Federal
-
March 19, 2025
Tax Court Upholds Penalty On Early Retirement Withdrawal
A Florida man should have included his early withdrawal of roughly $57,000 from his retirement account in that year's tax return, the U.S. Tax Court said Wednesday, also agreeing that the agency was correct to assess an accuracy-related penalty against him.
-
March 19, 2025
Technical, Policy Questions Still Swirl Around Amount B
U.S. multinational corporations have welcomed the option of a simplified transfer pricing approach under an international tax framework known as Amount B, but uncertainties linger about how the rules will ultimately shake out on a technical level both domestically and globally.
-
March 19, 2025
7th Circ. Orders Tax Court To Clarify ESOP Suit Dismissal
The Seventh Circuit axed the U.S. Tax Court's dismissal of a transit company's suit over an employee stock ownership plan, saying the lower court must specify that it lacked the authority to review the case because it was filed before the IRS completed an exam.
-
March 19, 2025
6th Circ. Says Pharmacist Doesn't Owe Tax On Forfeited IRA
A pharmacist doing time for running a Kentucky pill mill doesn't owe taxes on his forfeited retirement account, the Sixth Circuit ruled Wednesday, reversing a U.S. Tax Court decision that upheld what the appeals court described as an unexpected punishment.
-
March 19, 2025
Satellite Startup Execs Accused Of Fraud And Tax Evasion
An aerospace company's founder, an attorney and other executives lied about a venture to launch billions of dollars in satellites so they could rake in millions from investors, according to an indictment in D.C. federal court that also charges the founder with tax crimes.
-
March 19, 2025
Goldstein Says Feds 'Misled' Court With Obstruction Claim
U.S. Supreme Court lawyer and SCOTUSblog publisher Tom Goldstein wants a Maryland federal judge to sanction prosecutors in his tax evasion case for a "pattern of false and misleading statements" to the court accusing him of hiding millions in cryptocurrency and bribing his former law firm manager.
-
March 19, 2025
DC Judge Won't Preemptively Stop IRS Data Sharing With DHS
A D.C. federal judge on Wednesday said two immigrant rights groups had not shown that the IRS is poised to unlawfully share noncitizen taxpayer records with immigration enforcement authorities, rejecting their bid for a court order that would preemptively block any information transfer.
-
March 19, 2025
Law360 Announces The Members Of Its 2025 Editorial Boards
Law360 is pleased to announce the formation of its 2025 Editorial Advisory Boards.
-
March 19, 2025
Taxpayer Advocacy Joint Committee To Meet In April
The Taxpayer Advocacy Panel's Joint Committee will meet April 21 following a string of meetings by individual subcommittees earlier in the month, the Internal Revenue Service said Wednesday.
-
March 18, 2025
Tax Court Sides With IRS Deeming Debt 'Seriously Delinquent'
A Florida man's tax debt was property certified by the Internal Revenue Service as "seriously delinquent" and reported to the U.S. secretary of state to bar him from obtaining or renewing a passport, the U.S. Tax Court said Tuesday.
-
March 18, 2025
Express Scripts Denied Tax Break For Software In $43M Suit
Express Scripts is not entitled to a tax deduction for domestic production activities related to its software because it did not grant licenses to pharmacy benefit plan sponsors who used it, a Missouri federal court said Tuesday, denying the company's request for a tax refund in its $43 million case.
-
March 18, 2025
Tax Court Cleared To Resolve IRS Offset Feud, Justices Told
The U.S. Tax Court can still adjudicate a case challenging an Internal Revenue Service collection action even after the agency tried to improperly zero out the disputed liability in an attempt to dismiss the suit, a New Jersey woman told the U.S. Supreme Court.
-
March 18, 2025
Trump Hasn't Asked IRS For Immigrants' Tax Info, Gov't Says
The IRS hasn't received any requests from President Donald Trump for immigrants' tax return information and hasn't released any such information to the U.S. Department of Homeland Security, the government told a D.C. federal court in opposing a restraining order sought by immigrant rights groups.
-
March 18, 2025
5th Circ. Backs La. Doctor's Tax Evasion Conviction
The Fifth Circuit declined to overturn a Louisiana doctor's felony tax evasion conviction, rejecting her contention that jurors received muddied instructions that led to her being wrongly found guilty of dodging $1.6 million taxes and sentenced to more than four years in federal prison.
-
March 18, 2025
Judge Probes Atty Conflict In Vanguard $40M Settlement
A Pennsylvania federal judge questioned whether attorneys representing investors suing Vanguard over surprise tax bills have a conflict of interest in pushing for a $40 million settlement, adding to concerns about a parallel regulatory settlement that has delayed approval of the deal.
-
March 17, 2025
Florida Businessman Pleads Guilty To Hiding $20M From IRS
A Florida businessman faces up to five years in prison after he pled guilty Monday to hiding $20 million in Swiss bank accounts from the Internal Revenue Service.
-
March 17, 2025
Split 9th Circ. Won't Halt Federal Workers Reinstatement Order
A divided Ninth Circuit panel on Monday denied President Donald Trump's administration an immediate administrative stay of a California district court order requiring reinstatement of some probationary federal workers fired from six agencies, the majority saying a pause "would disrupt the status quo and turn it on its head."
-
March 17, 2025
The Tax Angle: Lawmakers Huddle To Mull TCJA
From a look at the three-day legislative retreat held by House Democrats to Ways and Means Republicans meeting behind closed doors to discuss the 2017 GOP tax overhaul, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
-
March 17, 2025
$19M In Partner Shares Not Earnings, Co. Tells Tax Court
A New York-based investment partnership accused the Internal Revenue Service of wrongly increasing its income subject to self-employment taxes by about $19 million by misclassifying its limited partners to include their shares, according to a U.S. Tax Court petition.
-
March 17, 2025
10th Circ. Grapples With Liberty Global's $248M Tax Credit Bid
A Tenth Circuit panel questioned Monday whether Liberty Global is entitled to $248 million in foreign tax credits for the sale of a Japanese affiliate, or if legislation limits the telecommunications giant from classifying the gains as overseas income.
-
March 17, 2025
Kleinberg Kaplan Adds Simpson Thacher Atty As Tax Partner
Kleinberg Kaplan announced Monday that it has added a Simpson Thacher & Bartlett LLP attorney to help provide clients with expertise on tax aspects of private investment fund formation and operation, as well as mergers and acquisitions, joint ventures and financings.
-
March 17, 2025
Coloradan Owes FBAR Penalty After Failing To Appear
An elderly Colorado man who failed to respond to the government's claim that he owed $482,000 for failing to report his foreign bank accounts is on the hook for the bill, a federal court ruled.
-
March 17, 2025
High Value Dubious In $23M Easement Dispute, 11th Circ. Told
A partnership that claimed a $23 million tax deduction for a conservation easement donation failed to consider the lack of market demand for a potential quarry it used to justify the land's high value, the U.S. government told the Eleventh Circuit.
-
March 17, 2025
Applicable Federal Rates To Drop Again In April
Applicable federal rates for income tax purposes are set to decrease in April for the second month in a row, the Internal Revenue Service said Monday.
-
March 17, 2025
Six Taxpayer Advocacy Panel Committees To Meet In April
Six Taxpayer Advocacy Panel committees will meet in April to discuss possible improvements to customer services, the Internal Revenue Service said Monday.
Expert Analysis
-
Don't Use The Same Template For Every Client Alert
As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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
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
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.