News & Analysis as of

Internal Revenue Service Settlement

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Proskauer Rose LLP

Wealth Management Update - September 2024 - 2

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September 2024 AFRs and 7520 Rate - The September 2024 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 4.8%, a decrease from the August 2024 rate of 5.2%. The September...more

Polsinelli

Real or Ruse? IRS’s New Settlement Initiative for Syndicated Conservation Easements

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The Internal Revenue Service (IRS) recently announced a new settlement initiative for Syndicated Conservation Easements (SCEs) that are currently under audit and have not reached the Tax Court. This new settlement initiative...more

Morris, Manning & Martin, LLP

DOJ Settles Conservation Easement Case

The Department of Justice has reached a settlement in Townley, a case concerning a $43 million conservation easement deduction. Earlier this year, I wrote an article highlighting a case in which, by most measures, the IRS...more

Chambliss, Bahner & Stophel, P.C.

Is a Personal Injury Settlement Taxed?

Approximately 6 percent of adult Americans experience an activity-limiting injury every three months, according to the Centers for Disease Control and Prevention (CDC). Injuries can happen because of carelessness, such as...more

ArentFox Schiff

Investigations Newsletters: Georgia Laboratory Owner Pleads Guilty to Felony Anti-Kickback Statute Violations

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Georgia Laboratory Owner Pleads Guilty to Felony Anti-Kickback Statute Violations - On February 28, the US Department of Justice (DOJ) announced the guilty plea of Andrew Maloney, who, along with his clinical laboratory...more

Allen Barron, Inc.

Tax Updates and Information for US Expatriates

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US tax filing is underway, and as we approach the April 15 deadline we would like to offer additional tax updates and information for US expatriates. The first and most important thing for US expatriates to know about taxes...more

Lippes Mathias LLP

IRS Halts Processing of ERC Claims Citing Extensive Fraud and Abuse

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In an extraordinary development, the IRS has halted its processing of Employee Retention Credit (“ERC”) refund claims as it struggles to keep up with the massive number of claims filed within the last several months. The...more

ArentFox Schiff

Investigations Newsletter: Arkansas Men Convicted in $18 Million Global Investment Fraud Conspiracy

ArentFox Schiff on

Arkansas Men Convicted in $18 Million Global Investment Fraud Conspiracy - A federal jury in the Western District of Arkansas convicted four men of conspiracy to commit wire fraud, wire fraud, and conspiracy to commit money...more

Flaster Greenberg PC

Tax Pitfalls To Avoid In Employment Litigation Settlements

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By all measures, 2021 was a banner year for hiring, but 2022 and 2023 have been the opposite. According to one media source, more than 121,000 jobs in the technology sector alone — think Google LLC, Amazon.com Inc.,...more

ArentFox Schiff

Guilty Plea in $250 Million Federal Child Nutrition Fund Fraud Scheme

ArentFox Schiff on

Guilty Plea in $250 Million Federal Child Nutrition Fund Fraud Scheme - A man from Brooklyn Park, Minneapolis, Minnesota, pled guilty for his involvement in a $250 million fraud scheme that exploited a federally-funded...more

Nilan Johnson Lewis PA

Recommendations for Nonprofits After the Minnesota Attorney General Settlement for Self-Dealing

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A nonprofit recently settled with the Minnesota Attorney General due to conflicts of interest and allegations of self-dealing. While it may be easy to dismiss the settlement as an example of a sham nonprofit obviously...more

Freeman Law

[Webinar] Updates: IRS Tax Enforcement, Taxation of Settlements, and Cross-Border Tax Planning - August 31st, 3:00 pm CT

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Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights. During this information-filled...more

Skadden, Arps, Slate, Meagher & Flom LLP

Final Regulations Clarify Rules on Deductions for Judgments and Settlement Payments in Government Disputes

On January 12, 2021, the Treasury Department (Treasury) and the IRS released final regulations under Section 162(f) and Section 6050X of Title 26 of the U.S. Code. Section 162(f), as amended by the Tax Cuts and Jobs Act of...more

Littler

Tax Court Reiterates the Proper Tax Treatment of “Physical Injuries” in Employment Cases

Littler on

In Stassi v. Commissioner, the United States Tax Court found that a settlement was not excludable from income as a personal physical injury because the taxpayer failed to demonstrate that her shingles was caused by her...more

ArentFox Schiff

Investigations Newsletter: DOJ’s 2020 False Claims Act Recoveries Lowest Since 2008

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DOJ’s 2020 False Claims Act Recoveries Lowest Since 2008 - On January 14, 2021, the Department of Justice (DOJ) announced that it obtained more than $2.2 billion in settlements and judgments from civil cases involving...more

Freeman Law

Are Lawsuit or Settlement Damages Taxable?

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Taxpayers who suffer from physical injuries or physical sickness can generally take advantage of a special provision in the Code that makes such damages non-taxable. See I.R.C. § 104(a)(2). Generally, this can be an easy...more

Freeman Law

[Webinar] Freeman Law Legal and Tax Update - October 27th, 3:00 pm CT

Freeman Law on

As businesses face unprecedented challenges, our legal team is here with insights and guidance. Join us as we discuss important developments during these unique times, and bring you up to speed on current initiatives. During...more

Mitchell, Williams, Selig, Gates & Woodyard,...

IRS Announces Settlement Program for Certain Conservation Easement Cases Docketed in the Tax Court

In News Release 2020-130 issued yesterday, the IRS Office of Chief Counsel announced a time-limited settlement offer for certain taxpayers with pending docketed Tax Court cases involving syndicated conservation easement...more

Skadden, Arps, Slate, Meagher & Flom LLP

Highlights From the Recently Issued Proposed Regulations Under Sections 162(f) and 6050X

On May 13, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations under Sections 162(f) and 6050X of the Internal Revenue Code regarding the disallowance of deductions for certain amounts...more

Kramer Levin Naftalis & Frankel LLP

New Treasury Regulations Address Disallowance of Deductions for Fines, Penalties and Other Amounts

On May 12, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-104591-18) that address the disallowance of deductions for amounts paid or incurred for...more

Haug Partners LLP

Don’t Get Caught In the Conflict: U.S. Versus Brazilian IP Transfer Pricing Rules

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During a 2019 Tax Executives Institute conference in Washington, D.C., the Commissioner of the U.S. Internal Revenue Service (IRS), Charles Rettig, proclaimed, “[I am] not a commissioner who believes that the IRS loses...more

Robins Kaplan LLP

Financial Daily Dose 2.10.2020 | Top Story: Volvo May go Public Via Merger With Owner’s Geely Automobile Holdings

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Volvo’s owner, Li Shufu, is mulling over a move to combine the carmaker with his publicly traded Geely Automobile Holdings—a play that would take Volvo public and “unify the bulk of billionaire Li’s growing stable of...more

Jones Day

Jones Day Presents: Large Business & International Examination Strategies: Fast Track Settlements

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In the fifth installment of Jones Day's series of video presentations on the IRS's Large Business & International Division ("LB&I") exam procedures, partner and tax litigator Chuck Hodges explains how the IRS's new fast track...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Settlements should encourage vigilance

While 2018 may have had less 401(k) litigation than the previous year, there was more than $90 million in settlements....more

Cozen O'Connor

November 13, 2018 Deadline Approaching For Comments On IRS Rules Relating To Reporting And Tax Deductions Of State AG Settlements

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The process of ironing out settlements of state attorney general (“AG”) investigations and litigations is likely to get more complicated. The 2017 Tax Cuts and Jobs Act (“Act”), among the many other things it did, amended a...more

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