President Joe Biden and fellow Democrats are racing to reach agreement on a scaled-back version of his economic agenda, with a self-imposed deadline and his departure later this week for summits in Europe intensifying pressure on negotiations. Read More

The White House said President Joe Biden made progress on his big tax-and-spending plan in a meeting with key moderate Senator Joe Manchin and Majority Leader Chuck Schumer, though further talks among staffers will be needed. Read More

Democratic lawmakers, with President Joe Biden’s support, are drawing up details of a plan to tax billionaires and other ultra-high earners after Senator Kyrsten Sinema’s opposition to raising the rate on corporations sank a key funding component for a multitrillion-dollar social-spending package. Read More

The White House’s concessions are piling up on President Joe Biden’s social-spending plan -- including climate, education and childcare provisions -- as negotiations continue into the weekend. Read More

Speaker Nancy Pelosi opened the door to Democrats using a special budget tool to raise the U.S. debt ceiling without the support of Senate Republicans, whose votes would otherwise be needed to end a filibuster on the increase. Read More

A failure to pass higher corporate taxes and additional levies on foreign income in the U.S. would mean that S&P 500 EPS will grow by 7% to $222, rather than current baseline forecast of 2% growth to $212, Goldman Sachs strategists led by David Kostin write in note. Read More

Employers generally won’t jeopardize their pension plan tax breaks if they rehire retirees or allow distributions of benefits to current workers who have reached retirement age, the Internal Revenue Service said Friday. Read More | Guideline Attached

Treasury Secretary Janet Yellen said she expects price increases to remain high through the first half of 2022, but rejected criticism that the U.S. risks losing control of inflation. Read More

Telecommunications company Liberty Global asked for a win without a trial in its $109 million challenge to federal regulations that it says run contrary to a portion of the 2017 tax law. Read More | Documents Attached

Several minor league baseball teams are latching onto Covid-relief money in a “walk-on-the-legal-wild-side” effort to preserve their patch of America’s pastime. Read More

A global mining giant’s Canadian subsidiary can’t remove millions in fees from its taxable income that it received as part of failed acquisition negotiations made decades ago, a court ruled. Read More | Document Attached

Cryptocurrency investors who receive a “nudge” letter from the U.K. about making tax payments should take them seriously, as ignoring them may carry serious penalties, tax advisers warn. Read More

Ireland has published a new draft law that would extend intercompany pricing rules to the taxation of foreign company branches in the country. Read More | Document Attached

Brigitte Alepin of the University of Quebec in Outaouais lays out the case for a minimum tax rate of 50% for billionaires. Read More

This week, our tax experts touched on a wide range of topics, from sales tax issues to transfer pricing. For a look at what’s making news, here’s our roundup. Read More

Group of airline pilots fighting FICA taxes paid on non-deferred compensation benefits have case dismissed for failure to follow court orders to submit short-form complaint, the Court of Federal Claims ... Read More | Opinion Attached

Where the extended six-year assessment period under tax code Section 6501(e)(1)(C) applies as a result of omitted subpart F income, the extended assessment period applies to the entire return ... Read More | Document Attached

Issuance of a Letter 627, Estate Tax Closing Letter, to an estate does not preclude the IRS from examining the return, the Chief Counsel’s Office informally advised. The IRS ... Read More | Document Attached

A case involving potential “Westbrooks” limitations on IRS assessment and collection of restitution imposed as a condition of a period of supervised release is not a Westbrooks case, the Chief ... Read More | Document Attached

A case in which a defendant was convicted solely of Title 26 (tax code) crimes after pleading not guilty is subject to “Westbrooks” limitations on IRS assessment and collection of ... Read More | Document Attached

Two cases involving false return preparation and potential “Westbrooks” limitations on IRS assessment and collection of restitution imposed as a condition of a period of supervised release are not Westbrooks ... Read More | Documents Attached

Rehires following bona fide retirement and in-service distributions frequently asked questions posted to IRS website October 22. If an employee who has a bona fide retirement and begins benefit distributions ... Read More | Document Attached

The IRS October 22 released Internal Revenue Bulletin 2021-43, dated October 25, 2021, containing the following previously released items: Notice 2021-58 (COBRA continuation coverage) and Notice 2021-59 (foreign currency regulations ... Read More | Document Attached

Draft Form 7203, S Corporation Shareholder Stock and Debt Basis Limitations, released October 21 to be used in figuring a shareholder’s stock and debt basis which replaces a three-part ... Read More | Document Attached

Employers reminded that they generally will not jeopardize the tax status of their pension plans if they rehire retirees or permit distributions of retirement benefits to current employees who have ... Read More | Document Attached

Families, teens and senior citizens reminded about the continued importance of protecting personal and financial information online despite the IRS and its Security Summit partners continuing to make strides in ... Read More | Document Attached

Public comments released October 22 on Notice 2021-56 providing standards that a limited liability company (LLC) must satisfy to receive a determination letter recognizing it as tax-exempt under tax code ... Read More | Document Attached

A consolidated group parent that experienced an ownership change received extra time to elect under Treasury Regulations Section 1.382-6(b) to allocate its net operating loss or taxable income and ... Read More | Documents Attached

A corporate group parent operating in multiple currencies may change its spot rate convention to the method it proposed for computing monthly exchange gain or loss with respect to payables ... Read More | Document Attached

An electric and natural gas utility is not permitted under the normalization rules of tax code Section 168(i)(9), former Section 167(l), and Tax Cuts and Jobs Act (Pub. ... Read More | Document Attached

A partnership received extra time to make an election under tax code Section 856(c)(1) to be treated as a real estate investment trust (REIT) for a certain tax year, ... Read More | Document Attached

The ineffectiveness of a small business corporation’s (“X”) S election, caused by its having an ineligible shareholder — a trust for which no electing small business trust (ESBT) election was ... Read More | Document Attached

The termination of a small business corporation’s (“Company”) subchapter S classification election as a result of its signing an operating agreement that included partnership-contemplating provisions (thus creating an impermissible second ... Read More | Document Attached

Grant making program to award scholarships annually to graduating high school seniors that are children of employees of B and C stores approved. The grant program will meet the requirements ... Read More | Document Attached

Grant making program to award scholarship to an entire elementary third -grade class selected due to being in underserved neighborhood and obtaining a specific percentage of students receiving free or ... Read More | Document Attached

Any “Company X” stock that a public charity receives from a trust pursuant to an agreement with a private foundation and the terms of a decedent’s will won’t be treated ... Read More | Document Attached

Guidelines and general requirements for the development, printing, and approval of the 2021 substitute tax forms, the IRS provided October 22. The forms covered are: (1) IRS tax forms and ... Read More | Document Attached

AICPA October 22 publicly released comments supporting S. 2583, the Disaster Retirement Savings Act, that would permanently remove financial penalties for individuals impacted by natural disasters who choose to use ... Read More | Document Attached