Federal

  • April 15, 2024

    Tax Attys, Broker Peddled 'Financial Fantasy,' NC Jury Told

    A North Carolina federal jury on Monday heard a series of secret recordings at the start of a tax fraud trial in which an insurance agent and a St. Louis attorney unwittingly pitched an undercover IRS agent on a way to decrease taxable income — or what the government characterized as a "financial fantasy."

  • April 15, 2024

    Exxon Seeks $1.8B Tax Refund As Qatar Deal Trial Opens

    Exxon Mobil Corp. argued Monday in Texas federal court that its deal with Qatar to extract natural gas from the country's coast was a partnership, rather than a lease agreement, saying at the start of a trial that it's entitled to get $1.8 billion in tax benefits back from the IRS.

  • April 15, 2024

    House OKs Ending Exemption For Terrorist-Supporting Orgs

    The House passed legislation Monday that would authorize the Internal Revenue Service to suspend the tax-exempt status of any nonprofit organization found by the U.S. Treasury secretary to support foreign terrorism.

  • April 15, 2024

    8th Circ. Urged To Revive IRS' Pricing For Medtronic

    The U.S. government urged the Eighth Circuit on Monday to side with the IRS' method for pricing the intangible property that medical device maker Medtronic licensed to a Puerto Rican affiliate, arguing it's the only way to determine arm's-length royalty rates.

  • April 15, 2024

    Donor Fund Regs Could Imperil Nonprofit-Sponsored Projects

    So-called fiscal sponsorship funds set up at established nonprofits to help new projects start charitable work could be unexpectedly threatened by proposed IRS and Treasury rules on donor-advised funds that could subject such arrangements to burdensome taxes, experts say.

  • April 15, 2024

    IRS Boasts Better Service, Direct File Progress On Tax Day

    The IRS achieved an 88% level of service this year on its phone lines and maintained an average call wait time of three minutes while answering more than a million more calls than last year's filing season, the U.S. Department of the Treasury announced Monday.

  • April 15, 2024

    Tax Court Finds Woman Liable Despite Divorce Decree

    A Connecticut woman is jointly and severably liable for tax liabilities despite a divorce decree that calls for them to be her ex-husband's responsibility, according to a transcript released Monday by the U.S. Tax Court.

  • April 15, 2024

    AICPA Calls For Clearer Forms For Tax-Exempt Orgs

    The Internal Revenue Service ought to clarify filing requirements for forms in order to simplify the filing process for tax-exempt organizations, the American Institute of Certified Public Accountants said in a letter made public Monday.

  • April 15, 2024

    'Magician' Tax Preparer Arrested On $100M Fraud Charges

    The owner of a New York tax preparation business who was known as "the magician" was arrested Monday on charges that he caused more than $100 million in tax losses to the government over a decade, according to the U.S. Department of Justice.

  • April 15, 2024

    Madoff Victims Can't Claim Theft Deduction, Tax Court Rules

    A New York couple who fell victim to Bernie Madoff's Ponzi scheme were properly denied a theft loss deduction because they did not own the assets that were stolen, the U.S. Tax Court ruled Monday.

  • April 15, 2024

    9th Circ. To Hear Hunter Biden Appeal In Criminal Tax Case

    The Ninth Circuit will hear Hunter Biden's argument that a California federal judge wrongly rejected requests by his defense team to toss a criminal tax case that Biden has claimed is politically motivated and vindictive, according to a notice filed Monday.

  • April 15, 2024

    IRS Waives Penalties For Not Paying Corp. Minimum Tax

    The Internal Revenue Service is waiving penalties for failure to make estimated quarterly payments of the corporate alternative minimum tax through at least April 15, the agency said Monday.

  • April 15, 2024

    IRS Improves Adherence To FOIA Rules, TIGTA Says

    The Internal Revenue Service "generally followed" Freedom of Information Act protocols for redacting taxpayer information from October 2022 to March 2023 — a considerable improvement from past reports, the Treasury Inspector General for Tax Administration said Monday. 

  • April 12, 2024

    Petition Watch: Judge DQs, 'Excessive' Damages & Price Wars

    A former al-Qaida member has asked the U.S. Supreme Court to clarify disqualification protocol for judges overseeing a case related to their prior work as a government attorney, and energy drink manufacturers want the court to develop a modern-day test to determine if companies qualify as price-discrimination competitors. Here's four high court petitions filed recently that you might've missed.

  • April 12, 2024

    FedEx Not Entitled To $84.6M In Tax Credit Dispute, US Says

    FedEx is not entitled to a judgment of nearly $84.6 million that the company requested in March for its foreign tax credit dispute, the federal government said Friday in a Tennessee federal court filing.

