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Weak Link Doomed $690M Whistleblower Claim, DC Circ. Says

by usoftax_admin | Aug 7, 2024 | Tax News

A whistleblower could not get up to $690 million, or 30% of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program, because the connection between his actions and the program was weak, the D.C. Circuit said Wednesday.

NJ Tax Agency Seeks Required Bids For Transfer Pricing Aide

by usoftax_admin | Aug 7, 2024 | Tax News

New Jersey is seeking bids to contract with a transfer pricing specialist because the state’s agreement with a prominent economist who helped draft the federal government’s transfer pricing rules can’t be renewed without a competitive process, a...

Loper Bright Limits Federal Agencies’ Ability To Alter Course

by usoftax_admin | Aug 7, 2024 | Tax News

The U.S. Supreme Court’s recent decision to dismantle Chevron deference also effectively overrules its 2005 decision in National Cable & Telecommunications Association v. Brand X, greatly diminishing agencies’ ability to change regulatory course from...

Waste Co. Not Entitled To Audit Records, IRS Tells Court

by usoftax_admin | Aug 7, 2024 | Tax News

Garbage-hauling giant Waste Management Inc. is not entitled to the IRS’ tax files on the company from 2017, including audit records, because some documents contain return information of third parties, the agency said Wednesday.

5th Circ. Grapples With ‘Ridiculous’ $100M Arbitration

by usoftax_admin | Aug 7, 2024 | Tax News

A Fifth Circuit panel struggled to make sense out of a “ridiculous” arbitration proceeding that produced four contradictory arbitration awards in a legal malpractice dispute, one awarding $100 million, pressing both sides during oral arguments Wednesday to...

‘Looting’ Of Co. Doesn’t End S Corp. Status, Tax Court Says

by usoftax_admin | Aug 7, 2024 | Tax News

While a co-owner of a California S corporation may have been the victim of two other owners “looting” the company through disproportionate distributions, such actions didn’t dissolve its S corporation status, the U.S. Tax Court ruled Wednesday.
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