Individuals concerned about losing the benefits of a temporarily increased exemption for the estate tax by making large gifts may not have to worry about paying an additional tax after the exemption decreases, under regulations the IRS proposed Tuesday.
The U.S. Tax Court should not dismiss more than $10 million in accuracy-related penalties against the owners of the historic Palmolive Building in Chicago for misstating the value of the skyscraper's donated easement, and the court must examine the company's intent, the IRS said in a recent filing.
Cryptic concerns about international criminal investigations were not enough Tuesday to secure New Jersey attorney John M. Hanamirian a leadership role defending hundreds of American pension plans against multidistrict litigation accusing them of cheating Danish tax authorities, a Manhattan federal judge said in court.
From the downfall of the physical presence test to proposed regulations to limit income inclusions for corporate U.S. shareholders of controlled foreign corporations, family, friends and turkey are not the only things tax attorneys have to be thankful for this holiday season. Here, Law360 looks at six tax developments practitioners appreciate and hope for this year.
The Internal Revenue Service was not required to inform an attorney and school administrator of her right to request innocent spouse relief, the Seventh Circuit has ruled, backing a U.S. Tax Court decision to deny her relief from her tax attorney-husband’s liabilities.
A Manhattan federal judge sentenced English lawyer Michael Little to 20 months in prison Tuesday for helping the children of a deceased investor dodge taxes on their $14 million inheritance over a decade and for failing to pay his own taxes, ruling also that the former Royal Marine lied as he testified in his own defense.
A group of former National Football League security personnel filed a proposed class action in a New York federal court Tuesday claiming the league misclassified them as independent contractors as a way to deny them overtime and benefits.
A New Jersey federal judge on Tuesday nixed a former attorney’s bid to set aside his six-year prison sentence for using a bogus law and accounting firm to defraud a foreign nation of more than $3.5 million, rejecting claims that he received ineffective legal assistance.
An immigration lawyer linked to President Donald Trump's former attorney Michael Cohen was found guilty of lying on more than 100 asylum applications to immigration authorities and aggravated identity theft following a two-week trial, the U.S. Attorney's Office for the Southern District of New York said Monday.
An investor has settled his $4.9 million tax bill with the IRS in a Texas federal court using the proceeds of a legal settlement to drop out of a $21 million suit involving an oil business.
Michigan state officials have slammed a Native American community’s quick win bid in a suit over the state’s tax authority, saying the community had provided information that was inaccurate or unsupported and federal law did not preempt the state’s imposition of sales or tobacco tax.
The Republic of Uzbekistan on Friday urged a D.C. federal court to toss a lawsuit filed by a Guernsey-based arbitration funder to confirm a $13 million arbitral award stemming from a mining and tax dispute, saying the suit is barred under sovereign immunity.
The U.S. Department of the Treasury released final regulations Monday with a simplified accounting method for those who produce or acquire property for resale and are required to capitalize costs to the property.
A sales tax refund company that knew a competing company was suing it for trade secret misappropriation missed a 60-day deadline to try to toss the claims under a state free speech law, a Texas appellate court has held, rejecting the argument that an amended petition reset the clock.
Carlos Ghosn, the CEO and chairman of the Nissan-Renault-Mitsubishi Alliance and one of the world’s best-known businessmen, was arrested by Japanese authorities early Monday morning after an investigation sparked by a whistleblower revealed he underreported his income and misused Nissan company funds for years.
A proposed European Union digital tax should be set at 5 percent rather than 3 percent and should include revenue from sites such as Netflix Inc. and Amazon.com Inc., European Parliament lawmakers said Monday.
Allen Matkins Leck Gamble Mallory & Natsis LLP has announced a former CliftonLarsonAllen attorney experienced in tax planning and structuring has joined the firm’s Los Angeles office as a partner.
The U.S. Department of Justice late Friday scoffed at Maryland’s newly launched lawsuit aimed at shielding the Affordable Care Act from a constitutional challenge, arguing that the state has no right to the ACA’s continued existence.
The Texas Supreme Court said Friday it would hear a case on whether an electric cooperative that operates heat recovery steam generators in power plants can qualify for a property tax exemption for pollution control, after an appeals court affirmed a state agency’s denial of the credit.
A California federal judge declined Thursday to order a retrial for an accountant found guilty of helping a venture capitalist siphon $18 million from a fund using false tax returns.
The new federal tax law was expected to change how deals get structured, and four months after its enactment, it is becoming clear how the legislation is having an impact on negotiations and tax planning strategies.
Now that the midterms are over, business leaders have a little insight into the future of taxes, trade and other policy issues affecting the economy. Still, companies should remain agile as, come January, a new and divided Congress will begin to chart its course, says Mary Moore Hamrick of Grant Thornton LLP.
Per IRS guidance released last month, Section 956 should allow controlled foreign corporation subsidiaries of corporate U.S. borrowers to provide full credit support for a U.S. parent’s borrowing without suffering adverse tax consequences. However, the mechanics for applying this section to U.S. partnerships remain unclear, say attorneys at Proskauer Rose LLP.
Predicting how the cybersecurity landscape will develop is critical for any organization wanting to mitigate the risk of the inevitable future attack. Michael Hall of HighQ Solutions Ltd. discusses five threats to look out for in the next 12 months.
On Oct. 23, the departments of Treasury, Labor and Health and Human Services released long-awaited guidance that would allow employees to use health reimbursement arrangement funds to buy their own health insurance. Attorneys at Groom Law Group examine the proposed regulations and the implications for taxpayers should they become final.
The decisions that are made as investments are structured, financed and executed — and later when they are sold — have a major impact on how much federal tax is paid under the Foreign Investment in Real Property Tax Act blocker investment structure, says Brad Wagner of Wagner Duys & Wood LLP.
Joshua Peck, incoming marketing director of Hill Wallack LLP, traces the evolution of the chief marketing officer position at law firms and shares insights from three legal marketing pioneers.
Fielding v. Commissioner of Revenue is the most recent in a series of cases that have used the U.S. Constitution to curtail the ability of states to impose their income taxes on nongrantor irrevocable trusts. Toni Ann Kruse and Melissa Price of McDermott Will & Emery LLP discuss the implications of this trend.
Now that the results of the 2018 election are (mostly) in, Evan Migdail and Melissa Gierach at DLA Piper LLP consider what a Democratic House, Republican Senate and Trump administration may be able to accomplish in the way of tax policy during the lame-duck session and the upcoming 116th Congress.
The Tax Cuts and Jobs Act provided a new framework for inbound international investors, who can anticipate greater operational efficiency in the United States. However, investors must also assess the impact of the stricter interest expense and net operating loss limitations, withholding tax liability and information reporting, says Adnan Islam of Friedman LLP.
In this monthly series, Amanda Brady of Major Lindsey & Africa interviews management from top law firms about the increasingly competitive business environment. Here we feature Katie DeBord, chief innovation officer at Bryan Cave Leighton Paisner LLP.