Federal

  • September 05, 2024

    Two Sentenced To Prison In $111M Tax Fraud Scheme

    Two members of a crime ring who admitted to participating in a $111 million tax fraud scheme involving stealing the identities of accountants and taxpayers were sentenced to prison, according to Texas federal court documents.

  • September 05, 2024

    IRS Seeks Input On Treasury Retirement Match Contributions

    The Internal Revenue Service said Thursday it is looking for comments regarding two portions of the Secure 2.0 Act of 2022 related to matching contributions paid by the U.S. Treasury Department to certain retirement savings vehicles for eligible people who make qualified contributions.

  • September 05, 2024

    Hunter Biden Pleads Guilty To Tax Charges In Surprise Move

    Hunter Biden entered a surprise guilty plea to nine criminal tax charges in California federal court on Thursday, bringing a dramatic conclusion to the case following a dizzying series of events on what was set to be the first day of his trial.

  • September 04, 2024

    Judge Chides IRS, Preparers Over $167M Refund For ID Fees

    A D.C. federal judge has declined to approve the IRS' roughly $167 million refund proposal for a putative class of tax-return preparers for charging them excessive fees for special identification numbers, saying the agency failed to address problems the preparers raised with its calculations.

  • September 04, 2024

    IRS' Economic Substance Authority Has Limits, Tax Court Told

    The U.S. Tax Court and other federal courts have the authority to conduct an initial analysis of a transaction in cases where the Internal Revenue Service is challenging the economic substance of the transaction, a manufacturers advocacy group said Wednesday in an amicus brief.

  • September 04, 2024

    Harris Floats Capital Gains Tax Hike To 28% For High Earners

    The tax on long-term capital gains would increase to 28% from 20% for taxpayers who earn $1 million or more under a proposal unveiled Wednesday by Vice President and Democratic presidential nominee Kamala Harris ahead of a campaign rally in New Hampshire.

  • September 04, 2024

    Woman Owes Taxes On Share Of Sold Biz, Tax Court Says

    A woman whose ex-husband told a bankruptcy court that he was the sole owner of a business they had started together was actually a 50% shareholder when it was sold and is liable for capital gains, the U.S. Tax Court ruled Wednesday.

  • September 04, 2024

    Tax Court OKs $465K Gambling Losses Deduction Amount

    An Indiana woman adequately proved she had more than $465,000 in substantiated gambling losses over six years, the U.S. Tax Court said Wednesday, though she failed to substantiate her claimed business losses.

  • September 04, 2024

    Warren Urges IRS To Look At Possible REIT Tax Break Abuse

    The Internal Revenue Service should increase its scrutiny of real estate investment trusts to determine whether companies are benefiting from REIT tax benefits while flouting rules, including those that limit the level of a REIT's ownership in a company, Sen. Elizabeth Warren told the agency's commissioner.

  • September 04, 2024

    Maryland Joining IRS Direct File Next Year

    Maryland will join the IRS' free electronic tax filing program known as Direct File in 2025, the U.S. Department of the Treasury and the Internal Revenue Service announced Wednesday.

  • September 04, 2024

    Ex-Mass. Pol 'A Little Sloppy' But Not Criminal, Jurors Told

    Former Massachusetts state Sen. Dean A. Tran denied charges Wednesday that he stole pandemic unemployment assistance and cheated on his taxes, with his attorney telling a jury that Tran simply made a series of paperwork "mistakes."

  • September 04, 2024

    Chippewa Lawyer Asks 8th Circ. To Reconsider Tax Exemption

    An attorney who contends that Congress never expressly allowed the federal government to tax Native Americans asked the Eighth Circuit to reconsider denying him a tax exemption on his self-employment income, saying the ruling conflicts with recent U.S. Supreme Court decisions.

  • September 04, 2024

    IRS Reopens Comment Period For Tax Payment Regs

    The Internal Revenue Service announced Wednesday that it had reopened the comment period for proposed regulations that would allow taxpayers to make payments using credit and debit cards directly with the agency instead of through a third party.

  • September 04, 2024

    IRS Announces 4 Tax Court Sessions Added To Calendar

    The Internal Revenue Service announced four U.S. Tax Court sessions in December and named calendar administrators for the sessions in a notice released Wednesday.

  • September 03, 2024

    11th Circ. Trims $12.6M FBAR Fine In 8th Amendment Split

    Some of the $12.6 million in penalties the IRS on imposed a man for willfully failing to report foreign bank accounts were in violation of the Eighth Amendment's bar on excessive fines, the Eleventh Circuit ruled, creating an apparent circuit split.

  • September 03, 2024

    5th Circ. Rejects 4 Arguments Against $6K Tax Bill

    The U.S. Tax Court correctly determined a man owed over $5,000 in tax deficiencies as well as more than $1,000 in penalties plus interest, the Fifth Circuit ruled Tuesday, finding none of the taxpayer's four arguments persuasive.

  • September 03, 2024

    IRS Should Be Bound By $2M Bankruptcy Deal, Justices Told

    An Alabama real estate developer who sought bankruptcy protection and agreed to settle his tax debts for $2 million asked the U.S. Supreme Court to review a decision allowing the IRS to demand additional taxes from him, saying the agency shouldn't be allowed to back out of the deal.

  • September 03, 2024

    Ex-Defense Contractor Arrested In $350M Tax Evasion Case

    A former defense contractor who, with his wife, is facing a 30-count indictment alleging they were involved in a decades-long scheme to defraud the U.S. government and avoid taxes on more than $350 million in income was arrested Tuesday.

