Federal

  • May 16, 2024

    P&G Exec Says FDII Uncertainty May Sway Cos.' IP Decisions

    The 2017 tax overhaul's measure for foreign-derived intangible income, a regime that gives tax breaks for domestically held intellectual property, faces uncertainty that could be one factor in keeping some companies from repatriating IP, a tax executive for Procter & Gamble said Thursday.

  • May 16, 2024

    Democrats Prod Justice Thomas on RV Loan, Tax Treatment

    Two Senate Democrats have asked U.S. Supreme Court Justice Clarence Thomas' attorney to respond to what they called a failure to answer their questions about the justice's $267,000 loan from a healthcare industry executive to finance a luxury recreational vehicle, saying the loan treatment could have violated federal tax laws.

  • May 16, 2024

    Eaton Must Give Up Personnel Docs In Transfer Pricing Probe

    Eaton must comply with an Internal Revenue Service summons for the personnel records of its foreign employees in the government's transfer pricing investigation of the multinational power management company, an Ohio federal judge ruled Thursday.

  • May 16, 2024

    House Dems Seek Vote On Disaster Tax Relief Bill

    Two Democrats on the House of Representatives' Ways and Means Committee requested a vote Thursday on legislation that would exclude disaster relief payments from a taxpayer's gross income.

  • May 16, 2024

    TCJA Renewal Tied To Fate Of Senate Bill, Finance Chair Says

    If Senate lawmakers can't pass a bipartisan House bill extending three business provisions and expanding a child tax credit, the hope of a larger deal to renew the 2017 GOP tax overhaul next year seems unlikely, the chair of the Senate Finance Committee said Thursday.

  • May 16, 2024

    House Ways And Means To Discuss Rust Belt Economy

    The House of Representatives' Ways and Means Committee will meet to discuss economic opportunities in the Rust Belt region May 20, the committee said Thursday.

  • May 16, 2024

    Firm Seeks To Force IRS To Process Worker Retention Credits

    A tax advisory firm helping businesses apply for the pandemic-era employee retention credit has asked an Arizona federal court to force the IRS to resume processing claims, saying the moratorium in place since September violates the Administrative Procedure Act.

  • May 16, 2024

    Ex-Minn. Public Defender Gets Probation For Tax Fraud

    A former Minneapolis chief public defender who argued that he should receive a lenient sentence after resigning in disgrace amid accusations that he failed to pay taxes for years on his private law firm was sentenced to three years probation by a Minnesota federal court.

  • May 16, 2024

    No Relief For Struggling SPACs Under Buyback Tax Proposal

    Special-purpose acquisition companies won't get sought-after relief from a new 1% tax on stock buybacks under a recent Treasury Department proposal that otherwise provides helpful clarity on the tax's implications for the subdued SPAC market, lawyers say.

  • May 16, 2024

    IRS Postpones Tax Due Dates In Ohio After Tornadoes

    Some Ohio taxpayers will be given until September to file tax returns and make payments because of tornadoes that hit the state in March, the Internal Revenue Service said Thursday.

  • May 16, 2024

    Biden Admin Proposes To Loosen Restrictions On Marijuana

    President Joe Biden on Thursday announced that his administration has formally recommended relaxing restrictions on marijuana, marking the most significant federal policy shift on cannabis since the drug was criminalized more than 50 years ago.

  • May 16, 2024

    US Must Produce Emails Between IRS Managers, Docs Leaker

    The government must produce emails between Internal Revenue Service managers and a former contractor who leaked thousands of wealthy people's tax returns, a Florida federal judge has ordered, saying the materials are relevant to a billionaire's case accusing the agency of responsibility for the leak.

  • May 16, 2024

    IRS Cancels Hearing On Direct Pay Partnership Tax Rules

    The Internal Revenue Service canceled a planned public hearing on proposed regulations that would allow certain unincorporated organizations to be excluded from the partnership tax rules for direct payments of green energy tax credits.

  • May 16, 2024

    Treasury Provides Extra Relief For Bonus Energy Tax Credits

    The U.S. Treasury Department provided additional safe harbors Thursday that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing their steel and aluminum parts in response to the Biden administration's new trade restrictions on solar products from China.

