• February 6, 2018

    10th Circ. Reverses Okla. Tribe's $27M Alcohol Tax Win

    A three-judge Tenth Circuit panel on Tuesday reversed and vacated an arbitration decision that had exempted Oklahoma tribe Citizen Potawatomi Nation from $27 million in alcohol sales taxes, saying a tribal-state gaming compact was unenforceable.

  • February 6, 2018

    Mass. Justices Question Legality Of 'Millionaire Tax' Petition

    Justices on Massachusetts' high court pushed back on Tuesday against the proponents of a ballot initiative that would increase income taxes on the state's highest earners and send the money to education and transportation programs, at times echoing a cohort of businesses arguing against its constitutionality.

  • February 6, 2018

    Pa. Gov. Seeks Tax On Natural Gas To Fund Education

    Pennsylvania Gov. Tom Wolf unveiled his 2019 budget plan Tuesday, calling for increased spending on education that would be partially offset by a new tax on natural gas.

  • February 6, 2018

    Sunoco Downplays Cost To Gov't In $306M Fed. Circ. Tax Row

    Sunoco urged a Federal Circuit panel in oral arguments Tuesday to revive its bid for a $306 million tax refund, arguing the government has “drastically overstated” the harm Sunoco's calculation of an alcohol-fuel subsidy into its final tax bill would impose on federal tax collections.

  • February 6, 2018

    2nd Circ. Orders Judge To Justify Tax-Dodger's Record Fine

    The Second Circuit ordered U.S. District Judge Analisa Torres on Tuesday to further detail her thinking in slapping Morris E. Zukerman with a $10 million fine for decades of tax evasion, after counsel for the incarcerated financier argued the penalty was orders of magnitude higher than any other.

  • February 6, 2018

    Tax Group Of The Year: Mayer Brown

    Mayer Brown LLP’s tax practice — a global heavyweight in the transactional and litigation spheres — was a shoo-in for Law360’s 2017 Practice Groups of the Year after having successfully defended Eaton Corp. against the IRS’ cancellation of two agreements and guided several multibillion-dollar transactions such as a major Canadian bank’s expansion in the U.S. and one of last year’s largest IPOs.

  • February 6, 2018

    Pa. Panel Orders Redo In Railroad Tax Exemption Fight

    A Pennsylvania appeals court said on Tuesday that a trial judge had failed to properly analyze what portions of an 85-acre railroad transfer depot owned by Lehigh Valley Rail Management LLC could be declared exempt from state utility taxes as an essential part of its operations at the site.

  • February 5, 2018

    Former Dell Employee, Accomplice Sentenced For Fraud

    A Texas federal court on Friday sentenced a former Dell Inc. employee to more than three years in federal prison and $10.8 million in restitution and his accomplice to 26 months in prison and $849,000 in restitution after they pled guilty to defrauding the company.

  • February 5, 2018

    House Panel Seeks Reformed Hiring Practices At IRS

    The House Committee on Oversight and Government Reform asked Friday for information on the Internal Revenue Service’s pledge to reform its hiring practices to ensure that past employees with documented performance issues are not rehired, saying it’s unclear if the agency’s vow has been carried out.

  • February 5, 2018

    IRS May Struggle To Comply With 2-For-1 Regulation Order

    The IRS has said little about how it will carry out President Donald Trump’s executive order requiring government agencies to eliminate two regulations for every new one created, but complying with the order appears daunting for a resource-strapped agency already strained to its limits.

  • February 5, 2018

    Amazon Settles €196M Tax Dispute With France

    Amazon has reached a deal with France over €196 million ($244 million) in taxes the tech giant allegedly owed in the country, according to a recent filing with the U.S. Securities and Exchange Commission, which did not disclose the settlement amount.

  • February 5, 2018

    Wells Fargo Denied New Trial In $1.25B Tax 'Sham' Case

    A Minnesota federal judge on Monday denied Wells Fargo & Co.’s request for a new trial in a case over a $1.25 billion transaction deemed a tax "sham" by the Internal Revenue Service, saying it could not consider new arguments by the financial institution.

  • February 5, 2018

    Tax Scammer's Wife Pleads With 2nd Circ. Over Seized Funds

    The wife of an attorney who helped set up illegal tax shelters sought Monday to convince a Second Circuit panel to overturn a lower judge’s ruling that allowed the feds to seize funds he gave to her, but the judges gave little hint as to how they might rule.

  • February 5, 2018

    Fla. High Court Won't Hear Key West Stormwater Fee Dispute

    The Florida Supreme Court declined Friday to take up the appeal of a decision allowing the city of Key West to impose a stormwater utility fee on three properties that are on another island and benefit minimally from the stormwater system.

  • February 5, 2018

    IRS Asks Supreme Court To Skip Appeal In Marijuana Case

    The IRS on Friday defended its authority to deny tax credits to drug traffickers and urged the U.S. Supreme Court to deny an appeal by a Colorado marijuana company that argued the IRS lacks the power to investigate drug cases.

