Federal
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June 13, 2024
Senate Finance Panel OKs 3 Tax Court Judges, Treasury IG
The Senate Finance Committee overwhelmingly approved Thursday the nominations of three judges for the U.S. Tax Court and a new inspector general for the U.S. Department of the Treasury, a post that has lacked a Senate-confirmed nominee for five years.
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June 13, 2024
Easement Deduction Limit Hurts Conservation, 11th Circ. Told
A partnership's tax deduction for its donation of a conservation easement should not be limited to its adjusted basis in the property, the partnership told the Eleventh Circuit in urging it to overturn a U.S. Tax Court decision that it claims will hurt conservation efforts.
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June 13, 2024
A Chronology Of The Hunter Biden Investigation
The story behind President Joe Biden's son Hunter Biden's conviction on federal gun charges started with a gun purchase in 2018, was complicated by a laptop repair in 2019, and could bleed into an upcoming trial on federal tax charges in California in September.
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June 13, 2024
Mo. City Tax Credit Suit Tossed Over Federal Jurisdiction
A federal judge dismissed a Kansas City, Missouri, resident's claims that the city unconstitutionally refused to credit his state income taxes paid to Kansas against his city earnings tax liabilities, ruling that a federal law barred the case from being lodged in federal court.
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June 13, 2024
IRS Extends Corp. AMT Penalty Relief Into August
The Internal Revenue Service will continue to provide penalty relief for entities that fail to make estimated quarterly payments of the corporate alternative minimum tax through Aug. 15, the agency said Thursday.
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June 12, 2024
Senate Budget Chair Seeks End To Carried Interest Tax Break
Lawmakers should end the favorable tax treatment of income from carried interest compared with ordinary earned income, Senate Budget Committee Chairman Sheldon Whitehouse said Wednesday.
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June 12, 2024
Feds Strike Deal Ending $7M FBAR Penalty Cases
The U.S. government agreed to settle a pair of foreign bank account reporting cases in which it had sought a total of $7 million from a former insurance broker and his wife's estate, according to a court order filed Wednesday in California federal court.
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June 12, 2024
Groups Push Back On Stock Buyback Tax Test's Scope
The U.S. Treasury Department's proposed stock buyback tax rules go too far in trying to assess whether the main purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, two groups said in comments released Wednesday.
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June 12, 2024
St. Louis Atty Urges Acquittal After Tax Avoidance Conviction
A Missouri attorney who was found guilty of participating in a $4 million tax avoidance scheme alongside her father and a North Carolina insurance agent is looking to wipe out the verdict, arguing there wasn't enough evidence to convict.
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June 12, 2024
IRS Nix Of $45M Easement Deduction Invalid, Donor Says
A North Carolina partnership asked the U.S. Tax Court to invalidate an Internal Revenue Service adjustment that slashed its $45.6 million deduction for its donation of a conservation easement, saying the agency failed to follow proper administrative procedures.
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June 12, 2024
Treasury Issued Over $1B In Clean Vehicle Tax Credits
The clean vehicle tax credit of up to $7,500 has saved buyers more than $1 billion in total upfront costs since January, the U.S. Treasury Department announced Wednesday, saying the figures represent a major milestone in lowering transportation costs since the incentive was updated in 2022.
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June 12, 2024
First 'Survivor' Winner Wants $3M Tax Case Tossed
The winner of the first season of the TV series "Survivor" asked a Rhode Island federal court to toss the government's case against him seeking nearly $3.3 million in unpaid taxes, saying the liabilities stem from his flawed criminal conviction for tax evasion nearly 20 years ago.
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June 12, 2024
4 Taxpayer Advocacy Panel Committees To Meet In July
Four Taxpayer Advocacy Panel committees will hold public meetings in July focused on improving customer service at the Internal Revenue Service, the agency announced Wednesday.
