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Tax
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April 17, 2024
Gov't Officials Urge Global Cooperation On Taxing Wealth
Global cooperation on taxing the wealthiest individuals and companies is necessary to address climate change and create social justice, government officials from Brazil, France and Nigeria said Wednesday at the International Monetary Fund's spring meeting.
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April 17, 2024
Tax Challenge Viable In Court, Philip Morris Tells NC Justices
A North Carolina administrative court has the power to find a state tax law unconstitutional, tobacco company Philip Morris USA has told the state Supreme Court in its attempt to avoid a more than $300,000 franchise tax bill.
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April 17, 2024
EmblemHealth Pushes IRS To Hand Over $6.7M Tax Refund
Not-for-profit insurance company EmblemHealth asked a New York federal court Wednesday to grant it a nearly $6.7 million tax refund, saying the Internal Revenue Service left a voicemail accepting its refund claim in February but still hasn't delivered the money.
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April 17, 2024
Swedish Tax Investigations Add $90M To Crypto Miners' Bills
Investigations revealed that a number of cryptocurrency mining centers in Sweden misrepresented their business dealings, which led to the Swedish Tax Agency doling out a total of 990 million Swedish krona ($90 million) in increased tax liabilities, the agency said Wednesday.
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April 17, 2024
9th Circ. Tosses $3.9M Tax Foreclosure Appeal As Premature
The Ninth Circuit dismissed a man's challenge to a court order that he believed allowed the government to foreclose on his property to pay his son's tax liabilities of more than $3.9 million, saying Wednesday that the appeal was premature because the order wasn't final.
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April 17, 2024
Judge Delays Trial Over $20M Allegedly Hidden From IRS
A Florida federal judge agreed Wednesday to delay the trial of a Brazilian-American businessman accused of hiding $20 million from the Internal Revenue Service by using Swiss bank accounts, but told the defendant the new deadlines are firm.
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April 17, 2024
Stormy Daniels Says Trump Flubbed Subpoena At Nightclub
Stormy Daniels, the adult film star at the center of Donald Trump's hush money case, said the former president failed to properly serve her with a subpoena seeking evidence of alleged bias last month after the man dropped the papers at her feet outside a Brooklyn nightclub.
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April 17, 2024
Loeb & Loeb Adds 2 Corporate Partners From Morrison Cohen
Loeb & Loeb LLP has announced the latest in a string of corporate hires from Morrison Cohen LLP's ranks, touting two new partners with domestic and international experience with strategic transactions.
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April 17, 2024
4th Circ. Affirms No Shield From IRS For Home In Bankruptcy
A North Carolina man who filed for bankruptcy protection and owes federal tax debt cannot shield the house he owns with his wife from the Internal Revenue Service, which is pursuing the asset as a creditor in the proceedings, the Fourth Circuit affirmed Wednesday.
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April 17, 2024
Financial Planner Gets Prison For Tax Shelter Fraud Scheme
A Cleveland financial planner who colluded with a Florida attorney to promote an illegal tax scheme using fake charitable donations to score deductions for his company's high-income clients was sentenced Tuesday to 20 months in prison for his part in the fraud.
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April 16, 2024
Corp. Transparency Act A Valid Use Of Powers, 11th Circ. Told
The U.S. Department of Treasury told the Eleventh Circuit that a federal district court erred in finding the Corporate Transparency Act unconstitutional, saying the lower court misunderstood the law's scope and relation to efforts to curb financial crime.
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April 16, 2024
Nothing 'Sinister' About Attys, Broker's Tax Plan, NC Jury Told
Two St. Louis attorneys and a North Carolina insurance agent on Tuesday tried to poke holes in an undercover IRS agent's investigation of what the government has characterized as a criminal tax avoidance scheme, which defense counsel sought to paint for the jury as a legal interpretation of federal tax law.
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April 16, 2024
Trump, Insurer Defend $175M Bond In NY AG Case
Donald Trump and the Delaware insurer that agreed to post the former president's $175 million bond in his civil business fraud case told a Manhattan judge that they have the money in cash, after New York Attorney General Letitia James questioned the sufficiency of the bond.
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April 16, 2024
DOE Aims To Wrap LNG Review By Year-End, Granholm Says
U.S. Secretary of Energy Jennifer Granholm on Tuesday said her agency hoped to complete the review of its liquefied natural gas export policy by year's end and pushed back on accusations that the current pause of export reviews is permanent.
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April 16, 2024
NC Justices Hint Contractor Qualifies For Tax Break
The North Carolina Supreme Court appeared ready to rule in favor of a contractor seeking a tax exemption reserved for manufacturers, with the justices concerned that hinging qualification on a sales percentage flouts the language of the applicable law.
