Federal

  • June 06, 2024

    Justices Affirm Taxing Of Estate On Insurance Payout

    The U.S. Supreme Court affirmed on Thursday a decision denying a tax refund to the estate of an owner of a building materials company that used a payout from his $3.5 million life insurance policy to purchase his shares in the business.

  • June 05, 2024

    CohnReznick Scores Quick Exit In Tax Scheme Suit

    A New York federal judge agreed to toss a housing partnership's suit accusing accounting firm CohnReznick LLP of professional negligence and fraud, finding that the district court doesn't have jurisdiction over the dispute.

  • June 05, 2024

    IRS Must Better Log AI Use In Tax Gap Estimates, GAO Says

    The Internal Revenue Service needs to complete documentation on its use of artificial intelligence models as part of a plan to improve its tax gap estimates, the Government Accountability Office said Wednesday.

  • June 05, 2024

    Californian Failed To Report Missing Income, Tax Court Says

    A California woman's contention that she should not be accountable for a deficiency in her 2021 tax filing due to what she said was an error by her accountant doesn't stand up under scrutiny, the U.S. Tax Court said Wednesday.

  • June 05, 2024

    Some Payments After Train Derailed Aren't Taxable, IRS Says

    Certain payments from Norfolk Southern Corp. to victims of its freight train derailment and toxic chemical spill in East Palestine, Ohio, are considered disaster relief payments and are therefore not taxable, the Internal Revenue Service said Wednesday.

  • June 05, 2024

    House Panel Tees Up $2B In IRS Cuts For Full Committee Vote

    A House Appropriations subcommittee approved legislation Wednesday that would reduce Internal Revenue Service funding for fiscal 2025 by over $2 billion and prohibit money from going to the agency's free online tax-filing program without congressional approval.

  • June 05, 2024

    Win May Embolden IRS Use Of Economic Substance Doctrine

    The IRS' successful wielding of the economic substance doctrine to characterize multinational telecommunications corporation Liberty Global's sophisticated set of intercompany deals as an abusive tax shelter could encourage the agency to apply similar analysis to even the most basic tax transactions.

  • June 05, 2024

    IRS Presses Justices To Weigh In On Tax Challenge Deadline

    The IRS urged the U.S. Supreme Court to overturn a Third Circuit decision finding the U.S. Tax Court's 90-day deadline for challenging tax bills is not set in stone, arguing the couple defending the ruling are wrongly relying on a 2022 high court decision.

  • June 05, 2024

    Billionaire's 'Naive' Stock-Trading Pilot Asks For No Prison

    A private pilot for U.K. billionaire Joe Lewis is asking for no prison time after pleading guilty to insider trading on stock tips provided by his boss, arguing that he has otherwise lived a law-abiding life and is less culpable than many white-collar defendants who've come through the Manhattan federal court.

  • June 05, 2024

    Taxpayer Advocacy Committee Meeting Moved Up

    The Internal Revenue Service moved up an open meeting of the Taxpayer Advocacy Panel's Notices and Correspondence Project Committee to June 18, it said Wednesday.

  • June 04, 2024

    Full DC Circ. Asked To Weigh Foreign Info Disclosure Penalties

    A D.C. Circuit panel made questionable assumptions about congressional intent when it revived the IRS' authority to assess and administratively collect penalties related to undisclosed foreign corporations, a businessman said Tuesday in asking the full appellate court to hear his case.

  • June 04, 2024

    Sen. Leaders Press Biden's Tax Court Nominees On Fairness

    Senate Finance Committee leaders pressed President Joe Biden's three new judicial nominees for the U.S. Tax Court to explain Tuesday how they would extend fair treatment to taxpayers if they are confirmed.

  • June 04, 2024

    Aflac Matriarch's Estate Owes $1.9M Penalty, Tax Court Told

    The Internal Revenue Service is seeking an additional accuracy penalty of over $1.9 million from the estate of the matriarch of the family that founded Aflac, according to a filing in the U.S. Tax Court.

  • June 04, 2024

    Tax Law Firm Can't Kick Ex-Clients' Class Suit To Arbitration

    Former clients of a Florida-based tax law firm who live in Wisconsin can move forward with their proposed class action accusing the firm of malpractice and charging illegal fees, a Wisconsin federal judge ruled Tuesday, rejecting the firm's requests to toss the suit or move it to arbitration.

  • June 04, 2024

    Tax Court Turns Down Whistleblower's Push To Boost Award

    Though a tax whistleblower contended he should be entitled to a reward based on the entire amount of deficiencies discovered in a large investigation, the IRS was right to calculate his reward based only on the specific taxpayer he identified, the U.S. Tax Court said Tuesday.