  • April 12, 2024

    4 Takeaways From Tax Court Nix Of Easement Perpetuity Rule

    The U.S. Tax Court's scrapping of an IRS rule on the perpetuity requirements for conservation easements could draw yet more judicial scrutiny to the agency's rulemaking and shift the focus of easement disputes to how the transactions are valued. Here, Law360 examines four key takeaways from the decision.

  • April 12, 2024

    OECD Base Erosion Project Still Percolating, Think Tank Says

    Policymakers should recognize that the Organization for Economic Cooperation and Development's tax project from roughly a decade ago to reduce base erosion and profit shifting may still be affecting companies' behavior, according to a publication released Friday from the fiscally conservative-leaning Tax Foundation.

  • April 12, 2024

    Woman Pleads Guilty To $1.3M COVID Tax Credit Fraud

    A California woman pled guilty to fraudulently obtaining $2 million in COVID-19 government loans and falsely claiming $1.3 million in tax credits, crimes that could result in a 20-year prison sentence, the U.S. Department of Justice said.

  • April 12, 2024

    Final 'Look-Through' Rules Coming Soon, IRS Official Says

    The IRS is about to release final regulations that would, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled, an agency official said Friday.

  • April 12, 2024

    The Week In Trump: Catch Up On The Ex-President's Cases

    Donald Trump and his legal team proved that they are nothing if not persistent as they repeatedly tried — and failed — to hit the brakes on the former president's porn star hush money trial in Manhattan.

  • April 12, 2024

    Construction Co. Owner Cops To Causing IRS $2.8M Tax Loss

    A Massachusetts construction company owner pled guilty to running an "off-the-books" cash payroll scheme that cost the federal government $2.8 million in tax losses, the U.S. Department of Justice said.

  • April 12, 2024

    IRS Adds 12 Census Tracts For Alternative Fuel Credit

    The Internal Revenue Service added additional census tracts to the list of those where people and businesses can qualify for the alternative fuel vehicle refueling property credit, the agency said Friday.

  • April 12, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, featuring a clarification surrounding qualified student loan bonds.

  • April 12, 2024

    Taxation With Representation: Freshfields, Kirkland & Ellis

    In this week's Taxation with Representation, eBay acquires Collectors' Goldin auction house, Vertex Pharmaceuticals buys Alpine Immune Sciences, Vista Equity Partners purchases Model N and Tradeweb Markets buys Institutional Cash Distributors.

  • April 12, 2024

    IRS Schedules Advisory Council Meeting For May

    The Internal Revenue Service Advisory Council will hold its next meeting May 8, the agency announced Friday.

Expert Analysis

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • A Proposal For Fairer, More Efficient Innocent Spouse Relief

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    Adding a simple election to the current regulatory framework for innocent spouse claims would benefit both taxpayers and the Internal Revenue Service by alleviating the undue burdens placed on those the program was intended to help and improving agency collections in such cases, says Laurie Kazenoff at Kazenoff Tax.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • Proposed Hydrogen Tax Credit Regs May Be Legally Flawed

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    While the recently proposed regulations for the new clean hydrogen production tax credit have been lauded by some in the environmental community, it is unclear whether they are sufficiently grounded in law, result from valid rulemaking processes, or accord with other administrative law principles, say Hunter Johnston and Steven Dixon at Steptoe.

  • Navigating ACA Reporting Nuances As Deadlines Loom

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    Stephanie Lowe at Liebert Cassidy walks employers through need-to-know elements of Affordable Care Act reporting, including two quickly approaching deadlines, the updated affordability threshold, strategies for choosing an affordability safe harbor, and common coding pitfalls.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • Why Biz Groups Disagree On Ending Chevron Deference

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    Two amicus briefs filed in advance of last month's U.S. Supreme Court oral arguments in Loper Bright Enterprises v. Raimondo highlight contrasting views on whether the doctrine of Chevron deference promotes or undermines the stable regulatory environment that businesses require, say Wyatt Kendall and Sydney Brogden at Morris Manning.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Look Ahead For The Electric Vehicle Charging Industry

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    This will likely be an eventful year for the electric vehicle market as government efforts to accelerate their adoption inevitably clash with backlash from supporters of the petroleum industry, say Rue Phillips at SkillFusion and Enid Joffe at Green Paradigm Consulting.

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

  • Planning A Defense As IRS Kicks Off Sports Losses Campaign

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    Sports team owners and partnerships face potential examination under the Internal Revenue Service’s recently announced sports industry losses campaign, and should be preparing to explain what drove their reported losses and assembling documentation to support their tax return positions and accounting methods, say Sheri Dillon and Jennifer Breen at Morgan Lewis.

  • What New Calif. Strike Force Means For White Collar Crimes

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    The recently announced Central District of California strike force targeting complex corporate and securities fraud — following the Northern District of California's model — combines experienced prosecutorial leadership and partnerships with federal agencies like the IRS and FBI, and could result in an uptick in the number of cases and speed of proceedings, say attorneys at MoFo.

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