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June 11, 2024
SVB Wants A Trial Over Its $605M Tax Bill From IRS
The parent company of failed Silicon Valley Bank has told a New York bankruptcy judge it wants him to decide if it owes the Internal Revenue Service more than $605 million in taxes.
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June 11, 2024
US Issues Sanctions For $50M Guyana Gold Tax Evasion
Two Guyanese businessmen and a Guyanese official were sanctioned by the U.S. Treasury Department on Tuesday after a probe into a corruption scheme that helped the businessmen evade $50 million in gold export taxes that should have been paid to Guyana's government, Treasury said.
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June 11, 2024
Aflac Matriarch's Estate Says IRS Missing Info In $11.7M Fight
The Internal Revenue Service's push to recover $11.7 million in deficiencies and penalties from the estate of the matriarch of the family that founded Aflac is predicated on a "mistaken understanding" regarding a trust, the estate told the U.S. Tax Court.
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June 11, 2024
Compliance Costs Outweigh Min. Tax Gains, Biz Reps Say
Multinational businesses are concerned that the burden of complying with the 15% global minimum tax outweighs any potential revenue gains associated with the burgeoning system, tax attorneys and a trade association representative said during a panel Tuesday.
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June 11, 2024
House Panel Chair Seeks To End Media Org's Tax Exemption
The House's top tax writer wants the Internal Revenue Service to revoke the tax-exempt status of a nonprofit Mideast-focused news outlet, telling Commissioner Daniel Werfel that the organization is aiding Hamas.
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June 11, 2024
Lawmakers Urge Biden To Back Brazil's Int'l Wealth Tax Plan
Sen. Bernie Sanders and Democratic lawmakers asked the Biden administration Tuesday to support the global minimum tax on billionaires being proposed by Brazil, which is encouraging the Group of 20 nations to endorse the initiative at its meetings next month.
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June 11, 2024
Kostelanetz Partners Talk Benefits Of Atlanta Tax Firm Tie-Up
Kostelanetz LLP partners Bryan Skarlatos and Todd Welty discuss the firm’s recent combination with Atlanta boutique Welty PC.
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June 11, 2024
Charity Founder Charged With Embezzling $2.5M, Evading Tax
The founder of a New York City charity embezzled $2.5 million in donations meant for low-income families and then failed to report the earnings to the Internal Revenue Service or pay tax on them, according to a criminal complaint unsealed Tuesday in New York federal court.
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June 11, 2024
IRS Schedules 3 Taxpayer Advocacy Panel Meetings For July
Three Taxpayer Advocacy Panel committees will hold public meetings in July focused on improving customer service at the Internal Revenue Service, the agency announced Tuesday.
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June 10, 2024
Ex-LA Chinatown Bank CFO Gets 3 Years For Embezzlement
The former chief financial officer of a bank based in Los Angeles' Chinatown has been sentenced to three years in prison after pleading guilty to bank fraud for embezzling more than $700,000 from his employer.
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June 10, 2024
Exec Wants IRS To Destroy Or Yield Docs In Summons Fight
The IRS should be forced to destroy or return bank records it obtained from a cryptocurrency executive charged in a 2020 bitcoin fraud investigation because the agency failed to notify him and his company of the summonses for the records, they told a Texas federal court Monday.
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June 10, 2024
Tax Court Rejects 'Shoebox' Method To Support Biz Expenses
The U.S. Tax Court rejected Monday the tax deductions that three California residents had claimed on their businesses' returns, saying their "shoebox" method of bundling receipts as evidence failed to substantiate their business expenses.
Staffing Hurdles Could Slow Impact Of IRS Audit Boost
The Internal Revenue Service's intended ramping up of enforcement on wealthy people, large corporations and complex partnerships may not have a meaningful impact in the short term because of challenges in hiring and training people to do the work.
Digital Taxes May Take Hold Regardless Of Treaty Signing
An internationally agreed-upon freeze on digital levies may continue to thaw even if countries meet their impending deadline to sign a related treaty for new corporate tax rules, in part because the accord faces a hazy path to formal ratification.
