Federal

  • June 25, 2024

    Pension Plans Can't Escape $2B Danish Tax Fraud Dispute

    Two U.S. pension plans made an "extremely strained" contention that Denmark's tax administrator waited too long to accuse them of participating in a $2.1 billion fraud scheme, a New York federal judge said in declining to toss the case.

  • June 25, 2024

    Ex-DOJ Atty Among New Trio At Chamberlain Hrdlicka

    Chamberlain Hrdlicka White Williams & Aughtry has strengthened its tax controversy and litigation practice with the addition of three attorneys in Atlanta, including a former senior trial attorney in the Tax Division of the U.S. Department of Justice for more than three decades.

  • June 25, 2024

    IRS Apologizes To Hedge Fund Founder Over Leaked Tax Data

    The IRS issued an extraordinary public apology Tuesday to hedge fund founder and billionaire Ken Griffin for the leak of his and others' tax information to the media by a former contractor who admitted to stealing the returns of thousands of wealthy individuals, including former President Donald Trump.

  • June 25, 2024

    House Bill Seeks 95% Windfall Tax On Excessive Profits

    Large corporations would face a 95% windfall tax on excessive profits under legislation reintroduced in the House.

  • June 25, 2024

    Tax Pros Worry Credit Sales Could Raise Substance Issues

    Tax professionals are concerned that deals involving a new way to sell clean energy tax credits for cash could face IRS scrutiny after the agency scored a high-profile win over a telecommunications company by deploying an aggressive interpretation of what's known as the economic substance doctrine.

  • June 25, 2024

    J&J Counsel Urges OECD To Ease Burdens Of Global Min. Tax

    Counsel for Johnson & Johnson on Tuesday urged the OECD and government officials working on the Pillar Two global minimum corporate tax to consider more permanent safe harbor provisions to reduce the compliance burdens associated with the levy.

  • June 25, 2024

    Global Tax Overhaul Won't Squash Competition, US Rep. Says

    The global tax overhaul designed by the Organization for Economic Cooperation and Development won't eliminate countries competing for companies' investments, a U.S. House lawmaker said Tuesday.

  • June 25, 2024

    Fla. Construction Co. Says It's Owed $4M In Worker Credits

    A road construction company in Chapter 7 bankruptcy proceedings asked a Florida federal court to force the IRS to give it nearly $4 million in tax refunds for pandemic-era employee retention credits that its bankruptcy trustee determined it was eligible to receive.

  • June 24, 2024

    Billionaire Drops Case Against IRS Over Tax Info Leak

    Billionaire hedge fund founder Ken Griffin dropped his case Monday seeking to hold the IRS accountable for the leak of his tax return information in a data breach that affected thousands of wealthy and powerful taxpayers, including former President Donald Trump.

  • June 24, 2024

    Tax Court Rejects Collection Appeal Over Amended Return

    An IRS agent did not abuse his discretion when he didn't consider a supposed amended tax return that a Rhode Island woman said would lower her tax liability and therefore a proposed installment agreement amount, the U.S. Tax Court said Monday.

  • June 24, 2024

    Illinois, Other States Back FTC Bid To Affirm Intuit Ad Ruling

    Illinois, along with 20 other states and the District of Columbia, defended the Federal Trade Commission in tax software giant Intuit's Fifth Circuit constitutional challenge to the agency's findings that the company engaged in deceptive advertising, saying in an amicus brief that the FTC's conclusion was correct.

  • June 24, 2024

    Ex-Chicago Alderman Gets Two Years For Boosting Law Firm

    An Illinois federal judge on Monday sentenced former Chicago Alderman Ed Burke to two years in prison and fined him $2 million for using his official position to steer tax business to his personal law firm, closing what prosecutors called "another sordid chapter" in the city's history of public corruption.

  • June 24, 2024

    Better Digital Tax Ban In Pillar 1 Treaty, Treasury Official Says

    The final text of a multilateral convention to implement the OECD-designed taxing rights overhaul will include improved language to eliminate existing digital services tax and prohibit prospective ones, a U.S. Treasury Department official said Monday.

  • June 24, 2024

    Tax Preparers Win Recommendation For Class Cert. In OT Suit

    A group of tax preparers have met the requirements to form a class in a suit accusing their former employer of failing to pay overtime, a New York federal magistrate judge said, rejecting the employer's argument that their request for class status came too late.

  • June 24, 2024

    IRS Finalizes Limits To Partnership Conservation Easements

    The Internal Revenue Service finalized rules Monday that curb the conservation easement tax deduction claimed by certain partnerships, with some changes to last year's proposed version, such as limiting the opportunity for entities to adjust their tax returns to avoid the new restrictions.

  • June 24, 2024

    Loss Guidance Will Cover Pillar 2, IRS Official Says

    Forthcoming guidance to address U.S. tax issues with dual consolidated losses will also include language advising taxpayers how to account for those losses under the Pillar Two global minimum tax, the IRS' top international tax counsel said Monday.

  • June 24, 2024

    NJ Tax Evader's Wife Owes IRS, Too, Tax Court Rules

    A New Jersey woman owes more than $125,000 in taxes jointly with her husband, the U.S. Tax Court ruled Monday, saying she should have questioned the returns her husband prepared for her signature after he pled guilty to tax evasion and bribery.

