Federal

  • September 16, 2024

    IRS Cancels Hearing On 'Basket Contract' Transactions Rule

    The Internal Revenue Service canceled a hearing on proposed rules that would flag what are known as basket option contracts as potentially abusive listed transactions, according to a notice released Monday.

  • September 13, 2024

    The 2024 Regional Powerhouses

    The law firms on Law360's list of 2024 Regional Powerhouses reflected the local peculiarities of their states while often representing clients in deals and cases that captured national attention.

  • September 13, 2024

    IRS Monitoring Of Cloud IT Security Lacking, TIGTA Says

    An audit of the IRS' cloud computing systems found that the agency was lacking in several areas, including not keeping up with systems to maintain the security of cloud computing services, according to a report released Friday by the Treasury Inspector General for Tax Administration.   

  • September 13, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included proposed regulations on clean electricity low-income community bonus credits and procedures for obtaining the IRS' automatic consent to change accounting methods to comply with changes to the treatment of research and development costs.

  • September 13, 2024

    Mortgage Co. CEO Gets 11 Years In Prison For Ponzi Scams

    A mortgage company owner was sentenced Thursday to 11 years and three months in prison for defrauding investors, a community bank and the government's pandemic relief program to cover gambling debts and personal expenses like luxury cars, Philadelphia's top federal prosecutor announced.

  • September 13, 2024

    Treasury Proposes Rules Defining Tax-Exempt Tribal Benefits

    Treasury and the Internal Revenue Service released proposed rules Friday that would define what qualifies as tribal welfare benefits exempt from taxable income.

  • September 13, 2024

    IRS Extends La. Tax Deadlines For Francine Storm Victims

    Victims of Hurricane Francine throughout Louisiana will have more time to file some tax returns and make estimated payments, the Internal Revenue Service announced Friday.

  • September 12, 2024

    AGs Ask 2nd Circ. To Revive Their SALT Cap Workaround Suit

    Attorneys general from New York, New Jersey and Connecticut asked the Second Circuit to revive their challenge to an IRS rule prohibiting workarounds to the federal cap on state and local tax deductions, saying the rule was arbitrary and contrary to congressional intent.

  • September 12, 2024

    Convicted Fraudster Seeks To Challenge $21M Restitution

    A Florida man convicted of defrauding hospitals in a payroll fraud scheme urged the Eleventh Circuit Thursday to allow him to challenge a $21 million restitution award while still in prison, saying he wasn't allowed to challenge inaccurate information during sentencing.

  • September 12, 2024

    Wilson Sonsini Hires Tax Pro From Slaughter and May

    Wilson Sonsini Goodrich & Rosati PC has recruited a tax specialist from Slaughter and May to its office in London to boost its strengths representing U.K. and European technology and life sciences companies that are expanding in the U.S. and globally.

  • September 12, 2024

    Ex-Mass. State Sen. Tran Convicted Of Pandemic Aid Fraud

    Former Massachusetts State Sen. Dean Tran was convicted Wednesday of fraudulently collecting pandemic unemployment benefits after he was voted out of office and of cheating on his taxes.

  • September 12, 2024

    House OKs Tightening Restrictions On Tax Credit For EVs

    The U.S. House of Representatives voted in favor of a bill Thursday that would place further restrictions on qualifications for a tax credit for new electric vehicles amid concerns that current limits don't do enough to keep the benefits from flowing to foreign adversaries, including China.

  • September 12, 2024

    IRS Lacked Way To Track CAMT Comments, TIGTA Finds

    The IRS Office of Chief Counsel did not always track comments it received in response to guidance issued on the corporate alternative minimum tax and did not have detailed procedures in place for the pre-rulemaking guidance process, the Treasury Inspector General for Tax Administration reported Thursday.

  • September 12, 2024

    Treasury Floats Long-Awaited Rules For Corp. Minimum Tax

    Treasury and the IRS released eagerly awaited rules Thursday on the new 15% corporate alternative minimum tax on corporations with reported profits of $1 billion or more, taking a step toward implementing a key provision of President Joe Biden's signature 2022 tax and climate law.

  • September 11, 2024

    Philly Loan Biz Brothers Admit To $100M Investment Scam

    The two brothers helming Philadelphia's Par Funding cash advance company admitted to reaping $100 million through an investment fraud scheme that could land them each over a decade in prison, Philadelphia's top federal prosecutor announced.

  • September 11, 2024

    Tax Court Affirms Sushi Restaurant Owner's Labor Deductions

    The U.S. Tax Court ruled Wednesday that the owner of an Alabama sushi restaurant was entitled to deduct nearly $292,000 in contract labor expenses for 2015 and 2016.

  • September 11, 2024

    House Tax Panel OKs Repeal Of $600 Reporting Threshold

    The House Ways and Means Committee advanced several bills Wednesday, including one that would repeal a law requiring peer-to-peer payment platforms such as Venmo and PayPal to report aggregate payments of $600 or more.

  • September 11, 2024

    Mass. Jury Weighs Raft Of Fraud Charges Against Ex-Pol

    A Boston federal jury resumed deliberations Wednesday in a criminal case alleging a former Massachusetts state senator lied on his taxes and an application for pandemic unemployment aid, after the ex-politico testified in his own defense.

  • September 11, 2024

    Bipartisan House Bill Would Make Short Rail Credit Permanent

    A bipartisan bill introduced in the U.S. House of Representatives would permanently extend a tax credit for regional and short-line railroads that expired at the end of 2017, according to an announcement Wednesday.

