Federal

  • May 14, 2024

    IRS Floats Property Rule Changes On Interest Capitalization

    The Internal Revenue Service floated changes Tuesday to the interest capitalization requirements for improvements constituting property production, including removing the so-called associated property rule that was invalidated by the Federal Circuit.

  • May 14, 2024

    Ex-Whiteford Taylor Business Co-Chair Joins Baker Donelson

    Baker Donelson Bearman Caldwell & Berkowitz PC has welcomed a new shareholder who spent more than a decade with the Internal Revenue Service and previously co-chaired Whiteford Taylor & Preston LLP's business department, the firm announced on Monday.

  • May 14, 2024

    IRS Finalizes Slash Of Preparer ID Fee

    The Internal Revenue Service will reduce the cost to apply for or renew a preparer tax identification number by nearly 50%, the agency said in a final rule released Tuesday.

  • May 13, 2024

    NJ Fraudster Gets More Prison Time, Owes $6M For Tax Evasion

    A New Jersey man who was convicted of dodging taxes on more than $16 million he stole from securities fraud victims was handed a six-year prison sentence — most of which will be served simultaneously with his fraud sentence — and ordered to pay over $6 million in restitution during a Garden State federal court hearing Monday in which he denied the crimes. 

  • May 13, 2024

    Corp. Transparency Act An Overbroad Dragnet, 11th Circ. Told

    Congress exceeded its authority in passing the Corporate Transparency Act, which prompted the U.S. Treasury Department to solicit personal information for law enforcement purposes from those that registered and owned state-registered entities, a small-business group told the Eleventh Circuit on Monday.

  • May 13, 2024

    US Tells DC Circ. Ayahuasca Church's Settlement Inapt

    Federal regulators are telling the D.C. Circuit to ignore a recent settlement that will allow a Phoenix-based church to continue using ayahuasca in its ceremonies, saying it has nothing to do with the Iowa-based ayahuasca church challenging the IRS's refusal to give it tax-exempt status.

  • May 13, 2024

    House GOP Bills Target Foreign Funding To Tax-Exempt Orgs

    The House Ways and Means Committee will vote Wednesday on a package of bills that would increase scrutiny of foreign donations to tax-exempt organizations, including legislation that would require those organizations to publicly report the donations, the Joint Committee on Taxation announced Monday.

  • May 13, 2024

    Biz Coalition Pushes Senate To Renew R&D Tax Break

    The U.S. Senate should act quickly to renew a provision allowing research and development expenses to be immediately deductible, a coalition of businesses told the chamber's leaders in a letter Monday.

  • May 13, 2024

    2nd Circ. Won't Revive UBS Suit Over Disclosed Account Info

    The Second Circuit declined Monday to revive a couple's suit accusing UBS of fraudulently flagging an account to the Internal Revenue Service, finding that any alleged harm resulting from an audit would have been caused by the agency itself.

  • May 13, 2024

    Tax Court Denies Calif. Women Innocent Spouse Relief

    A California woman will not receive innocent spouse relief from a tax liability stemming from a joint return filed with her estranged husband, the U.S. Tax Court ruled Monday, saying any reasonable person would have questioned the return's accuracy.

  • May 13, 2024

    Texas Farming Couple Owe $1.9M, Tax Court Says

    An oral surgeon and his wife who raised large deer and bass for hunting and ecotourism in Texas are on the hook for nearly $1.9 million in taxes, as a U.S. Tax Court decision issued Monday found that they weren't entitled to farming deductions.

  • May 13, 2024

    Energy Credit Program For Low-Income Areas To Open May 28

    Applications for a clean-energy investment program that provides bonus tax credits for projects in low-income communities will open May 28, the Internal Revenue Service said Monday.

  • May 13, 2024

    Tax Lien Association Hires Industry Pro As GC

    The National Tax Lien Association has found its new general counsel in an experienced attorney less than four months after the death of its longtime top attorney.

  • May 13, 2024

    Houston Truck Co. Doesn't Owe $2M Excise Tax, 5th Circ. Told

    A Houston truck company that sells tires made by a Chinese manufacturer doesn't owe $2 million in import taxes because it's not legally the tire importer, the company told the Fifth Circuit in asking it to affirm a ruling that could split circuits.

