Federal

  • 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.

  • April 22, 2024

    Senate Bill Would Clarify IRS Process For Math Corrections

    A bill introduced Monday in the U.S. Senate would clarify the process in which the Internal Revenue Service corrects math errors in tax returns.

  • April 19, 2024

    PE Exec Can Recoup $1M 'Varsity Blues' Forfeiture

    A private equity executive whose conviction in the "Varsity Blues" college admissions case was almost entirely wiped out by the First Circuit is entitled to a refund of $1 million he paid to the scheme's ringleader, a federal judge ruled Friday.

  • April 19, 2024

    Utah Charity Leader Gets Year In Prison For $1.3M Tax Evasion

    The former head of a Utah charity was sentenced to a year and a day in prison for evading taxes on $1.3 million he was paid as part of a covert arrangement with a purported donor, according to documents filed in a Utah federal court.

  • April 19, 2024

    IRS Previews New Digital Assets Reporting Form

    The Internal Revenue Service released a draft of a form brokers will have to use for the first time to disclose their digital asset sales to the agency, including instructions for taxpayers whose transactions are subject to the reporting requirements. 

  • April 19, 2024

    Atty Says False Testimony Justifies Chrisleys' Acquittal

    Attorneys for Todd and Julie Chrisley of the reality television show "Chrisley Knows Best," who are in prison after being convicted on federal charges of bank fraud and tax evasion, urged the Eleventh Circuit to undo their convictions on Friday, arguing prosecutors knowingly presented false, prejudicial testimony at trial.

  • April 19, 2024

    Polsinelli Adds Shareholder To Tax Credit Practice In Dallas

    An attorney who spent more than a decade developing a niche practice specializing in tax credit financing has moved her practice to Polsinelli PC's Dallas office after five years at Munsch Hardt Kopf & Harr PC.

  • April 19, 2024

    Atty In Tax Fraud Case Gets Supervised Release, $25K Fine

    A former Houston lawyer whose conviction in connection with an $18 million tax scheme was overturned told a federal judge Friday that not testifying in his 2019 trial was "one of the worst mistakes" of his life as he was sentenced to a year of supervised release as part of a plea deal.

  • April 19, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, featuring the federal income tax treatment of amounts paid for the purchase of energy efficient property and improvements under the Inflation Reduction Act.

  • April 19, 2024

    Miami Tax Prep Biz Should Be Shut Off For Fraud, DOJ Says

    A Miami tax preparation business and its owner should be permanently barred from preparing returns after illegally understating customers' liabilities and causing a $500,000 tax loss to the U.S. government for 2023, the U.S. Department of Justice told a Florida federal court.

  • April 19, 2024

    IRS Corrects Advanced Manufacturing Credit Rules

    The Internal Revenue Service issued a correction notice Friday, fixing a number of errors in final regulations concerning the elective payment election of the advanced manufacturing investment credit under a 2022 law that established the credit.

  • April 19, 2024

    Insurance Co's Shifting Payments Still Fixed Asset, IRS Says

    A stock life insurance company's fixed annuity contract involving structured settlement transactions can still qualify as a funding asset, even though the payment amounts increase with the market, the Internal Revenue Service said in a pair of private letter rulings released Friday.

  • April 19, 2024

    Taxation With Representation: Kirkland, Cleary, O'Melveny

    In this week's Taxation With Representation, Resideo Technologies Inc. announced plans to buy Snap One Holdings Corp., APi Group said it bought an elevator maintenance company, Prysmian said it agreed to purchase Encore Wire, and Sayari said it closed on an investment from TPG.

  • April 19, 2024

    Questions Loom Over China's Pillar 2 Participation

    Practical and political problems surrounding the Organization for Economic Cooperation and Development's 15% global minimum corporate tax raise questions about how China and its biggest companies could undermine that regime.

  • April 18, 2024

    Brothers Can't Deduct $3.8M Theft Loss, Tax Court Says

    Two brothers who claimed that a convicted fraudster stole from a holding company for their struggling savings and loan can't take a theft-loss deduction topping $3.8 million because they failed to prove a connection to the fraud, the U.S. Tax Court ruled Thursday.

  • April 18, 2024

    Donor Fund Rules Unlikely To Be Retroactive, Officials Say

    Proposed regulations from the U.S. Department of the Treasury and Internal Revenue Service on donor-advised funds will likely be changed so that they don't apply retroactively, government officials said Thursday.

  • April 18, 2024

    AbbVie Can't Get Deduction For $1.6B Merger Fee, IRS Says

    The IRS defended its denial of AbbVie's claimed deduction for a $1.6 billion payment to a biotechnology company over their failed merger, telling the U.S. Tax Court that the pharmaceutical giant is misconstruing an underlying statute to challenge the agency's decision.

  • April 18, 2024

    Clinic Head Gets 9 Years For Medicare Kickback, Tax Scheme

    A health clinic manager was sentenced to nine years in prison and ordered to pay $40 million in restitution to the government for participating in a multimillion-dollar healthcare kickback scheme that involved tax fraud, according to documents in a New York federal court.

  • April 18, 2024

    AICPA Offers Support For Disaster Tax Lookback Plan

    A House proposal that would allow for those affected by disasters to extend the period for claiming tax credits or refunds when granted postponements for filing tax returns received support from the American Institute of Certified Public Accountants.

  • April 18, 2024

    IRS Updates Rates For Foreign Insurance Company Equations

    The Internal Revenue Service published updated domestic asset/liability and yields percentages Thursday that foreign life insurance companies as well as foreign property and liability insurance companies need to compute their minimum effectively connected net investment income for tax years starting in 2023.

  • April 18, 2024

    $32B More In Tax Yielded In Fiscal '23 Closed Audits, IRS Says

    The Internal Revenue Service closed nearly 583,000 tax return audits in fiscal year 2023, resulting in $31.9 billion of recommended additional tax after examination, the agency said Thursday in its annual data book.     

  • April 18, 2024

    Atty In Tax Fraud Must Pay Full $2.5M Per Plea Deal, Feds Say

    A former Houston attorney set to be sentenced Friday for his role in an $18 million offshore tax scheme is trying to limit the government's ability to collect $2.5 million in restitution he promised to pay in a plea agreement last year, prosecutors told a Texas federal court Thursday.

  • April 18, 2024

    IRS Seeks Advisory Council Noms, Creates Fairness Panel

    The Internal Revenue Service is seeking nominations for the council that advises the agency's commissioner, the IRS said Thursday, while the council is also launching a new subcommittee on fairness in tax administration.

  • April 18, 2024

    Transfer Pricing And Dancing: Recalling KPMG's Sean Foley

    Sean Foley, who died suddenly in September, was a devoted husband, father, brother and friend and a brilliant colleague. He was one of the world's top experts in an area of international tax known as transfer pricing, where he became the global leader of KPMG's practice.

  • April 18, 2024

    IRS Adds 2nd Public Hearing Day On Donor-Advised Regs

    The Internal Revenue Service has added a second, telephone-only public hearing in May on proposed regulations on excise taxes on certain taxable distributions made from donor-advised funds, the agency announced Thursday.

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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