  • February 5, 2018

    Tax Group Of The Year: Davis Polk

    This past year saw Davis Polk & Wardwell LLP's tax team mop up a $2.4 billion victory for Citigroup Inc. and advise Baker Hughes Inc. on its $32 billion combination with General Electric’s oil and gas business, earning the firm a place among Law360’s Tax Practice Groups of the Year.

  • February 5, 2018

    From Amazon To Foxconn, Incentives To Woo Biz Scrutinized

    Recent efforts by 20 finalist cities to entice Amazon to build its new headquarters in their community and by Wisconsin to lure Foxconn have sparked a trend of heightened awareness and scrutiny over using tax dollars to woo and keep businesses and to create jobs.

  • February 2, 2018

    Iran UN Consultant Gets 3 Months For Tax, Sanctions Crimes

    A researcher for Iran's mission to the United Nations who copped to tax evasion and sanctions violations was sentenced by a Brooklyn federal judge to three months in prison on Friday after he testified at length to rebut prosecutors' insinuations that he worked for Iranian intelligence.

  • February 2, 2018

    Locke Lord Adds Tax, Transaction Atty From Andrews Kurth

    Locke Lord LLP’s tax practice received a boost with the addition of a partner in its Dallas office, as the firm announced Thursday the addition of a former Andrews Kurth Kenyon LLP attorney with significant experience navigating the tax complexities of various transactional, real estate and capital markets matters.

  • February 2, 2018

    For States, New Federal Tax Law Is A Big Problem To Solve

    The new federal tax reform law has thrown states for a loop, and Vermont on Friday showed exactly why when it joined other states to switch to federal adjusted gross income from federal taxable income.

Expert Analysis

  • Tax Reform Reshuffles The Deck For Outsourcing

    Gary Wilcox

    The new tax bill changes the calculus for cross-border services outsourcing and cloud agreements. For a U.S.-parented provider deciding whether to increase its U.S. operations relative to non-U.S. operations, several provisions must be considered, including the deduction for foreign-derived intangible income, the tax on global intangible low-taxed income and the base erosion and anti-abuse tax, say attorneys at Mayer Brown LLP.

  • Tax Overhaul Is A Mixed Blessing For The Finance Industry

    Michele Alexander

    The 40 percent reduction in the statutory corporate rate stands to yield major benefits for the finance sector. But other provisions in the Tax Cuts and Jobs Act, including international anti-abuse laws, may unintentionally burden banks, say Michele Alexander and Ryan Davis of Bracewell LLP.

  • America's Shifting Views On Marijuana Post-Cole Memo

    Jonathan Robbins

    Although Attorney General Jeff Sessions' rescission of the Cole memo does not change federal law, negative response to the rescission across the cannabis sector and political landscape was strong, swift and bipartisan, which may lead to congressional action in the future, say Jonathan Robbins and Joshua Mandell of Akerman LLP.

  • An Important International Provision In The Tax Act

    Charles Purcell

    The Tax Cut and Jobs Act made significant changes to the taxation of foreign income of U.S. persons, including the introduction of a new type of income. Attorneys with K&L Gates LLP look at how the new global intangible low-taxed income could affect investment funds.

  • How Tax Reform Will Change FCA Settlements

    Douglas Baruch

    Little attention has been paid to a provision of the new tax law that requires federal agencies to specify, at the time of settlement of government claims, the portion of the settlement that may be deductible as a business expense. This is sure to impact False Claims Act and other settlements involving the government going forward, say attorneys with Fried Frank Harris Shriver & Jacobson LLP.

  • The Public Finance Industry Dodged A Tax Reform Bullet

    Victoria Ozimek

    The passage of the tax bill brought an end to a nearly two-month rollercoaster ride that had the public finance industry white-knuckled and a little green in the face. The final bill belied initial assurances that tax reform “won’t touch tax-exempt bonds,” but the end result could have been a lot worse, say Victoria Ozimek and Brian Teaff of Bracewell LLP.

  • The Latest From IRS On Section 409A Relief

    Marc Fosse

    Taxpayers required to include the value of their 457A plan benefit in income before receiving a distribution may find they have an unexpected tax hit without a plan distribution to cover the tax liability. But a notice recently issued by the IRS allows for distribution of funds from 457A plans without incurring additional penalties under Section 409A of the Internal Revenue Code, say Marc Fosse and Yatindra Pandya of Trucker Huss APC.

  • 6 E-Discovery Predictions For 2018

    Erich Potter

    Erich Potter, discovery counsel with Oles Morrison Rinker & Baker LLP, discusses six ways e-discovery will continue to excite and confound in 2018.

  • 6 Roles To Embrace In An Evolving Legal Industry

    Rob MacAdam

    Smart law firms are increasingly positioning professionals to proactively guide them as the legal landscape reshapes itself, harnessing six emerging roles within their organizational charts to embrace new approaches, tools and systems, says Rob MacAdam of HighQ.

  • Opinion

    This Year, Let’s Invest In Lawyer Resiliency

    Highly profitable companies have comprehensive corporate wellness programs that realize plateauing health care costs, greater employee engagement, and a demonstrable competitive advantage. The legal field needs a similar awakening, says Rudhir Krishtel, a former partner of Fish & Richardson and senior patent counsel at Apple.