Federal

  • June 28, 2024

    Spouse's Prenup Payments Count As Income, IRS Says

    Support payments to a taxpayer from a former spouse made before they officially divorce constitute alimony and should be included in the taxpayer's gross income, the Internal Revenue Service said in a private letter ruling released Friday.

  • June 28, 2024

    IRS Revokes Variable Annuity Ruling From 2014

    The IRS revoked part of a 2014 private letter ruling regarding an annuity option with variable payments that a taxpayer had planned to offer, saying in a ruling released Friday that it no longer agreed with its former position.

  • June 28, 2024

    Taxation With Representation: Kirkland, Vinson, Skadden

    In this week's Taxation with Representation, Aareal Bank AG and Advent International sell a property management and maintenance software company, Webtoon Entertainment Inc. and Tamboran Resources Corp. price initial public offerings, SM Energy Company acquires oil and gas assets, and Nokia sells Alcatel Submarine Networks to the French state.

  • June 28, 2024

    Estate Owes $4.9M For Son-Of-Boss Scheme, US Says

    An estate owes $4.9 million in tax liabilities for a couple's scheme to artificially cancel out their capital gains, the federal government said in a complaint in Michigan federal court, arguing that the Son-of-Boss scheme constitutes fraud and its proceeds aren't entitled to bankruptcy protection.

  • June 28, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included an extension of the penalty relief for entities that fail to make estimated quarterly payments of the corporate alternative minimum tax.

  • June 28, 2024

    Supreme Court Strikes Down Chevron Deference

    The U.S. Supreme Court on Friday overturned a decades-old precedent that instructed judges about when they could defer to federal agencies' interpretations of law in rulemaking, depriving courts of a commonly used analytic tool and leaving lots of questions about what comes next.

  • June 27, 2024

    Biden, Trump Spar Over Fate Of 2017 Tax Cuts In 1st Debate

    President Joe Biden and former President Donald Trump debated the GOP's 2017 tax policy overhaul Thursday night, with Trump praising its economic benefits and Biden criticizing the tax cuts for favoring the wealthy and increasing federal deficits.

  • June 27, 2024

    IRS To Offer Combined Filing For Energy Investment Credits

    The Internal Revenue Service will let clean energy project owners that are claiming investment tax credits for more than 200 facilities file the claims with a single form, an agency official said Thursday.

  • June 27, 2024

    Corp. Tax Cuts Worsen Racial, Income Inequality, Report Says

    In the first year of a corporate tax break, white U.S. households receive 88% of the benefits while Black and Hispanic households each receive just 1%, according to a study published Thursday by the Institute on Taxation and Economic Policy and an advocacy organization.

  • June 27, 2024

    TurboTax Maker Wipes Out 2 Of 3 Software Patents At PTAB

    The Patent Trial and Appeal Board delivered a mixed bag of decisions in patent challenges brought by Intuit against a small software outfit that claims to have invented the idea of "co-browsing."

  • June 27, 2024

    High Response To IRS Transfer Pricing Letters, Official Says

    Most taxpayers that received letters from the Internal Revenue Service pursuant to a compliance campaign warning them of a transfer pricing issue have responded, an IRS official said Thursday.

  • June 27, 2024

    Congress Shouldn't Rush OECD Tax Package, Group Says

    Congress should avoid "rubber-stamping" the two pillars of the Organization for Economic Cooperation and Development's plan to fight tax base erosion and profit shifting and instead gather more information on its impact on the U.S., a conservative advocacy group said Thursday.

  • June 27, 2024

    IRS Criminal Chief Says COVID Fraud Work To Hold Steady

    IRS Criminal Investigation agents expect to spend as much time this year on coronavirus assistance policy-related fraud as last year, the division chief said at a conference Thursday.

  • June 27, 2024

    IRS Tells 10th Circ. To Deny Liberty Global's $110M Refund Bid

    The U.S. government urged the Tenth Circuit on Thursday to reject telecommunication giant Liberty Global's push for a $110 million tax refund, arguing a lower court correctly deduced that the company's business restructurings were carried out solely to avoid tax.