  • June 04, 2024

    House Bill Would Cut $2B In IRS Funding, Restrict Direct File

    The chairman of the House Appropriations subcommittee that handles Internal Revenue Service funding introduced legislation Tuesday to cut that funding for fiscal 2025 by over $2 billion and prohibit money from going to the agency's free online tax-filing program without congressional approval.

  • June 04, 2024

    11th Circ. Affirms Nix Of IRS Easement Disclosure Guidance

    The Eleventh Circuit affirmed Tuesday that an Internal Revenue Service notice imposing reporting requirements on potentially abusive conservation easements was invalid because the agency failed to solicit the public feedback required by administrative law.

  • June 04, 2024

    IRS Announces 6 Tax Court Sessions Added To Calendar

    The Internal Revenue Service announced six U.S. Tax Court sessions in October and named calendar administrators for the sessions in a notice released Tuesday.

  • June 04, 2024

    IRS Didn't Have To Tell Man About Summonses, 5th Circ. Told

    The Internal Revenue Service wasn't required to tell a Texas man with unpaid tax liabilities that it had demanded his financial information from third parties, the agency told the Fifth Circuit, urging it to affirm a lower-court decision tossing the man's suit challenging the summonses.

  • June 03, 2024

    FTX, IRS Propose Settling $8B Tax Fight For Just $885M

    FTX and the Internal Revenue Service have reached a proposed settlement worth roughly $885 million that would resolve the agency's contention that the bankrupt cryptocurrency exchange operator owes $8 billion in taxes, according to a motion filed Monday in Delaware federal bankruptcy court.

  • June 03, 2024

    Danish Tax Agency Says $2.1B Tax Fraud Suits Not Filed Late

    Denmark's tax administrator urged a New York federal court to reject bids to toss its suits against U.S. pension plans and individuals it accuses of participating in a $2.1 billion fraud scheme, saying the suits were not filed too late.

  • June 03, 2024

    Treasury Aims To Salvage Corp. Transparency Act At 11th Circ.

    The Corporate Transparency Act is a valid exercise of congressional authority to curb money laundering under the commerce clause and the necessary and proper clause in the Constitution, the U.S. Treasury Department told the Eleventh Circuit on Monday in a bid to restore the law's reporting requirements.

  • June 03, 2024

    Suzanne Somers' Estate Owes $2.7M, Tax Court Says

    Television producer Alan Hamel and the estate of his wife, actor Suzanne Somers, owe nearly $2.7 million in taxes and penalties going back to 1996 related to losses in a partnership, the U.S. Tax Court ruled Monday.

  • June 03, 2024

    IRS Correctly Denied Man Collection Alternative, Court Says

    The Internal Revenue Service did not abuse its discretion when rejecting a Florida man's collection alternative request, the U.S. Tax Court said Monday.

  • June 03, 2024

    Couple Can't Justify $3.7M Loss Deduction, Tax Court Says

    A New York couple failed to adequately prove that they should have been able to claim $3.7 million in net operating losses on their personal income taxes that were generated by settlement payments made by a company they owned, the U.S. Tax Court said Monday.

Expert Analysis

  • A Proposal For Fairer, More Efficient Innocent Spouse Relief

    Author Photo

    Adding a simple election to the current regulatory framework for innocent spouse claims would benefit both taxpayers and the Internal Revenue Service by alleviating the undue burdens placed on those the program was intended to help and improving agency collections in such cases, says Laurie Kazenoff at Kazenoff Tax.

  • 7 Common Myths About Lateral Partner Moves

    Author Photo

    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • Proposed Hydrogen Tax Credit Regs May Be Legally Flawed

    Author Photo

    While the recently proposed regulations for the new clean hydrogen production tax credit have been lauded by some in the environmental community, it is unclear whether they are sufficiently grounded in law, result from valid rulemaking processes, or accord with other administrative law principles, say Hunter Johnston and Steven Dixon at Steptoe.

  • Navigating ACA Reporting Nuances As Deadlines Loom

    Author Photo

    Stephanie Lowe at Liebert Cassidy walks employers through need-to-know elements of Affordable Care Act reporting, including two quickly approaching deadlines, the updated affordability threshold, strategies for choosing an affordability safe harbor, and common coding pitfalls.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

    Author Photo

    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • Why Biz Groups Disagree On Ending Chevron Deference

    Author Photo

    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.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

    Author Photo

    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.

  • A Look Ahead For The Electric Vehicle Charging Industry

    Author Photo

    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.

  • A Post-Mortem Analysis Of Stroock's Demise

    Author Photo

    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.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

    Author Photo

    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.

  • Planning A Defense As IRS Kicks Off Sports Losses Campaign

    Author Photo

    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.

  • What New Calif. Strike Force Means For White Collar Crimes

    Author Photo

    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.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

    Author Photo

    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.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.