Federal

  • April 24, 2024

    Treasury Limits Reach Of Look-Through Rule In Final Regs

    The U.S. Treasury Department finalized regulations Wednesday that retain but narrow the scope of a proposal to, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.

  • April 24, 2024

    IRS Followed Protocol In Choosing Higher IT Bid, GAO Says

    The Internal Revenue Service reasonably assessed proposals for information technology engineering services before choosing an offer that was higher than others, the Government Accountability Office found.

  • April 24, 2024

    TIGTA Helps Stop $3.5B Pandemic Credit Scam, Agency Says

    The Treasury Inspector General for Tax Administration, in conjunction with the Internal Revenue Service, has cracked down on a scheme where individuals potentially improperly claimed $3.5 billion in coronavirus relief tax credits, the office said Wednesday.

  • April 23, 2024

    Treasury Says Aussie Royalty Ruling Contradicts US, OECD

    Australia's updated draft ruling regarding when payments for the rights to distribute software would be considered royalties conflicts with OECD and U.S. standards on the treatment of such deals, a U.S. Department of the Treasury official said in a letter made public Tuesday.

  • April 23, 2024

    Tax Court OKs IRS Notice After Petitioner Spews 'Gibberish'

    The U.S. Tax Court ruled in favor of the Internal Revenue Service on Tuesday after a Nevada woman used "tax protester gibberish," the court said, in an attempt to circumvent more than $37,000 in unreported income.

  • April 23, 2024

    Biz Ownership Law Constitutional, Lawmakers Tell 11th Circ.

    The Corporate Transparency Act is a garden-variety exercise of Congress' powers to address threats to national security, foreign affairs, commerce and tax collection, five Democratic lawmakers told the Eleventh Circuit, disputing a ruling that the law is unconstitutional.

  • April 23, 2024

    DC Circ. Backs Tax Penalties Against Swiss Couple

    A Swiss couple who incurred $500,000 in penalties for failing to report millions of dollars they held in Swiss bank accounts can't get out of paying, the D.C. Circuit ruled Tuesday, rejecting their argument that the IRS didn't properly approve the fines.

  • April 23, 2024

    Int'l Pricing Pact Guidance Is Coming Soon, IRS Official Says

    Updated Internal Revenue Service guidance that would help multinational corporations pursue advance pricing agreements will likely be released in a few months, an agency official said Tuesday.

  • April 23, 2024

    Migrant-Hiring Crimes And Tax Evasion Get Pair Prison, $1.8M Fine

    A Florida federal judge has ordered two men to pay $1.8 million to the U.S. government and sentenced them to three years in prison after they confessed to recruiting migrants without employment authorization and failing to report workers' wages for tax purposes.

  • April 23, 2024

    Tomato Cos. Ask 9th Circ. To Allow Immediate Cost Deduction

    Two companies that supply 40% of U.S. tomato paste and diced tomatoes asked the Ninth Circuit to allow deduction of their facilities' restoration costs during the tax year in which the tomatoes are processed, even though the companies don't pay the restoration costs until later.

  • April 23, 2024

    Atty Can Deduct $303K In Racing Ad Costs, 10th Circ. Told

    A Colorado attorney asked the Tenth Circuit to reverse a U.S. Tax Court decision that prevented him from deducting $303,000 in advertising expenses tied to his automobile racing, saying the lower court incorrectly ruled that the costs were related to a hobby rather than his litigation practice.

  • April 23, 2024

    Feds Want About 3 Years In Prison For LA Bank Embezzler

    The former chief financial officer at a community bank in Los Angeles should spend nearly three years in prison after admitting he embezzled more than $700,000 and used employee identities in a life insurance scheme, the government told a California federal court.

  • April 23, 2024

    Indicted 'Magician' Tax Preparer's Clients Under Scrutiny

    Clients of a New York City-based tax preparer who earned the nickname "the magician," allegedly making $15 million while fraudulently depriving the IRS of $100 million, may also face charges, a prosecutor told the federal judge in charge of the case on Tuesday.