  • May 15, 2024

    Conn. Strip Club Owner Ran 'Brothel,' Hid $5.7M, Feds Say

    The man in charge of a Connecticut strip club and two of his associates operated the business as a brothel, took payments for "commercial sex acts," lied to secure a $150,000 federal COVID-19 relief grant, and hid $5.7 million in income from the IRS, according to a federal indictment unsealed Wednesday.

  • May 15, 2024

    Russian Gas Ex-CFO Can't Nix $44M FBAR Suit, Judge Rules

    The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks can't escape the government's civil suit seeking nearly $44 million in reporting penalties, a Florida federal judge ruled Wednesday.

  • May 15, 2024

    House Panel Advances Tax-Exempt Org Oversight Bills

    The House Ways and Means Committee approved a package of bills Wednesday that would increase scrutiny of foreign donations to tax-exempt organizations, including legislation that would require those organizations to publicly report the donations.

  • May 15, 2024

    Schulte Roth Adds Ex-Kleinberg Kaplan Partner To Tax Group

    Schulte Roth & Zabel LLP added a former Kleinberg Kaplan Wolff & Cohen PC partner with a focus on private investment funds to its tax group in New York.

  • May 15, 2024

    11th Circ. Judge Doubts Defense Of IRS Easement Notice

    An Eleventh Circuit judge was skeptical Wednesday of the government's arguments that the Internal Revenue Service could issue a notice imposing reporting requirements on potentially abusive conservation easements without soliciting public feedback that administrative law requires.

  • May 15, 2024

    3 Key Takeaways From Floated Foreign Trust Reporting Rules

    Proposed rules for reporting transactions with foreign trusts recently issued by the U.S. Treasury Department provide breathing room on disclosure requirements for certain offshore retirement accounts, but leave open some questions about classification. Here, Law360 breaks down three sections of the proposed foreign trust reporting regulations.

  • May 15, 2024

    House Judiciary Chair Seeks Docs On IRS Backdating Probe

    The House Judiciary Committee's Republican chairman asked an IRS watchdog to reveal findings from investigations into allegations of IRS employee misconduct, including in a high-profile $38 million conservation easement deduction case in which the agency admitted to backdating evidence.

  • May 15, 2024

    Senate Finance Panel Schedules Hearing On Tax Accounts

    The Senate Finance Committee will meet next week to discuss investment in tax-advantaged accounts and its impact on children, the committee said Wednesday.

  • May 15, 2024

    Pardoned NJ Atty Suspended Over Tax, Fraud Convictions

    A former Gilmore & Monahan PA partner — who was convicted of failing to pay payroll taxes and lying on a loan application, and was pardoned by then-President Donald Trump — has received a two-year suspension from practicing law in New Jersey, though it will be largely offset by a previous suspension he served, according to a Wednesday order. 

  • May 15, 2024

    IRS Not On Hook For Ohio Woman's Legal Fees, Court Says

    The Internal Revenue Service is not liable to pay nearly $87,000 in legal fees of an Ohio woman because the agency's position was "substantially justified" throughout the woman's pursuit of a refund, the U.S. Tax Court ruled Wednesday.

  • May 15, 2024

    Applicable Federal Interest Rates To Rise In June

    Applicable federal rates for income tax purposes will increase in June, the Internal Revenue Service said Wednesday.

Expert Analysis

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

  • Newman Suspension Shows Need For Judicial Reform

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    The recent suspension of U.S. Circuit Judge Pauline Newman following her alleged refusal to participate in a disability inquiry reveals the need for judicial misconduct reforms to ensure that judges step down when they can no longer serve effectively, says Aliza Shatzman at The Legal Accountability Project.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

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    Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • How Law Firms Can Use Account-Based Marketing Strategies

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    Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.

  • While Risks Exist, AI Could Transform IRS Enforcement

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    The Internal Revenue Service's recently announced use of artificial intelligence could revolutionize the agency's enforcement efforts, and transparency about its use and a forum for challenging AI findings could help mitigate fears that the technology will increase bias, say attorneys at Lewis Brisbois.

  • Strategic Succession Planning At Law Firms Is Crucial

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    Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.

  • Maximizing Law Firm Profitability In Uncertain Times

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    As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • How Gov't Agencies Will Fare In The Event Of A Shutdown

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    With a federal shutdown potentially set to begin at the end of this month, it may be useful to consider the approximate timelines that agencies such as the Federal Trade Commission and IRS have announced for curtailing operations, and potential strategies for mitigating challenges that may arise while agency functions are limited, say attorneys at Cleary.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

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