Federal
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August 30, 2024
Danish Gov't Pledges No Ponzi Analogies At $2.1B Tax Trial
The Danish tax authority won't compare pension funds, investors and attorneys it has accused of defrauding Denmark in a $2.1 billion tax refund scheme to a Ponzi scheme or infamous perpetrator Bernie Madoff, it said Friday in New York federal court.
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August 30, 2024
Whistleblower Seeks 2nd Bid At $690M Claim In DC Circ.
A whistleblower denied up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program asked for a D.C. Circuit panel to rehear his case Friday, saying its original opinion included numerous mistakes and misunderstandings.
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August 30, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included an announcement of the reopening of a voluntary disclosure program for businesses that think they improperly received COVID-19-era employee retention credits.
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August 30, 2024
Partnership Asks 11th Circ. To Restore $9M Easement Break
A partnership asked the Eleventh Circuit to reinstate its nearly $9 million deduction for donating a conservation easement in Georgia, saying the U.S. Tax Court erroneously limited the deduction to its cost basis by claiming partners who contributed the property had held it as inventory.
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August 30, 2024
IRS Corrects Proposed Rules To Address Pillar 2 Losses
The Internal Revenue Service issued corrections Friday to proposed rules that outline when foreign taxes under the Pillar Two international minimum tax agreement could trigger long-standing U.S. rules that aim to prevent companies from what is known as double-dipping the same economic loss.
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August 30, 2024
Dow Seeks To Add 7 Chemicals To IRC Taxable Substances
The Internal Revenue Service said Friday that it is looking for public comments on proposals by Dow Chemical to add seven chemicals to the Internal Revenue Code's list of taxable substances.
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August 30, 2024
Taxation With Representation: Kirkland, Paul Weiss, Squire
In this week's Taxation With Representation, Oneok reaches two agreements with energy infrastructure companies worth a total $5.9 billion, McKesson inks a $2.49 billion deal for a cancer center, and First Busey and CrossFirst Bankshares agree to a $917 million merger.
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August 30, 2024
Rule Aims To Widen Low-Income Green Electricity Tax Credits
Geothermal, hydropower, nuclear fusion and nuclear fission projects would be among the types of electricity facilities that could be eligible for clean electricity low-income community bonus credit amounts starting in 2025, the Internal Revenue Service and U.S. Treasury Department said in proposed rules released Friday.
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August 29, 2024
9th Circ. Says IRS Properly Rejected Payment Compromise
A man who owed $50 million in taxes and offered to settle part of his debt was correctly denied a compromise, the Ninth Circuit affirmed Thursday, rejecting his argument that his offer should have been deemed accepted because the agency missed the two-year deadline for rejecting it.
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August 29, 2024
Tax Court Rejects Bid To Change Ruling Post-Chevron
The U.S. Supreme Court's recent overturning of the Chevron standard of judicial deference to agencies when interpreting statutes does not justify reconsidering a Cayman Islands partnership's tax liability, the U.S. Tax Court ruled.
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August 29, 2024
4th Circ. Won't Revive Whistleblower's Credit Suisse Tax Suit
The Fourth Circuit upheld the dismissal of a former Credit Suisse employee's whistleblower case that alleged the Swiss bank continued to help clients evade taxes after it made a related plea deal with the U.S., saying a 2023 U.S. Supreme Court decision on the False Claims Act could not save the case.
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August 29, 2024
Convicted Drexel Prof Says Records Would've Swayed Jury
A Drexel University accounting professor convicted on charges of tax evasion and filing false tax returns after the government accused him of failing to report $3.3 million in income from a Trenton pharmacy has asked a New Jersey federal judge for a new trial.
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August 29, 2024
IRS Lacking In Limiting Below-$400K Audits, TIGTA Says
The IRS has made only partial progress toward complying with a U.S. Treasury Department directive to develop methodology to ensure the agency doesn't increase the audit rate for businesses and households with annual incomes below $400,000, the Treasury Inspector General for Tax Administration reported Thursday.
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August 29, 2024
GAO Suggests IRS Improve Retirement Account Oversight
The Internal Revenue Service needs to beef up its oversight of conflicts of interest between fiduciaries and individual retirement account investors, according to a U.S. Government Accountability Office report.
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August 29, 2024
Applications Open For $6B In Advanced Energy Tax Credits
Full applications are now open for manufacturers seeking a share of a second-round $6 billion tax-credit allocation for their development projects that support the clean energy industry, the Internal Revenue Service and U.S. Department of Energy said Thursday.
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August 29, 2024
Colo. Group Asks US Justices To Revive Ballot Law Dispute
A Colorado organization asked the U.S. Supreme Court to review a lower-court decision upholding a state law requiring financial impacts be included in the titles of some tax-related ballot initiatives.