Trucks Don't Qualify For $400M Tax Exemption, 6th Circ. Told
A Tennessee company's refurbished trucks do not qualify for the safe harbor from the heavy-truck excise tax and should not be exempt from roughly $400 million in excise taxes, penalties and interest, the U.S. government told the Sixth Circuit.
Featured Stories
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Staffing Hurdles Could Slow Impact Of IRS Audit Boost
The Internal Revenue Service's intended ramping up of enforcement on wealthy people, large corporations and complex partnerships may not have a meaningful impact in the short term because of challenges in hiring and training people to do the work.
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A Chronology Of The Hunter Biden Investigation
The story behind President Joe Biden's son Hunter Biden's conviction on federal gun charges started with a gun purchase in 2018, was complicated by a laptop repair in 2019, and could bleed into an upcoming trial on federal tax charges in California in September.
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Digital Taxes May Take Hold Regardless Of Treaty Signing
An internationally agreed-upon freeze on digital levies may continue to thaw even if countries meet their impending deadline to sign a related treaty for new corporate tax rules, in part because the accord faces a hazy path to formal ratification.
Expert Analysis
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.
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Lean Into The 'Great Restoration' To Retain Legal Talent
As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.
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How Cannabis Rescheduling May Alter Paraphernalia Imports
The Biden administration's recent proposal to loosen federal restrictions on marijuana use raises questions about how U.S. Customs and Border Protection enforcement policies may shift when it comes to enforcing a separate federal ban on marijuana accessory imports, says R. Kevin Williams at Clark Hill.
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NCAA Settlement May End The NIL Model As We Know It
The recent House v. NCAA settlement in California federal court, in which the NCAA agreed to allow schools to directly pay March Madness television revenue to their athletes, may send outside name, image and likeness collectives in-house, says Mike Ingersoll at Womble Bond.
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Fishing Makes Me A Better Lawyer
Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge at Robinson Bradshaw.
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A Healthier Legal Industry Starts With Emotional Intelligence
The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.
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To Make Your Legal Writing Clear, Emulate A Master Chef
To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.
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Circuit Judge Writes An Opinion, AI Helps: What Now?
Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.
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BF Borgers Clients Should Review Compliance, Liability
After the U.S. Securities and Exchange Commission's recently announced enforcement proceedings against audit firm BF Borgers for fabricating audit documentation for hundreds of public companies, those companies will need to follow special procedures for disclosure and reporting — and may need to prepare for litigation from the plaintiffs bar, say attorneys at Debevoise.
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Trauma-Informed Legal Approaches For Pro Bono Attorneys
As National Trauma Awareness Month ends, pro bono attorneys should nevertheless continue to acknowledge the mental and physical effects of trauma, allowing them to better represent clients, and protect themselves from compassion fatigue and burnout, say Katherine Cronin at Stinson and Katharine Manning at Blackbird.
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What Updated PLR Procedure May Mean For Stock Spin-Offs
A recently published Internal Revenue Service revenue procedure departs from commonly understood interpretations of the spinoff rules by imposing more stringent standards on companies seeking private letter rulings regarding tax-free stock spinoff and split-off transactions, and may presage regulatory changes that would have the force of law, say attorneys at Skadden.
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Proposed Cannabis Reschedule Sidesteps State Law Effects
The U.S. Department of Justice's recent proposal to move cannabis to Schedule III of the Controlled Substances Act provides certain benefits, but its failure to address how the rescheduling would interact with existing state cannabis laws disappointed industry participants hoping for clarity on this crucial question, says Ian Stewart at Wilson Elser.
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How Attys Can Avoid Pitfalls When Withdrawing From A Case
The Trump campaign's recent scuffle over its bid to replace its counsel in a pregnancy retaliation suit offers a chance to remind attorneys that many troubles inherent in withdrawing from a case can be mitigated or entirely avoided by communicating with clients openly and frequently, says Christopher Konneker at Orsinger Nelson.