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April 16, 2024
Ex-Mich. Speaker, Wife Charged With Embezzlement
Former Michigan House Speaker Lee Chatfield was charged Tuesday with criminally misusing money from his nonprofit to pay for family trips and designer clothing while in office, as the state attorney general called on lawmakers to beef up Michigan's "worthless" campaign finance laws.
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April 16, 2024
Veteran's Signature On IRS Doc Not Forged, Tax Court Finds
U.S. Air Force veteran and his wife failed to convince the U.S. Tax Court on Tuesday that their signatures were forged on an agreement to pay federal income taxes while working in Australia for defense contractor Raytheon.
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April 16, 2024
GOP Senators Call IRS' E-File Program Too Costly
Senate Republicans continued to criticize the Internal Revenue Service's free tax filing pilot program during a Finance Committee hearing Tuesday, saying the program has not followed best practices and will be costly to implement long term.
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April 16, 2024
IRS Extends Excise Tax Relief For Min. Plan Distribution
Plans that fail to make certain required minimum distributions in 2024 will not be assessed an excise tax under changes made to retirement plan legislation, the Internal Revenue Service said in guidance released Tuesday.
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April 16, 2024
McDermott Hires 2 Partners For Global Tax Practice In Paris
McDermott Will & Emery is expanding its global tax practice group with two partners in Paris who have a track record of advising on cross-border mergers and acquisitions and tax controversies before France's tax authority, the firm announced.
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April 16, 2024
Retrial For Feds' Conduct Denied In $12M Tax Fraud Case
An Atlanta man convicted of running a $12 million tax refund fraud scheme isn't entitled to a new trial even though federal prosecutors withheld evidence that the man said minimized his role in the crime, a federal judge ruled.
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April 16, 2024
BigLaw Attys Among First 7 Jurors Picked In Trump's NY Trial
Two BigLaw attorneys on Tuesday were among seven people sworn in as jurors in Donald Trump's Manhattan hush money trial, which could proceed to opening statements as soon as Monday.
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April 16, 2024
Moving Co. Execs Found Guilty In $7.7M Payroll Tax Scheme
The former president of a moving company and its head bookkeeper conspired to evade more than $7.7 million in federal payroll taxes, a New York federal jury has found.
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April 15, 2024
Tax Attys, Broker Peddled 'Financial Fantasy,' NC Jury Told
A North Carolina federal jury on Monday heard a series of secret recordings at the start of a tax fraud trial in which an insurance agent and a St. Louis attorney unwittingly pitched an undercover IRS agent on a way to decrease taxable income — or what the government characterized as a "financial fantasy."
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April 15, 2024
Ocean Agency Requires Cos. To Cover Well Razing Costs
The Bureau of Ocean Energy Management on Monday unveiled a final rule aimed at ensuring oil and gas companies, and not taxpayers, are the ones footing the bill for decommissioning offshore wells and infrastructure.
Expert Analysis
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While Risks Exist, AI Could Transform IRS Enforcement
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.
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AGs' Distaste For Food Bill May Signal Other State Issues
States' recent opposition to a proposed federal law that would block them from regulating out-of-state agricultural production could affect issues beyond this narrow debate, such as the balance of state and federal regulatory power, reproductive rights post-Dobbs, and energy production and water use, say Christopher Allen and Stephen Cobb at Cozen O'Connor.
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Strategic Succession Planning At Law Firms Is Crucial
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.
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Maximizing Law Firm Profitability In Uncertain Times
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.
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5th Circ. Ruling Reminds Attys That CBP Can Search Devices
The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.
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Enforcement Of International Tax Reporting Is Heating Up
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.
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How Gov't Agencies Will Fare In The Event Of A Shutdown
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.
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Avoiding The Ethical Pitfalls Of Crowdfunded Legal Fees
The crowdfunding of legal fees has become increasingly common, providing a new way for people to afford legal services, but attorneys who accept crowdsourced funds must remember several key ethical obligations to mitigate their risks, say Hilary Gerzhoy and Julienne Pasichow at HWG.
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4 Pharma Industry Arguments Against CMS Drug Pricing Plan
The Centers for Medicare & Medicaid Services is facing significant pushback regarding its plans for implementing the Inflation Reduction Act's Medicare drug price negotiation program, due to a number of potential repercussions for manufacturers, say attorneys at Mintz Levin.
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IRS Notice Clarifies R&E Amortization, But Questions Remain
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.
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Preparing Your Legal Department For Pillar 2 Compliance
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.
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What Large Language Models Mean For Document Review
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.
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Series
Participating In Living History Makes Me A Better Lawyer
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.
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Opinion
Private Equity Owners Can Remedy Law Firms' Agency Issues
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.
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How To Protect Atty-Client Privilege While Using Generative AI
When using generative artificial intelligence tools, attorneys should consider several safeguards to avoid breaches or complications in attorney-client privilege, say Antonious Sadek and Christopher Campbell at DLA Piper.