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August 29, 2024
Couple Not Entitled To Seek $480K Refund, US Tells 5th Circ.
A couple claiming they paid their tax bill should not be allowed to sue the Internal Revenue Service for a refund in a federal district court, the government told the Fifth Circuit on Thursday, saying the agency thinks the couple still owes about $480,000.
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August 29, 2024
Day Pitney Lands Former Reuters Tax Counsel In Conn.
Day Pitney LLP continued its recent growth in its tax practice in Connecticut with the addition of an experienced tax attorney from Thomson Reuters.
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August 29, 2024
IRS Expands Accounting Change Waiver Eligibility
The Internal Revenue Service adjusted a previous notice Thursday to modify certain procedures for obtaining automatic consent of the agency commissioner to change methods of accounting for expenditures paid or incurred in taxable years beginning after 2021.
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August 29, 2024
Churches Attack Nonprofit Politics Ban As Unconstitutional
Churches and Christian advocacy groups asked a Texas federal court to declare unconstitutional a provision in the Internal Revenue Code that prevents tax-exempt nonprofits from endorsing political candidates, saying the IRS discriminates against conservative religious groups and churches in applying the law.
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August 29, 2024
IRS Corrects Partnership Conservation Easement Limit Rules
The Internal Revenue Service issued corrections Thursday to finalized rules that curb the conservation easement tax deduction claimed by certain partnerships under the Secure 2.0 Act.
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August 28, 2024
Hunter Biden's Addiction Expert Knocked Out Of Tax Trial
A California federal judge on Tuesday barred Hunter Biden's expected addiction expert from testifying in his upcoming trial on tax charges, saying the expert's opinions hadn't been clearly linked to the specifics of Biden's own struggle.
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August 28, 2024
IRS Declines Watchdog's Ask For Attys In Talks With Big Cos.
The IRS declined a recommendation by its internal watchdog to require the agency's counsel to attend talks held with large multinational corporations by its appellate division, which agents say thwarts their ability to correctly enforce the economic substance doctrine, according to a report.
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August 28, 2024
Pa. Atty Admits To Dodging Taxes On Mass Tort Deal Fees
A Pennsylvania attorney pled guilty Wednesday to failing to pay taxes for approximately $1.2 million in income she received over three years, depriving the government of up to half a million dollars in revenue, according to the U.S. Attorney's Office for the Middle District of Pennsylvania.
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August 28, 2024
Feds Looks To Toss Ex-Citizens' Renunciation Fee Challenge
The federal government asked a D.C. federal judge to throw out a lawsuit brought by former U.S. citizens who want their $2,350 citizenship renunciation fee refunded, arguing during a Wednesday hearing that the United States is immune from the litigation and the plaintiffs can't relitigate claims that they already lost.
Expert Analysis
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Think Like A Lawyer: Follow The Iron Rule Of Trial Logic
Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.
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The Art Of Asking: Leveraging Your Contacts For Referrals
Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.
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IRS Sings New Tune: Whistleblower Form Update Is Welcome
In a significant reform at the Internal Revenue Service's Whistleblower Office, the recently introduced revisions to the Form 211 whistleblower award application use new technology and a more intuitive approach to streamline the process of reporting allegations of tax fraud committed by wealthy individuals and companies, says Benjamin Calitri at Kohn Kohn.
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This Earth Day, Consider How Your Firm Can Go Greener
As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.
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Energy Community Tax Credit Boost Will Benefit Wind Sector
Recent Internal Revenue Service guidance broadening tax credit eligibility to more parts of offshore wind facilities in so-called energy communities is a win for the industry, which stands to see more projects qualify for a particularly valuable bonus in the investment tax credit context due to the capital-intensive nature of offshore wind projects, say attorneys at Troutman Pepper.
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Weisselberg's Perjury At Trial Spotlights Atty Ethics Issues
Former Trump Organization executive Allen Weisselberg’s recent guilty plea for perjury in the New York attorney general's civil fraud trial should serve as a reminder to attorneys of their ethical duties when they know a client has lied or plans to lie in court, and the potential penalties for not fulfilling those obligations, say Hilary Gerzhoy and Julienne Pasichow at HWG.
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Practicing Law With Parkinson's Disease
This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.
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Why Supreme Court Should Allow Repatriation Tax To Stand
If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.
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For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill
A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.
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Trump's NY Civil Fraud Trial Spotlights Long-Criticized Law
A New York court’s recent decision holding former President Donald Trump liable for fraud brought old criticisms of the state law used against him back into the limelight — including its strikingly broad scope and its major departures from the traditional elements of common law fraud, say Mark Kelley and Lois Ahn at MoloLamken.
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Requiring Leave To File Amicus Briefs Is A Bad Idea
A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.