  • June 24, 2024

    Julie Chrisley To Be Resentenced, But Convictions Stand

    The Eleventh Circuit on Friday upheld the tax evasion and fraud convictions of former reality TV stars Todd and Julie Chrisley, but ordered a Georgia federal judge to resentence Julie Chrisley after finding that the judge failed to fully explore her discrete role in the $36 million scheme.

  • June 24, 2024

    Supreme Court Won't Review Tax Challenge Deadline

    The U.S. Supreme Court declined Monday to review a Third Circuit finding that the U.S. Tax Court's 90-day deadline for filing challenges to tax bills isn't hard and fast.

  • June 24, 2024

    4th Circ. Affirms Nix Of $1.2M R&D Credit For Biotech Co.

    A biotechnology company that claimed tax credits for increasing its scientific research was correctly denied about $1.2 million of its request, the Fourth Circuit ruled Monday in upholding a U.S. Tax Court decision that found the company was wrongly counting research expenses twice.

  • June 24, 2024

    IRS Assessment Of $10M Earner Audits Faulty, TIGTA Says

    The Internal Revenue Service says it is rolling back its audits of returns claiming at least $10 million in income because it found them unproductive, but the Treasury Inspector General for Tax Administration said Monday that that is not true in every case.

  • June 24, 2024

    OECD Tax Plan Issues Still Being Hashed Out, US Official Says

    Both the global minimum corporate tax and taxing rights overhaul plans designed by the Organization for Economic Cooperation and Development have outstanding issues that stakeholders are attempting to resolve, a U.S. Treasury Department official said at a conference Monday.

  • June 21, 2024

    Fed. Circ. Backs Subsidy Duties For Canadian Wind Towers

    A Canadian wind tower manufacturer can't get a break on countervailing duties despite being upfront about errors in its sales data, with the Federal Circuit ruling Friday that the errors raise the possibility of additional mistakes.

  • June 21, 2024

    IRS Urges 6th Circ. To Back Gold Broker's $3M Tax Bill

    The Sixth Circuit should uphold about $3 million in tax liabilities against a self-employed gold and silver broker who failed to file returns for a decade, the IRS argued Friday, calling "frivolous" the man's argument that he isn't subject to federal income taxes.

  • June 21, 2024

    Couple Can't Hide Behind Preparer's Errors, Tax Court Says

    A Georgia couple failed to show the U.S. Tax Court that their faulty filing was the result of trusting a competent tax adviser, leading the court to rule Friday that they were correctly assessed an accuracy-related penalty by the Internal Revenue Service.

Featured Stories

  • Tax Pros Worry Credit Sales Could Raise Substance Issues

    Kat Lucero

    Tax professionals are concerned that deals involving a new way to sell clean energy tax credits for cash could face IRS scrutiny after the agency scored a high-profile win over a telecommunications company by deploying an aggressive interpretation of what's known as the economic substance doctrine.

  • Supreme Court Leaves Lifeline For Billionaire Income Tax

    Natalie Olivo

    The U.S. Supreme Court narrowed but did not entirely block the path to billionaire income tax legislation when the majority's opinion declined to weigh constitutional questions about taxing unrealized gains in its decision to uphold a mandatory repatriation levy.

  • The Tax Angle: More GOP TCJA Teams, Nonprofit Hospitals

    Stephen K. Cooper

    From a look at efforts by the Republicans on the Senate Finance Committee to prepare for next year's expiration of the 2017 tax overhaul law to a new call for nonprofit hospitals to provide more charity care, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

Expert Analysis

  • 6 Tips For Maximizing After-Tax Returns In Private M&A Deals

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    With potential tax legislation likely to spur a surge in private business sales, sellers can make the most of after-tax proceeds with strategies that include price allocation and qualified investment options, say Isaac Grossman and Daniel Studin at Morrison Cohen.

  • After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1

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    The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.

  • Recruitment Trends In Emerging Law Firm Frontiers

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    BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.

  • What DOL Fiduciary Rule Means For Private Fund Managers

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    Attorneys at Ropes & Gray discuss how the U.S. Department of Labor's recently released final fiduciary rule, which revises the agency's 1975 regulation, could potentially cause private fund managers' current marketing practices and communications to be considered fiduciary advice, and therefore subject them to strict prohibitions.

  • Money, Money, Money: Limiting White Collar Wealth Evidence

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    As courts increasingly recognize that allowing unfettered evidence of wealth could prejudice a jury against a defendant, white collar defense counsel should consider several avenues for excluding visual evidence of a lavish lifestyle at trial, says Jonathan Porter at Husch Blackwell.

  • How Associates Can Build A Professional Image

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    As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.

  • Navigating New Safe Harbor For Domestic Content Tax Credits

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    The U.S. Department of the Treasury’s recent notice simplifying domestic content calculations for certain solar, onshore wind and battery storage projects, which directly acknowledges the difficulty for taxpayers in gathering data to support a domestic content analysis, should make it easier to qualify additional domestic content bonus tax credits, say attorneys at A&O Shearman.

  • Firms Must Rethink How They Train New Lawyers In AI Age

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    As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.

  • 'Energy Communities' Update May Clarify Tax Credit Eligibility

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    A recent IRS notice that includes updated lists of locations where clean energy projects can qualify for additional tax credits — based 2023 unemployment data and placed-in-service dates — should help provide clarity regarding project eligibility that sponsors and developers need, say attorneys at Troutman Pepper.

  • Think Like A Lawyer: Always Be Closing

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    When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    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.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    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.

  • How Cannabis Rescheduling May Alter Paraphernalia Imports

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    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.