  • June 27, 2024

    $2.1B Danish Tax Fraud Suspect Won't Testify, Court Says

    A New York federal court denied dueling requests from U.S. pension plan investors accused of participating in a $2.1 billion Danish tax fraud scheme and from Denmark's tax agency to bring in the man that both sides say masterminded the scheme, or to bring in one of his employees.

  • June 27, 2024

    Ex-Skadden Tax Head And M&A Pro Joins Freshfields In NY

    Freshfields Bruckhaus Deringer LLP has added the former head of the tax practice at Skadden Arps Slate Meagher & Flom LLP as a partner this week, who brings to the role experience in deals like 21st Century Fox's $71 billion acquisition by Disney and the merger of T-Mobile and Sprint.

  • June 27, 2024

    TIGTA Points To Areas Of Improvement For Direct File

    A phase of the Direct File pilot program that allowed eligible IRS employees to get the first crack at the online tax filing service had issues with accuracy of its tax returns and lacked a Spanish translation, the Treasury Inspector General for Tax Administration said Thursday.

  • June 27, 2024

    New FATCA Deal Requires US Banks To Share Info With Swiss

    The United States and Switzerland signed a Foreign Account Tax Compliance Act agreement that will require U.S. banks to share financial account information on a bilateral basis, Switzerland's Federal Department of Finance announced Thursday.

  • June 27, 2024

    IRS Delays Tax Deadlines In Miss. After April Storms

    Certain Mississippi taxpayers affected by storms, tornadoes and flooding that hit the state starting April 8 now have until Nov. 1 to file individual and business tax returns and make payments, the Internal Revenue Service said Thursday.

  • June 26, 2024

    Repatriation Tax Ruling May Sway State Wealth Tax Debates

    The U.S. Supreme Court's upholding of the federal repatriation tax could indirectly affect state tax policy discussions, including by influencing consideration of wealth taxes and encouraging states to keep potential due process issues in mind when enacting tax legislation.

  • June 26, 2024

    Tax Court Says Couple Wrongly Claimed Unsigned Checks

    A Minnesota eye doctor and his wife overstated their income on their joint tax return, as they declared pay that they never actually received from their corporation in the form of unsigned checks, the U.S. Tax Court said in an opinion released Wednesday.

  • June 26, 2024

    IRS To Make Syndicated Easement Settlement Offers

    The Internal Revenue Service will send settlement offers next month to some taxpayers who participated in syndicated conservation easement deals that the agency is auditing, it announced Wednesday.

  • June 26, 2024

    Advice Panel Calls For Regulating Noncredentialed Preparers

    Congress should authorize the Internal Revenue Service to regulate noncredentialed tax preparers to protect taxpayers and the tax system from erroneous returns, the agency's Electronic Tax Administration Advisory Committee said in its annual report to lawmakers Wednesday.

  • June 26, 2024

    9th Circ. Revives $491K Refund Error Recovery Suit

    The Ninth Circuit resurrected Wednesday an IRS suit that seeks to recover more than $491,000 from a taxpayer to whom the agency erroneously mailed a refund, reversing a lower court decision that dismissed the case for falling outside the two-year statute of limitations.

  • June 26, 2024

    5th Circ. Affirms Block On ARPA Tax Rule For Texas, La., Miss.

    A Texas federal judge properly ruled that the federal government could not enforce a provision in the American Rescue Plan Act that prohibits states from using pandemic aid to offset tax cuts, the Fifth Circuit said.

Expert Analysis

  • 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.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

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    As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.

  • How IRA Unlocks Green Energy Investments For Tribes

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    An Inflation Reduction Act provision going into effect May 10 represents a critical juncture for Native American tribes, offering promising economic opportunity in green energy investment, but requiring a proactive and informed approach when taking advantage of newly available tax incentives, say attorneys at Lewis Brisbois.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

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    Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.

  • What To Know About IRS' New Jet Use Audit Campaign

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    The Internal Revenue Service recently announced plans to open several dozen audits scrutinizing executive use of company jets, so companies should be prepared to show the business reasons for travel, and how items like imputed income and deduction disallowance were calculated, say attorneys at Morgan Lewis.

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