Federal
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May 08, 2024
IRS May Float Disguised Sale Partnership Rules, Official Says
The Internal Revenue Service is considering "re-proposing" regulations that it withdrew in 2019 regarding the disguised sale of property to or by a partnership, an agency official said Wednesday.
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May 08, 2024
Top House Tax Writer Pushing Schumer For Tax Bill Vote
House Ways and Means Committee Chairman Jason Smith has urged Senate Majority Leader Chuck Schumer to bring up the tax bill passed by the House in January, Smith said Wednesday, adding that the delay is jeopardizing the proposal's support.
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May 08, 2024
TCJA Extension Would Cost $4.6T, CBO Report Says
Extending the provisions of the Tax Cuts and Jobs Act for 10 years under a proposal from Republicans would increase the U.S. deficit by $4.6 trillion, according to a report issued Wednesday by the Congressional Budget Office after a request from Democratic senators.
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May 08, 2024
DOJ Says Man Owes $6.2M After Failing To Report Foreign Biz
A man owes tax penalties of $6.2 million to the U.S. after failing to disclose his ownership interests in two foreign entities from 1997 to 2004, the government told a California federal court Wednesday.
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May 08, 2024
Biz Groups Tell 10th Circ. Economic Substance Doesn't Apply
The economic substance doctrine doesn't apply when a business considers tax in making a choice between two legally permissible alternatives, two organizations told the Tenth Circuit in their briefs supporting Liberty Global's position in its $109 million tax refund bid.
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May 08, 2024
4th Circ. Asks If High Court Ruling Bars Credit Suisse Tipster
A Fourth Circuit panel questioned Wednesday whether a U.S. Supreme Court ruling prevented it from reviving a whistleblower case by a former Credit Suisse employee alleging the bank helped U.S. citizens evade taxes after paying a $2.6 billion criminal penalty.
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May 08, 2024
Auto Cos. Brace For EV Battery Compliance Hurdles
New federal regulations aimed at shoring up the domestic electric vehicle manufacturing supply chain give automakers a much-needed two-year cushion to navigate a compliance minefield, and to figure out how to reinvigorate the recent waning consumer demand for electric vehicles.
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May 08, 2024
Minn. Man Sentenced To Prison For Role In $6.7M Fraud
A Minnesota man was sentenced in federal court to 108 months in prison and told to pay more than $4.7 million in restitution for running a scheme that led to the filing of false tax returns that caused roughly $6.7 million in tax losses, the U.S. Department of Justice said.
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May 08, 2024
Ambulance Co.'s Former Owner Gets 6 Years For Tax Evasion
The former owner of an ambulance company was sentenced to more than six years in federal prison for failing to pay employment taxes to the federal government and obstructing the Internal Revenue Service as it tried to collect, according to Virginia federal court documents.
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May 08, 2024
A Foley Hoag Co-Chair Joins Litigation Firm As Name Partner
Litigation and dispute resolution firm Elliott Kwok Levine & Jaroslaw LLP will operate under a new name after welcoming as its newest name partner a former federal prosecutor who most recently co-chaired Foley Hoag LLP's white-collar crime and government investigations practice.
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May 08, 2024
DOD Trucking Contractor Owner Indicted On $1M Tax Evasion
The owner of a trucking company that hauled military supplies for the U.S. Department of Defense tried to evade more than $1 million in taxes partly by using a nominee company headed by her former dispatcher, according to an indictment by a federal grand jury in Ohio.
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May 08, 2024
Offshore Drilling Co. Demands $70M Refund From IRS
The IRS wrongfully withheld $69.7 million in tax refunds to an offshore drilling company, despite acknowledging that the refunds are justified by net operating loss carrybacks authorized by a pandemic law and then promising to pay, the company said in Texas federal court.
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May 07, 2024
Biz Orgs. Ask 10th Circ. To Toss Economic Substance Ruling
The Tenth Circuit must not uphold a Colorado federal court's ruling that it didn't need to determine whether economic substance doctrine was relevant before disallowing an intercompany transaction by Liberty Global Inc., three business groups told the Tenth Circuit in briefs Tuesday.
