Federal

  • May 31, 2024

    IRS Memo Backs Tax For Noninsurance Payments To Captives

    When the IRS determines that a company's payments to its foreign captive insurer were not for actual insurance, the agency can assert a 30% tax on the captive for the income it received under the arrangement, the IRS chief counsel's office said in a memo released Friday.

  • May 31, 2024

    Texan's Estate Owes $3.4M For Missed Tax Pays, Court Told

    A Texas man's estate owes over $3.4 million in unpaid taxes, interest and penalties because of missed payments stretching back over a decade, even after multiple extensions were granted to the two executors, the government told a federal district court.

  • May 31, 2024

    5 Tax Bills To Watch This Summer

    House and Senate lawmakers return to Washington, D.C., on Monday, where several tax-related bills await them in both chambers, including a stalled package that would restore business tax breaks and expand the child tax credit. Here, Law360 takes a look at five bills that could move through Congress this summer.

  • May 31, 2024

    Calif. Man Owes 6 Years Of FBAR Penalties, IRS Tells Court

    A Californian has failed to pay foreign bank account reporting penalties he was assessed that were tied to a business he owed in Mexico for six years, the Internal Revenue Service told a federal court.

  • May 31, 2024

    Fuel Producers Should Apply ASAP For Tax Credit, IRS Says

    Fuel producers hoping to start claiming the clean fuel production credit as soon as January should register with the Internal Revenue Service by July 15, the agency said Friday, warning that registration applications made after that date are less likely to go through in time.

  • May 31, 2024

    IRS Delays Deadlines For Mass. Taxpayers Hit By 2023 Storms

    Certain Massachusetts taxpayers impacted by severe storms and flooding that hit the state Sept. 11 now have until July 31 to file various individual and business tax returns and make payments, the Internal Revenue Service said Friday.

  • May 31, 2024

    Taxation With Representation: Cravath, Cleary, Fried Frank

    In this week's Taxation With Representation, T-Mobile buys United States Cellular Corp.'s wireless operations, Energy Transfer plans to buy WTG Midstream, ConocoPhillips acquires Marathon Oil, and Goldman Sachs Alternatives raises over $20 billion for its direct lending strategy.

  • May 30, 2024

    Chicago Kiosk Salesman Gets 1 Year For Filing False Returns

    An electronic-sweepstakes kiosk salesman from Chicago was sentenced to a year in prison for filing false tax returns that included more than $500,000 in inflated business expenses, according to Illinois federal court documents.

  • May 30, 2024

    IRS Adds 16 Tax Court Sessions To Calendar

    The Internal Revenue Service announced 16 U.S. Tax Court sessions in September and October and named calendar administrators for the sessions in a notice released Thursday.

  • May 30, 2024

    Tax Court Nixes $30M In Conservation Easement Deductions

    The U.S. Tax Court upheld on Thursday the IRS' rejection of more than $30 million in charitable contribution deductions for Alabama conservation easements for partnerships acting as test cases for a larger group that took $187 million in deductions.

  • May 30, 2024

    Tax Court Tosses Whistleblower Award Contest

    The U.S. Tax Court ruled Thursday that it cannot review a woman's roughly $1,700 whistleblower award from the Internal Revenue Service because it does not meet a threshold for mandatory awards.

  • May 30, 2024

    IRS Names New Chief Taxpayer Experience Officer

    The Internal Revenue Service has chosen an adviser in its Transformation and Strategy Office to serve as the agency's new chief taxpayer experience officer, according to a statement Thursday.

  • May 30, 2024

    Later Pillar 1 Due Date Set For June As Tax Talks Wrap Up

    Diplomats agreed this week to finalize a treaty for reallocating some of large companies' tax payments and setting standards to simplify some transfer pricing in lower-income countries by June 30 after having missed a March deadline, according to a statement published Thursday by the OECD.

  • May 30, 2024

    Ex-KPMG Manager Joins Davis+Gilbert As Tax Partner

    A former managing director at KPMG has joined New York law firm Davis+Gilbert LLP as a tax partner in its corporate and transactions practice, Davis+Gilbert announced.

  • May 30, 2024

    Black Business Owners Sue Over Impact Of Transparency Act

    The Corporate Transparency Act creates unique burdens on businesses owned by people of color, immigrants and other marginalized groups, the Black Economic Council of Massachusetts and several company owners said in the latest legal challenge to the anti-money laundering law.

  • May 30, 2024

    Russian Gas Ex-CFO Says $44M FBAR Penalty Is Excessive

    The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks told a Florida federal court that the $44 million in foreign account reporting penalties the government is seeking is illegally high.

  • May 30, 2024

    IRS To Make E-File Program Permanent, Plans Expansions

    The Internal Revenue Service will make permanent the free online tax filing system it launched as a limited pilot program this year and plans to expand its scope, Commissioner Daniel Werfel said Thursday.

  • May 29, 2024

    10th Circ. Tosses Insurance Co. Appeal In Tax Court Dispute

    The Tenth Circuit tossed an insurance company's challenge to a U.S. Tax Court ruling rejecting the company's effort to invalidate tax deficiency notices on Wednesday, saying it lacked authority to hear the case because the Tax Court's decision wasn't a final one that would end litigation.

  • May 29, 2024

    Miami Tax Preparers Should Be Barred For Fraud, DOJ Says

    Two Miami-based tax professionals and their businesses should be barred from preparing federal tax returns for others because they repeatedly claimed fraudulent credits without their customers' knowledge, the U.S. Department of Justice told a Florida federal court.

  • May 29, 2024

    Baker McKenzie Grows Tax Practice With Ex-KPMG Adviser

    Baker McKenzie announced the hiring of an experienced Chicago-based tax adviser as a principal who most recently spent sixteen and a half years at Big Four accounting firm KPMG.

  • May 29, 2024

    Presidential Candidate Convicted For $15.5M Tax Fraud

    A tax-preparation business owner and 2024 presidential candidate was convicted on 33 counts of tax fraud after being accused of inflating deductions in a scheme federal prosecutors said caused more than $15.5 million in tax losses, according to Texas federal court documents.

  • May 29, 2024

    Treasury Details Which Tech Would Get Clean Energy Credits

    Treasury released proposed rules Wednesday outlining which technologies would qualify for new zero-emission energy tax credits, saying wind, solar and geothermal are among those that would make the cut.

  • May 28, 2024

    Preserving Enhanced LITC Funding Could Aid Tax System

    Lawmakers haven't yet enacted funding levels for low-income taxpayer clinics for 2025, but they could grease the wheels of tax administration by preserving enhanced funding for the clinics, which helps more taxpayers comply with the law, reducing the burden on the IRS.

  • May 28, 2024

    Mich. Doctor Denied Release From Contempt In FBAR Fight

    A Michigan doctor will stay jailed for civil contempt after a federal judge found Tuesday that he failed to back up claims that he cannot pay his more than $1 million in foreign bank account reporting penalties due to a bank's bankruptcy and his criminal history.

  • May 28, 2024

    Biz Groups Back BofA In Merger Interest Tax Fight At 4th Circ.

    Business groups told the Fourth Circuit on Tuesday that they supported Bank of America in its fight against a North Carolina federal court ruling that found the bank wasn't entitled to net the interest on the tax liabilities of Merrill Lynch after the two companies merged.

Expert Analysis

  • 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.

  • 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.

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