  • April 23, 2024

    IRS Opens Low Income Clinic Grant Period For 2025

    The Internal Revenue Service has begun accepting applications from Low Income Taxpayer Clinics for matching funds in 2025, the agency announced Tuesday.

  • April 23, 2024

    DOL's Final Investment Advice Regs Expand ERISA's Reach

    The U.S. Department of Labor issued final regulations Tuesday broadening who qualifies as a fiduciary under the Employee Retirement Income Security Act, backing off some changes included in a proposal the agency released in October.

  • April 22, 2024

    Hedge Funder's IRS Suit Over Leaked Tax Info Gets Trimmed

    A Florida federal judge on Monday dismissed part of a hedge fund executive's case seeking to hold the Internal Revenue Service accountable for a leak of his private tax data to the media, saying he failed to show he suffered any damages.

  • April 22, 2024

    Congress Can Enact Corp. Transparency, Orgs Tell 11th Circ.

    Congress is empowered to require American companies to report their beneficial owners to the federal government because there is ample evidence they've previously been used to fund hostile foreign actors, evade sanctions and traffic drugs, two think tanks told the Eleventh Circuit in an amici brief.

  • April 22, 2024

    Partnership Can't Claim $22.7M Loss, Tax Court Says

    The U.S. Tax Court on Monday upheld the IRS' decision to deny a $22.7 million loss deduction claimed by a Connecticut partnership, finding that underlying transactions involving a bankrupt Brazilian company's debt obligations amounted to a disguised property sale.

  • April 22, 2024

    Fla. Man Fined After Failing To Report 11 Years Of Income

    A Florida man is liable for penalties after failing to report approximately $7 million in income across 11 tax years, the U.S. Tax Court ruled Monday.

  • April 22, 2024

    Ga. Teacher Frivolously Disputed Deficiency, Tax Court Says

    A Georgia man is required to pay a $15,000 penalty for maintaining a frivolous position in his challenge of an income tax deficiency, the U.S. Tax Court ruled Monday.

  • April 22, 2024

    IRS Failed To Act After Supervisor Groped Worker, Court Told

    An IRS employee told an Iowa federal court Monday that her supervisor groped her and made a sexually degrading comment about her during a meeting but that the agency "has done nothing" to protect her, despite an investigation concluding the harassment had likely occurred.

  • April 22, 2024

    Va. Man Too Late, On Hook For $86K, Tax Court Rules

    A Virginia man petitioned the U.S. Tax Court too late to contest his $86,000 liability, the court ruled Monday as it backed the Internal Revenue Service in the dispute.

  • April 22, 2024

    Conn. Couple Appealing $2.9M Tax Bill To 2nd Circ.

    A Connecticut couple ordered to pay $2.9 million in back taxes, interest and penalties are asking the Second Circuit to reconsider the determination. 

  • April 22, 2024

    Ex-US Atty's Stepson Says He Has None Of Docs Gov't Seeks

    The stepson of a former Nevada U.S. attorney convicted of failing to pay taxes told a Nevada federal court that he doesn't have the financial documents the federal government has demanded in its $1.3 million tax suit against his stepfather.

  • April 22, 2024

    Chamberlain Hrdlicka Picks Firm Veteran As San Antonio Head

    Chamberlain Hrdlicka White Williams & Aughtry announced Monday that it had tapped a shareholder with more than a decade at the tax-focused firm to helm its growing San Antonio location in the Lone Star State.

Expert Analysis

  • 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.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.

  • Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules

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    Regulations recently proposed by the IRS and the U.S. Department of the Treasury concerning two types of tax credits for clean hydrogen production facilities should resolve many of the most pressing questions around qualification for the credits — albeit in a relatively stringent manner, say attorneys at Morgan Lewis.

  • Employee Experience Strategy Can Boost Law Firm Success

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    Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.

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