• November 22, 2017

    Ireland Boosts Use Of Technology In Tax Evasion Inquiry

    Revenue, Ireland’s tax authority, is employing a host of novel techniques to seek out and track offshore tax evasion, including use of proprietary software and machine-learning technologies to digest data ranging from income returns to social media accounts.

  • November 22, 2017

    Cities And States Brace For Loss Of SALT Deductions

    As the work of reforming the federal tax code took a temporary timeout for Thanksgiving, opponents of legislation that would fully or partly eliminate deductions for state and local taxes didn’t let up in their fight, despite increasingly long odds they would succeed in changing lawmakers' minds when they return from their break.

  • November 22, 2017

    Gov’t Sues Ill. Couple For Evading $1M In Taxes Since 1997

    The U.S. government sued an Illinois couple Tuesday, alleging they failed to pay over $1 million in personal federal income taxes since 1997.

  • November 22, 2017

    Pa. High Court Reverses Ruling On Corp. Tax Appeal Window

    The Pennsylvania Supreme Court reversed a lower court’s ruling Wednesday, saying the date that taxes are paid marks the starting point for a three-year appeal window, rather than when they are finalized with the submission of a company’s annual report.

  • November 22, 2017

    UK Promises Tough Paradise Papers Response In Budget

    Britain’s Treasury promised new measures to tackle tax dodging on Wednesday in its budget statement and is set to bolster enforcement following a string of leaks that highlight how the U.K. is a major conduit for tax evasion.

  • November 21, 2017

    Ex-Swiss Banker Acquitted Of Helping US Tax Evaders

    A New York federal jury on Tuesday acquitted a former Swiss banker of what prosecutors alleged was a criminal conspiracy to help U.S. taxpayers hide millions of dollars in undeclared income in offshore bank accounts to dodge taxes.

  • November 21, 2017

    Calif. Couple's $500K Settlement Not Excludable: 9th Circ.

    The Ninth Circuit on Monday affirmed U.S. Tax Court findings that a California couple's settlement proceeds could not be excluded from their gross income and the couple could not avoid penalties after failing to prove they acted in good faith when they understated their income tax liability.

  • November 21, 2017

    'Willfulness' In Civil FBAR Cases Comes Down To The Facts

    A judge’s recent decision to let a pharmaceutical CEO escape civil penalties for failing to report his Swiss bank account doesn’t necessarily signal that courts could be a reliable counterweight against the IRS’ dwindling sympathy, tax specialists say, but instead highlights the fact-dependent approach for determining willful nondisclosure.

  • November 21, 2017

    Philly Lawyers Denied Tax Board Back Pay In Appeal

    A Pennsylvania appeals court ruled Tuesday that three Philadelphia lawyers, including a former state Supreme Court justice, who served on the city’s Board of Revision of Taxes were not entitled to back pay after their salaries were reduced by an ordinance later declared unconstitutional.

  • November 20, 2017

    6th Circ. Won't Revive Truck Dealer's $4M Tax Refund Suit

    The Sixth Circuit on Monday denied a Kentucky truck dealer’s bid to revive its suit seeking to recoup over $4 million in excise taxes, finding that without consent forms from customers — who ultimately paid the tax — the retailer failed to follow administrative refund procedures.

  • November 20, 2017

    Ex-Willkie, Hunton Atty Cops To Role In $7.8M Scheme

    A former Willkie Farr & Gallagher LLP and Hunton & Williams LLP partner admitted Monday in New Jersey federal court to taking part in a scheme with her estranged husband to defraud the firms and Mastercard Inc. out of roughly $7.8 million by billing them for work that was not performed.

  • November 20, 2017

    Eaton Says Investors' 2nd Complaint In Tax Info Suit Fails

    Eaton Corp. PLC asked a New York federal judge on Friday to dismiss a second amended complaint in a proposed shareholder class action alleging the company defrauded shareholders about its desire or ability to sell a major business unit in the wake of a controversial merger.

  • November 20, 2017

    Feds Get Court Costs In BB&T's Tax Fight Over $1.5B Loan

    The U.S. Court of Federal Claims on Friday allowed the U.S. government to recover most of the litigation costs related to BB&T Corp.’s unsuccessful bid for foreign tax credits tied to a $1.5 billion loan from Barclays Bank PLC, but the court also found certain expenses were unnecessary despite the complexity of the case.

  • November 17, 2017

    Tax Bill’s Ambiguity Increases Investors’ Litigation Risk

    The tax bill that recently passed the U.S. House of Representatives is missing key definitions and contains ambiguous terms relating to the use of so-called carried interest in the asset management business, which could result in investors taking risky positions on their tax returns to seek clarification from the courts.

  • November 17, 2017

    High Court Asked To Review Attorney Fee Denial In Tax Case

    A taxpayer petitioned the U.S. Supreme Court to review a Fourth Circuit decision upholding a district court’s rejection of his motion to recover nearly $600,000 in attorneys' fees, even though he prevailed on the merits of the underlying case.

