Federal

  • March 19, 2024

    ABA Tax Section Seeks Revised Donor-Advised Fund Rules

    The U.S. Treasury Department should revise excise tax rules for certain distributions from donor-advised funds in a manner that is consistent with regulations governing similar funds and that doesn't duplicate existing tax penalties, the American Bar Association Tax Section said.

  • March 19, 2024

    Staffing Co. Owner Gets 4 Years For Hiring Untaxed Labor

    The owner of a staffing company in Key West, Florida, that hired untaxed and unauthorized workers was sentenced by a Florida federal judge to four years in prison and ordered to pay $3.5 million in restitution to the U.S. government, according to court documents.

  • March 19, 2024

    GILTI Figures Into CFC Applicability Project, Official Says

    The U.S. global intangible low-taxed income system is factoring into continuing Internal Revenue Service work on whether a tax code provision limiting corporations from offsetting income with net operating or other tax losses after ownership changes applies to controlled foreign corporations, an agency official said Tuesday.

  • March 19, 2024

    Pension Plan Segment Rates Increase In March

    Segment rates for calculating pension plan funding rose in March, the Internal Revenue Service said Tuesday.

  • March 19, 2024

    Exxon Wants Closed Court In $1.8B Tax Trial

    Exxon Mobil plans to seek courtroom closures for parts of an upcoming trial in its $1.8 billion suit challenging denied tax deductions for payments it made to Qatar, telling a Texas federal court that certain testimony, if made public, would damage its relationship with the foreign partner.

  • March 18, 2024

    Ariz. Rebates Trigger Federal Tax, IRS Tells Court

    Arizona's one-time 2023 payments to taxpayers are subject to federal taxation because they do not qualify for exclusions for general welfare or disaster relief payments, the Internal Revenue Service told a federal court.

  • March 18, 2024

    Justices Won't Review Dead Film Exec's IRS Summons

    The U.S. Supreme Court on Monday denied a request from the daughter of a dead film executive to consider invalidating an IRS summons for her father's financial records, letting stand a Ninth Circuit decision that found the agency sought the records in good faith.

  • March 18, 2024

    Werfel Calls Online Biz Account Authentication A Challenge

    Establishing an effective user authentication method for companies using online business tax accounts is a challenge for the Internal Revenue Service and the agency wants suggestions on how to do it, commissioner Daniel Werfel said Monday.

  • March 18, 2024

    Treasury Mulling Whether To Keep Foreign Tax Credit Regime

    The U.S. Treasury Department is considering whether the best way to provide administrable foreign tax credit rules and address related policy concerns is to retain the framework from paused final regulations or develop a new one, a Treasury official said Monday.

  • March 18, 2024

    Tennis Job No Reason To Slice 'Varsity Blues' Term, Feds Say

    A tennis instructor job in New York is no reason to grant an early end to the home confinement portion of a sentence given to a former Georgetown University coach for his role in the "Varsity Blues" college admissions scandal, prosecutors told a Massachusetts federal judge Monday.

  • March 18, 2024

    Wyden, Whitehouse Scrutinize DOJ's Caterpillar Investigation

    Two top Democratic senators asked the U.S. Justice Department about its handling of a criminal inquiry into Caterpillar for potential financial crimes and corporate tax fraud after receiving evidence corroborating a report that former DOJ officials may have suppressed the investigation, according to a letter released Monday.

  • March 18, 2024

    Feds Want 12 Years For Ex-Broker In Fraud, Tax Case

    A former mortgage broker whose decadelong fraud scheme tricked more than a dozen people out of $8 million and caused more than $3 million in tax losses should spend 12 and a half years in prison, the government told a Rhode Island federal court.

  • March 18, 2024

    IRS Schedules Hearing On Hydrogen Production Taxes

    The Internal Revenue Service plans to hold a three-day public hearing this month on proposed rules affecting the tax treatment of the production of clean hydrogen, the agency announced Monday.

  • March 15, 2024

    Ohio Ambulance Co. Says HR Firm Botched Tax Returns

    An Ohio ambulance company accused its human resources management firm of failing to accurately prepare and submit amended tax returns that would have allowed the company to claim pandemic-era tax credits, according to a complaint filed in an Ohio federal court.

  • March 15, 2024

    Justices Told Estate Incorrectly Taxed On Insurance Payout

    The federal government's argument that the $3.5 million in life insurance proceeds a company used to redeem a deceased owner's shares increased both the company's value and its dead owner's estate tax liability ignores "economic reality," the estate told the U.S. Supreme Court on Friday.

