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Adam Spiegel

Adam Spiegel is an associate in the firm’s Washington, DC office and a member of the Tax practice group. He has advised clients on various tax controversy and planning matters, including both international and domestic tax issues. Adam also advises clients on tax credit matters related to the Chips & Science Act and the Inflation Reduction Act. Based on his previous experience in the Employee Benefits group, Adam also advises on worker classification and employment tax issues.

Adam has worked with a variety of clients, including clients in the pharmaceutical, technology, and sports industries.

Prior to joining Covington, Adam clerked for Judge R. Lanier Anderson III of the United States Court of Appeals for the Eleventh Circuit.

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The House of Representatives continues work on a reconciliation bill that would enact significant tax provisions and spending cuts.  The various legislative committees have completed work on the areas of the bill within their jurisdiction, including the Ways and Means Committee, which proposed language that would enact $3.8 trillion in tax cuts over the next ten years.  Over the weekend, the House Budget Committee consolidated the legislation, and the House Bill is now before the Rules Committee, where a managers’ amendment may be considered before it heads to the House floor.  This article is one of a series of articles discussing various proposals in the legislation that touch on tax withholding, reporting, and fringe benefits.

The House Bill proposes to increase the thresholds under current law for information returns required under sections 6041 and section 6050W, as described in more detail below, as well as to modify section 3406 (requiring backup withholding) to align with this proposed change.  Continue Reading House Reconciliation Bill Would Increase Thresholds for Reporting Obligations under Sections 6041 and 6050W

On March 9, 2023, the U.S. Department of Treasury released the Greenbook (formally known as the General Explanation of the Administration’s Revenue Proposals) for FY 2024 to explain revenue proposals included in the Administration’s budget.  One proposal is to increase the number of hours required to be worked by an individual for the employer to be eligible for the Work Opportunity Tax Credit (WOTC).Continue Reading Treasury Greenbook Includes Proposal to Alter Work Opportunity Tax Credit

On February 28, 2023, the Supreme Court decided Bittner v. United States—a rare Supreme Court foray into Financial Crimes Enforcement Network or FinCEN reporting of foreign bank and financial accounts under the Bank Secrecy Act (“BSA”).  The BSA is codified under Title 31 (Money and Finance) of the United States Code rather than Title 26 (the Internal Revenue Code) so the section references in this post are to Title 31.  At issue was how to calculate penalties for nonwillful violations of the BSA’s recordkeeping and reporting obligations for foreign transactions and accounts.  By a narrow 5-4 majority, the Supreme Court held that the penalty for a nonwillful violation of the reporting requirements shall be assessed on a per-form basis rather than a per-account basis, a result favorable for those taxpayers with nonwillful failures.

Continue Reading Supreme Court Limits Penalties for Nonwillful FBAR Failures in Bittner Decision