  • November 17, 2017

    Senate Tax Bill Amendments Include Whistleblower Incentives

    Sen. Orrin Hatch, R-Utah, on Thursday night offered last-minute amendments to the GOP tax bill that included tax deductions and potentially larger awards for whistleblower claims.

  • November 17, 2017

    UK Litigation Roundup: Here's What You Missed In London

    The last week has seen a consulting firm sue the shareholder rights group that challenged the Royal Bank of Scotland, Lehman Brothers' bankrupt European unit take on HMRC, and three reinsurers lodge a claim against Petroleos de Venezuela's captive insurer. Here, Law360 looks at those and other new claims in the U.K.

  • November 17, 2017

    Industry Defends Senate Tax Bill's Private Jet Fee Exemption

    Aviation industry groups are defending a new provision affecting private aircraft management firms in the Senate GOP tax reform bill.

  • November 17, 2017

    FERC Finds Utilities' Tax Recording Could Affect Rates

    Utilities have incorrectly recorded income tax overpayments as prepayments for the next year even though they elected to receive refunds, according to a Federal Energy Regulatory Commission report issued Thursday, which flagged other accounting errors that may have affected certain consumer billings.

  • November 17, 2017

    Mich. Tribe Wins Bid To Strengthen Casino Doc Protections

    A federal magistrate judge on Thursday granted the Keweenaw Bay Indian Community’s request to strengthen the protective order in its suit against Michigan officials over the state’s taxing authority.

Expert Analysis

  • Acting As Fiduciary Is Always In An Atty's Best Interest

    Stuart Riemer

    Attorneys understand the importance of fiduciary duty when providing legal counsel to their clients. But the U.S. Department of Labor's new rule on conflicts of interest makes it important to act as a fiduciary in other situations as well, such as when serving as a trustee or as the executor of an estate, says Stuart Riemer of Treasury Partners.

  • Opinion

    Like-Kind Exchanges: Crucial To Small Business Growth

    Brent Abrahm

    For more than 90 years, like-kind exchanges under Section 1031 of the Internal Revenue Code have been a key tool for small businesses and investors. But this powerful economic driver is now in real danger as Congress and the Trump administration ponder its possible elimination as part of tax reform, says Brent Abrahm of Accruit.

  • Congressional Forecast: October

    Richard Hertling

    In contrast to the September work period, when an unsuccessful effort to repeal the Affordable Care Act topped the congressional agenda, the three-week October session is likely to see Republican House and Senate leaders try to advance another of their central policy goals: comprehensive tax reform, say Richard Hertling and Kaitlyn McClure of Covington & Burling LLP.

  • 4 Employer Concerns During And After Natural Disasters

    Shira Yoshor

    It seems natural disasters have dominated the news in the past month, and employers have to know how far they must go to help during these difficult times. Questions about payment of wages, the Family and Medical Leave Act, accommodation for stress, and disaster-related health issues are just a few of the concerns employers must confront in the face of a storm or other major disruptive event, says Shira Yoshor of Greenberg Traurig LLP.

  • Collaboration Between Company's Tax And IP Experts: Part 1

    Rebel Curd

    Within a multinational enterprise, coordination between the tax, legal and intellectual property management professionals is essential to ensure that the strategic and financial objectives for IP assets are achieved while minimizing potential risks, say consultants at Charles River Associates.

  • The Challenges Of Administering A Robot Tax

    Robert Kovacev

    A San Francisco county supervisor is leading an effort to impose a tax on businesses that install “robots, algorithms, or other forms of automation” that displace workers. Such proposals stem from legitimate concerns, but it is surprisingly difficult to define what a robot is, says Robert Kovacev of Steptoe & Johnson LLP.

  • An IRS Lifeline To Public Utilities On Normalization

    Jeffrey Davis

    Last week, the Internal Revenue Service provided a safe harbor for public utilities that inadvertently break the so-called normalization rules, which are used to reconcile tax treatment of investment tax credits, or accelerated depreciation of assets, with their regulatory treatment. This is undoubtedly good news for public utilities, say attorneys with Mayer Brown LLP.

  • How Collaboration Is Changing Inside Some Law Firms

    Chris Cartrett

    In our recent survey of business of law professionals, nearly half of respondents said that who they collaborate with, inside their law firm, is different from five years ago, says Chris Cartrett of legal software provider Aderant.

  • New Flexibility Comes To REIT Earnings Distribution

    Sarah Beth Rizzo

    New IRS guidance will allow real estate investment trusts and regulated investment companies that would like to issue 80/20 stock/cash dividends to avoid the filing fee, drafting expense and approximately six-month delay associated with obtaining a private letter ruling, say Sarah Beth Rizzo and David Polster of Skadden Arps Slate Meagher & Flom LLP.

  • The Psychology Of Hourly Fee Arrangements

    J.B. Heaton

    The range of possible and better fee agreements is wide. But such alternatives will become popular only if litigants confront the psychological tendencies shaping their existing fee arrangements, says J.B. Heaton, a partner at Bartlit Beck Herman Palenchar & Scott LLP.