than or greater than intended, say attorneys at Seyfarth Shaw.
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Now Is The Time For State And Local Sales Tax Simplification
In the five years since the U.S. Supreme Court’s landmark decision in South Dakota v. Wayfair, state and local governments increasingly rely on sales tax, but simple changes are needed to make compliance more manageable for taxpayers, wherever located, without unduly burdening interstate commerce, says Charles Maniace at Sovos.
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Recent Bills Show Congress' Growing Maturity On Cannabis
Though two recently introduced cannabis reform bills, the Prepare Act and the Small Business Tax Equity Act, are unlikely to pass in this Congress, they demonstrate a new level of focus and sophistication on the part of lawmakers as it relates to cannabis at the federal level, says Irina Dashevsky at Greenspoon Marder.
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What To Make Of IRS' New Advance Pricing Guidance
Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.
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Compliance Obligations Still Murky For Superfund Excise Tax
Comments on the IRS' reinstatement of the Superfund chemicals excise tax show that, given taxpayers' lack of institutional knowledge and the government's previous failure to finalize clarifying guidance, further regulatory action is needed to help taxpayers understand their obligations, say Nicole Elliott and Mary Kate Nicholson at Holland & Knight.
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The Reciprocal Tax Bill Is A Warning Shot At Pillar 2
A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.
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3 Developments That May Usher In A Nuclear Energy Revival
A recent advancement in nuclear energy technology, targeted provisions in the Inflation Reduction Act and a new G7 agreement on nuclear fuel supply chains may give nuclear power a seat at the table as a viable, zero-carbon energy source, say attorneys at Vinson & Elkins.
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What Tax-Exempt Orgs. Need From Energy Credit Guidance
Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.