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May 07, 2024
Tax Software Co. Still Can't Trim Rival's Trade Secrets Suit
A corporate-focused tax preparation software company still can't pare back a suit alleging that it poached workers from its rival's recently acquired company, a Pennsylvania federal judge ruled Tuesday.
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May 07, 2024
IRS Urged To Limit Scope Of Donor Fund Rules
Proposed IRS regulations on donor-advised funds should be changed to limit their scope so they don't subject other types of funds to taxes and reporting requirements, stakeholders said Tuesday during a second day of a hearing on the proposal.
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May 07, 2024
6th Circ. Considers Rebooting Crypto Reporting Challenge
Sixth Circuit judges seemed unsure of whether a group of cryptocurrency users can challenge a pending mandate to report large crypto transactions, as the judges grappled Tuesday with whether the plaintiffs have shown they are harmed by the forthcoming rule and whether the challenge is premature.
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May 07, 2024
Think Tank Projects Broad Tax Hikes If TCJA Expires
Most U.S. taxpayers would see substantially increased tax bills if the individual provisions of the Tax Cuts and Jobs Act are allowed to expire at the end of 2025, the Tax Foundation said Tuesday.
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May 07, 2024
Industry Groups Suggest Changes To Aussie Reporting Rules
A coalition of global fund industry associations asked Australia to further amend its proposal for public country-by-country tax data reporting by including, among other measures, a provision that would allow companies to withhold sensitive information, according to a letter released Tuesday by the U.S. Treasury Department.
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May 07, 2024
IRS To Release Self-Employment Tax Regs
The Internal Revenue Service plans to release self-employment tax regulations, an agency official said during the Practising Law Institute webcast Tuesday.
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May 07, 2024
Employment Agency Owner Admits Hiding $10M In Income
The owner of a temporary employment agency pled guilty to filing false federal business tax returns to conceal more than $10 million in corporate income, the U.S. Department of Justice announced Tuesday.
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May 07, 2024
Electric Groups Say PIN Rule May Hurt Energy Credit Process
While three groups representing electric equipment manufacturers are supportive of the energy efficient home improvement credit, they say its product identification number, or PIN, requirement could harm the process, according to a letter released Tuesday by the U.S. Department of the Treasury.
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May 07, 2024
Treasury Floats Foreign Trust Reporting Rules
The U.S. Treasury Department proposed regulations Tuesday that provide guidance on the requirements for individuals to report their transactions with foreign trusts to the Internal Revenue Service, including the receipt of large gifts.
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May 06, 2024
10th Circ. Urged To Alter Substance Finding In Liberty Global
To preserve the stability of federal tax law, the Tenth Circuit should reverse a lower court's finding that it needn't determine the economic substance doctrine is relevant before disallowing a transaction's tax benefits, the National Foreign Trade Council said Monday, supporting telecommunications firm Liberty Global.
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May 06, 2024
IRS Urged To Drop Investment Advisers From Donor Rules
The IRS should change regulations on donor-advised funds so that personal investment advisers wouldn't be considered donor-advisers, stakeholders told the agency at a hearing Monday, saying failure to do so could chill charitable giving and would exceed regulatory authority.
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May 06, 2024
Man's FBAR Filing Makes Challenge Moot, 7th Circ. Says
The Seventh Circuit upheld Monday the dismissal of a man's challenge to the constitutionality of filing reports of foreign accounts because after filing the suit, the man reported his bank account, making the case moot.
Expert Analysis
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Planning A Defense As IRS Kicks Off Sports Losses Campaign
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.
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What New Calif. Strike Force Means For White Collar Crimes
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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Reimagining Law Firm Culture To Break The Cycle Of Burnout
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.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
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.
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As Promised, IRS Is Coming For Crypto Tax Evaders
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.
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5 Reasons Associates Shouldn't Take A Job Just For Money
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.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
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.
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Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules
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.
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Employee Experience Strategy Can Boost Law Firm Success
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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6 Practice Pointers For Pro Bono Immigration Practice
An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.
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Lessons From Country Singer's Personal Service Saga
Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.
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7 E-Discovery Predictions For 2024 And Beyond
The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.
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5 Litigation Funding Trends To Note In 2024
Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.