Federal

  • June 03, 2024

    Taxes Take Center Stage In Pot Industry Amid Fed. Policy Shift

    The federal government's move to loosen restrictions on cannabis is expected to trigger a wave of mergers and acquisitions structured as asset deals in the industry, especially among struggling retail operations willing to restructure in order to raise profits and lower their tax liabilities.

  • June 03, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin, which included an updated list of procedures for taxpayer-initiated requests for changes in methods of accounting.

  • June 01, 2024

    Blockbuster Summer: 10 Big Issues Justices Still Must Decide

    As the calendar flips over to June, the U.S. Supreme Court still has heaps of cases to decide on issues ranging from trademark registration rules to judicial deference and presidential immunity. Here, Law360 looks at 10 of the most important topics the court has yet to decide.

  • May 31, 2024

    3M Tells 8th Circ. IRS Used Invalid Regs For $24M Allocation

    Multinational conglomerate 3M reiterated Friday its bid for the Eighth Circuit to reverse a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from the company's Brazilian affiliate, arguing the agency's adjustment relied on substantively invalid regulations.

  • May 31, 2024

    IRS Guidance Narrows Spinoffs Available For Preapproval

    Recent IRS guidance limiting the types of spinoff transactions that revenue officials will approve as tax-free ahead of time leaves practitioners and corporations to determine whether to pursue certain intercompany reorganizations without the agency's blessing.

  • May 31, 2024

    Ex-UBS Exec Owes $4.7M In FBAR Penalties, Court Told

    A former CEO of Swiss bank UBS' North American group faces a $4.7 million tax bill that the U.S. claims is due because he did not report his foreign bank accounts or assets, according to a suit filed in Connecticut federal court.

  • May 31, 2024

    IRS Can Seek Tax Beyond Bankruptcy Deal, 11th Circ. Affirms

    A deal between the IRS and an Alabama real estate developer to settle his tax debt for $2 million during Chapter 11 bankruptcy proceedings wasn't final, and the agency can demand additional taxes from him, the Eleventh Circuit affirmed Friday.

  • May 31, 2024

    US, Bulgaria Sign Country-By-Country Reporting Agreement

    The U.S. and Bulgaria signed an agreement Friday on the automatic exchange of country-by-country reports between the nations, Bulgaria's Ministry of Finance said.

  • 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.

Expert Analysis

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    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.

  • IRS Sings New Tune: Whistleblower Form Update Is Welcome

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    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.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    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.

  • Energy Community Tax Credit Boost Will Benefit Wind Sector

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    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.

  • Weisselberg's Perjury At Trial Spotlights Atty Ethics Issues

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    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.

  • Practicing Law With Parkinson's Disease

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    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.

  • 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.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    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.

  • Trump's NY Civil Fraud Trial Spotlights Long-Criticized Law

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    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.

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

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    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.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

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    As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.

  • How IRA Unlocks Green Energy Investments For Tribes

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    An Inflation Reduction Act provision going into effect May 10 represents a critical juncture for Native American tribes, offering promising economic opportunity in green energy investment, but requiring a proactive and informed approach when taking advantage of newly available tax incentives, say attorneys at Lewis Brisbois.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

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    Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.

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