  • September 11, 2024

    Worker Credit Moratorium Effectively Killed Claims, Court Told

    An Internal Revenue Service moratorium on processing tax credits for retaining employees during the coronavirus pandemic has effectively disallowed the granting of credits to deserving businesses, a Texas Montessori school told a federal court as it pursued a refund of nearly $200,000 in credits.

  • September 11, 2024

    McCarter & English Recruits EY Tax Pro In New Jersey

    McCarter & English LLP has bulked up its tax and employee benefits team in New Jersey with a longtime Ernst & Young expert at a time when the Garden State's business community is bracing for regulations on a series of corporate tax reforms. 

  • September 11, 2024

    Missouri Man Gets 3 Years In Prison For Fraud, Tax Crimes

    A Missouri man was sentenced to three years in prison for attempting to raid bank accounts and fetching roughly $3 million in corporate tax refunds for a bogus company, Connecticut's top federal prosecutor announced.

  • September 11, 2024

    Latham Hires Senior Tax Pro From Travers Smith In London

    Latham & Watkins LLP said on Wednesday that it has recruited a former head of tax at Travers Smith LLP for its office in London, a blow for the U.K. law firm, which has been hit by the departure of a series of partners.

  • September 10, 2024

    Wealthiest 0.01% Had 34% Average Tax Rate, JCT Says

    The income group constituting the top 0.01% wealthiest individuals had an average federal tax rate of 34% in 2019, the Joint Committee on Taxation said in a report on high-income and high-wealth taxpayers.

  • September 10, 2024

    Werfel Asked To Clarify How To Treat R&D Costs In M&A

    Accounting firm RSM US LLP, in a letter released Tuesday, asked Internal Revenue Commissioner Daniel Werfel to clarify how to treat research and development costs when a taxpayer disposes of an entire business in a mergers and acquisitions transaction.

Expert Analysis

  • Brownfield Questions Surround IRS Tax Credit Bonus

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    Though the IRS has published guidance regarding the Inflation Reduction Act's 10% adder for tax credits generated by renewable energy projects constructed on brownfield sites, considerable guesswork remains as potential implications seem contrary to IRS intentions, say Megan Caldwell and Jon Micah Goeller at Husch Blackwell.

  • Law Firms Should Move From Reactive To Proactive Marketing

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    Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.

  • The Big Issues A BigLaw Associates' Union Could Address

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    A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.

  • It's Time For A BigLaw Associates' Union

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    As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.

  • Why DOJ's Whistleblower Program May Have Limited Impact

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    The U.S. Department of Justice’s new whistleblower pilot program aims to incentivize individuals to report corporate misconduct, but the program's effectiveness may be undercut by its differences from other federal agencies’ whistleblower programs and its interplay with other DOJ policies, say attorneys at Milbank.

  • How Justices Upended The Administrative Procedure Act

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    In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.

  • Trump's Best Hush Money Appeal Options Still Likely To Fail

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    The two strongest potential arguments former President Donald Trump could raise in appealing his New York hush money conviction seem promising at first, but precedent strongly suggests they will still ultimately fail — though, of course, Trump's unique position could lead to surprising results, says former New York Supreme Court Justice Ethan Greenberg, now at Anderson Kill.

  • Tips For Tax Equity-Tax Credit Transfers That Pass IRS Muster

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    Although the Internal Revenue Service has increased its scrutiny of complex partnership structures, which must demonstrate their economic substance and business purpose, recent cases and IRS guidance together provide a reliable road map for creating legitimate tax equity structures, say Ian Boccaccio and Michael Messina at Ryan Tax.

  • Mirror, Mirror On The Wall, Is My Counterclaim Bound To Fall?

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    A Pennsylvania federal court’s recent dismissal of the defendants’ counterclaims in Morgan v. Noss should remind attorneys to avoid the temptation to repackage a claim’s facts and law into a mirror-image counterclaim, as this approach will often result in a waste of time and resources, says Matthew Selmasska at Kaufman Dolowich.

  • 3 Leadership Practices For A More Supportive Firm Culture

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    Traditional leadership styles frequently amplify the inherent pressures of legal work, but a few simple, time-neutral strategies can strengthen the skills and confidence of employees and foster a more collaborative culture, while supporting individual growth and contribution to organizational goals, says Benjamin Grimes at BKG Leadership.

  • E-Discovery Quarterly: Rulings On Hyperlinked Documents

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    Recent rulings show that counsel should engage in early discussions with clients regarding the potential of hyperlinked documents in electronically stored information, which will allow for more deliberate negotiation of any agreements regarding the scope of discovery, say attorneys at Sidley.

  • Loper Bright Limits Federal Agencies' Ability To Alter Course

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    The U.S. Supreme Court's recent decision to dismantle Chevron deference also effectively overrules its 2005 decision in National Cable & Telecommunications Association v. Brand X, greatly diminishing agencies' ability to change regulatory course from one administration to the next, says Steven Gordon at Holland & Knight.

  • A Guide To Long-Term, Part-Time Employee Determinations

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    With final regulations under the Secure Act requiring 401(k) retirement benefits for long-term, part-time employees expected soon, Amy Sheridan and David Guadagnoli at Sullivan & Worcester look at how the proposed rules would shift the risk-reward calculus on excluding categories of employees, and what plan sponsors would need to consider when designing retirement plans.

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