  • May 13, 2024

    Semisubmersible Co. CEO Convicted Of Fraud, Fleeing Law

    The CEO of a semisubmersible manufacturer has been convicted by a Hawaii federal jury of financial fraud, witness tampering and attempting to escape law enforcement in one of his company's ocean vessels.

  • May 11, 2024

    Gov't Urges 8th Circ. To Uphold 3M's $24M Pricing Adjustment

    The U.S. government asked the Eighth Circuit to uphold a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from 3M's Brazilian affiliate, arguing the company's appeal involves misplaced reliance on a U.S. Supreme Court decision.

  • May 10, 2024

    4th Circ. Judge Suspects 'Abuse' In Land Donor Tax Case

    The Fourth Circuit appeared poised Friday to rule that a couple owes taxes and penalties after claiming an inflated $5.1 million valuation on donated land for deductions, with one judge positing he believed the couple had engaged in "abuse" of a conservation donation.

  • May 10, 2024

    Texas Couple Must Sell $2.3M In Assets To Satisfy Tax Claim

    A disbarred accountant and his wife must sell $2.27 million worth of their assets to satisfy her unpaid federal tax liabilities, a Texas federal judge ruled, handing an early win to the government.

  • May 10, 2024

    Biden To Seek Tax Hikes On Wealthy In 2025, Adviser Says

    One of President Joe Biden's key tax policy goals if he's still in office during negotiations over expiring Tax Cuts and Jobs Act provisions in 2025 is to increase revenue overall by raising taxes on corporations and wealthy taxpayers, National Economic Council Director Lael Brainard said Friday.

  • May 10, 2024

    DC Tax Atty Can't Use Ch. 7 To Ditch Depo In $19M Theft Suit

    A corporate D.C. tax attorney accused of bilking a former client out of $19 million via a captive insurance scam will be deposed, despite a stay in the Maryland federal case against him and his firm after both filed for bankruptcy.

  • May 10, 2024

    SEC Targets Fatburger's Parent Co. In $27M Loan Scheme

    The restaurant company that owns Fatburger and Fazoli's made illegal loans to its director and former chief executive, who spent $27 million in company money on himself while skirting taxes and leaving the company struggling, the Securities and Exchange Commission told a California federal court Friday. 

  • May 10, 2024

    Use Of AI For Tax Comment Letters Poses Ethical Quandaries

    While artificial intelligence can streamline the process of conducting a comprehensive review of complex, IRS-proposed federal tax regulations, tax attorneys must be aware of professional and ethical considerations when using it to help draft comment letters to submit to the agency.

  • May 10, 2024

    IRS Schedules 7 Taxpayer Advisory Panel Meetings For June

    The Internal Revenue Service announced Friday the schedule for seven Taxpayer Advocacy Panel committee meetings in June.

  • May 10, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin, which included proposed regulations regarding the application of the stock repurchase excise tax.

  • May 09, 2024

    'Lobster Broker' Biz Owner Liable For Dividends Deficiency

    A Florida man who owned 50% of the stock of a "lobster broker business" is on the hook for a federal income tax deficiency related to nearly $193,000 in dividends from the business, the U.S. Tax Court said Thursday, but the man isn't liable for an accuracy-related penalty.

Expert Analysis

  • 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.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

  • Kentucky Tax Talk: Taking Up The Dormant Commerce Clause

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    Attorneys at Frost Brown examine whether the U.S. Supreme Court is likely to review Foresight Coal Sales v. Kent Chandler to consider whether a Kentucky utility rate law discriminates against interstate commerce, and how the decision may affect dormant commerce clause jurisprudence.

  • Prevailing Wage Rules Complicate Inflation Act Tax Incentives

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    Nicole Elliott and Timothy Taylor at Holland & Knight discuss the intersection between tax and labor newly created by the Inflation Reduction Act, and focus on aspects of recent U.S. Department of Labor and U.S. Department of the Treasury rules that may catch tax-incentive seekers off guard.

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