  • March 15, 2024

    IRS Asked To Change Effective Date In Part-Time Worker Rule

    The effective date for proposed IRS rules on participation of long-term, part-time employees in retirement plans would violate administrative law if not changed in final regulations, an attorney speaking for a benefits organization told the agency and the U.S. Treasury Department at a hearing Friday.

  • March 15, 2024

    Applicable Federal Interest Rates To Rise In April

    Applicable federal rates for income tax purposes will rise in April, the Internal Revenue Service said Friday.

  • March 15, 2024

    The Tax Angle: House GOP Plots TCJA Renewal Strategy

    House Republicans left Washington this week for their annual two-day legislative issues conference, hoping to expand their control of the chamber in the upcoming November elections and planning their strategy for renewal of their historic 2017 tax overhaul law.

  • March 15, 2024

    Tax Foundation Says UN Should Avoid Duplicating Tax Efforts

    The United Nations should only create global tax rules in areas where it can effectively reduce uncertainty and should avoid duplicating negotiations underway elsewhere, the Tax Foundation said Friday in a response to the organization.

  • March 15, 2024

    Feds Want 6 Years For 'Poster Boy' Of Mass. Police Corruption

    Boston federal prosecutors have recommended nearly 6 years in prison for a former Massachusetts trooper who they say is the living embodiment of police misconduct in light of his trial convictions for stealing overtime pay, lying on his taxes and cheating to get student financial aid for his son.

  • March 15, 2024

    Attys, Broker Fight For Advice-Of-Counsel Defense In Tax Trial

    Two St. Louis attorneys and a North Carolina insurance agent staring down criminal tax charges in North Carolina federal court said the government can't prevent them from relying on advice-of-counsel defenses at their upcoming trial, arguing they've handed over all the information prosecutors need to prepare.

  • March 15, 2024

    $3B In Employment Tax Credits Claimed In Scheme, Feds Say

    Three New Jersey men who said they were leaders of religious and charitable organizations fraudulently claimed nearly $3 billion in employment tax credits from a federal pandemic loan program, according to a criminal complaint filed in New Jersey federal court.

  • March 15, 2024

    Direct Hit On Tax Regs Unlikely If Justices Ditch Chevron

    A decision from the U.S. Supreme Court later this year on two cases challenging the so-called Chevron doctrine, which gives federal agencies wide latitude to interpret ambiguous laws, isn't likely to immediately affect tax regulations.

  • March 15, 2024

    Taxation With Representation: Freshfields, Kirkland

    In this week's Taxation with Representation, AstraZeneca acquires Amolyt Pharma, XCF Global Capital goes public and EQT Corp. merges with Equitrans Midstream Corp.

  • March 15, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, featuring updated tax treatment for certain public utility debt.

Expert Analysis

  • 4 PR Pointers When Your Case Is In The News

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    Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Charting The Course For Digital Assets In 2024

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    Although 2023 was a tough year for the digital asset industry, upcoming court decisions, legislation and regulatory action will bring clarity, allowing the industry to expand and evolve, and the government will decide what innovation it will allow without challenge, says Joshua Smeltzer at Gray Reed.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • Giving The Gov't Drug Patent March-In Authority Is Bad Policy

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    The Biden administration's recent proposal to allow government seizure of certain taxpayer-funded drug patents is a terrible idea that would negate the benefits of government-funded research, to the detriment of patients and the wider economy, says Wayne Winegarden at Pacific Research Institute.

  • How Clients May Use AI To Monitor Attorneys

    Excerpt from Practical Guidance
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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • How 'As Such' Changes LPs' Self-Employment Tax Exposure

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    In light of the U.S. Tax Court’s recent Soroban Capital Partners decision hinging on "as such" to define the statutory limited partners exemption, state law limited partnerships should consider partners' roles and responsibilities before determining whether they are obligated to pay self-employment income tax, say attorneys at Morgan Lewis.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • IRA Monetization Energizes Clean Power Tax Credit Market

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    Recent large sales of clean energy production tax credits reflect an environment in which the Inflation Reduction Act's provisions for monetizing such credits via direct transfer — bypassing slow, costly tax equity transactions — offer opportunities for both developers and investors, says Andrew Eastman at Husch Blackwell.

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