  • September 03, 2024

    9th Circ. Rejects Tax Lien Pro Rata Share In Bankruptcy Sale

    The bankruptcy court is not authorized to use the pro rata method to allocate proceeds between the IRS and an estate with a tax lien for unpaid taxes and penalties, the Ninth Circuit ruled Tuesday, saying there is nothing in bankruptcy law that explicitly allows this approach.

  • September 03, 2024

    Debtor's Late-Filing Case Should Be Reviewed, Justices Told

    Tax experts urged the U.S. Supreme Court to review a Ninth Circuit decision that found late-filed returns prevented a taxpayer from discharging his federal tax debt in bankruptcy, saying the case reflects a decades-long debate that has split the circuits three ways.

  • September 03, 2024

    Non-EU Cos. Need Clarity On Public Tax Reporting, Firms Say

    The European Union should clarify how multinational corporations headquartered outside the bloc need to format tax data they report under new public disclosure rules, global accounting firms said.

  • September 03, 2024

    IRS Issues More Edits For Foreign Currency Accounting Regs

    The Internal Revenue Service issued further corrections Tuesday to proposed rules that would adjust the timing for when companies can use certain accounting methods for gains or losses that arise from foreign currency transactions.

  • August 30, 2024

    Partnership Can't Save Premature Tax Court Appeal, Feds Say

    The IRS is urging the Eleventh Circuit to throw out a Tax Court appeal that a partnership formed by two former Atlanta Braves players filed over a slashed $47.6 million conservation easement deduction, since the appeal was improperly filed before a final decision was entered.

  • August 30, 2024

    3 Ways Justices' SEC Fraud Ruling Could Affect Tax Disputes

    The U.S. Supreme Court's groundbreaking decision to curb the U.S. Securities and Exchange Commission's in-house fraud enforcement could hamper the IRS' ability to assert certain penalties, including in contested conservation easement cases, and challenge the U.S. Tax Court's authority to review them. Here, Law360 examines three arenas in which the Supreme Court decision could shake up tax administration and litigation.

  • August 30, 2024

    Alvarez & Marsal Appoints Tax Experts As Managing Directors

    Alvarez & Marsal Tax LLC appointed tax experts from Anderson and Deloitte as its new managing directors, the firm announced.

Expert Analysis

  • After Chevron: Uniform Tax Law Interpretation Not Guaranteed

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    The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.

  • Texas Ethics Opinion Flags Hazards Of Unauthorized Practice

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    The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • How High Court Approached Time Limit On Reg Challenges

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    The U.S. Supreme Court's decision in Corner Post v. Federal Reserve Board effectively gives new entities their own personal statute of limitations to challenge rules and regulations, and Justice Brett Kavanaugh's concurrence may portend the court's view that those entities do not need to be directly regulated, say attorneys at Snell & Wilmer.

  • How To Clean Up Your Generative AI-Produced Legal Drafts

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    As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.

  • A Tale Of 2 Trump Cases: The Rule Of Law Is A Live Issue

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    The U.S. Supreme Court’s decision this week in Trump v. U.S., holding that former President Donald Trump has broad immunity from prosecution, undercuts the rule of law, while the former president’s New York hush money conviction vindicates it in eight key ways, says David Postel at Henein Hutchison.

  • Industry Self-Regulation Will Shine Post-Chevron

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    The U.S. Supreme Court's Loper decision will shape the contours of industry self-regulation in the years to come, providing opportunities for this often-misunderstood practice, says Eric Reicin at BBB National Programs.

  • 3 Ways Agencies Will Keep Making Law After Chevron

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    The U.S. Supreme Court clearly thinks it has done something big in overturning the Chevron precedent that had given deference to agencies' statutory interpretations, but regulated parties have to consider how agencies retain significant power to shape the law and its meaning, say attorneys at K&L Gates.

  • Atty Well-Being Efforts Ignore Root Causes Of The Problem

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    The legal industry is engaged in a critical conversation about lawyers' mental health, but current attorney well-being programs primarily focus on helping lawyers cope with the stress of excessive workloads, instead of examining whether this work culture is even fundamentally compatible with lawyer well-being, says Jonathan Baum at Avenir Guild.

  • Tracking Implementation Of IRA Programs As Election Nears

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    As the Biden administration races to cement key regulations implementing the Inflation Reduction Act, a number of the law's programs and incentives are at risk of delay or repeal if Republicans retake control of Congress, the White House or both — so stakeholders should closely watch ongoing IRA implementation and guidance, say attorneys at Squire Patton.

  • Unpacking The Circuit Split Over A Federal Atty Fee Rule

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    Federal circuit courts that have addressed Rule 41(d) of the Federal Rules of Civil Procedure are split as to whether attorney fees are included as part of the costs of a previously dismissed action, so practitioners aiming to recover or avoid fees should tailor arguments to the appropriate court, says Joseph Myles and Lionel Lavenue at Finnegan.

  • Takeaways From Justices' Redemption Insurance Decision

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    The U.S. Supreme Court’s recent decision in Connelly v. U.S. examines how to determine the fair market value of shares in a closely held company for estate tax purposes, and clarifies how life insurance held by the company to enable redemption of a decedent’s shares affects that calculation, says Evelyn Haralampu at Burns & Levinson.

  • 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.

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