Federal

  • August 19, 2024

    Eaton Ordered To Give Int'l Employee Records To IRS

    Eaton Corp. must disclose employment records for some European workers in its transfer pricing dispute with the U.S. government because public interest in curtailing tax avoidance outweighs the interest in protecting the workers' privacy, an Ohio federal judge ruled Monday.

  • August 19, 2024

    Danish Gov't Wants Evidence Excluded In $2B Tax Fraud Case

    A New York federal court should exclude some evidence presented by U.S. pension plans accused in what the Danish tax agency is calling a $2.1 billion tax fraud scheme, the agency said.

  • August 19, 2024

    Spouse Asks Tax Court To Reconsider Relief Request

    A woman barred from innocent spouse relief on grounds that tax debt related to an erroneously issued refund doesn't qualify asked the U.S. Tax Court to reconsider, saying she's entitled to the break for any unpaid tax liability.

  • August 19, 2024

    IRS Issues Student Loan Matching Contribution Guidance

    The Internal Revenue Service issued guidance Monday for employers wanting to take advantage of a retirement plan overhaul that for the first time allows certain plan sponsors to provide matching contributions based on student loan payments.

  • August 19, 2024

    H&R Block's Case On In-House Judges' Role Is Paused

    A Missouri federal judge who refused to halt Federal Trade Commission proceedings accusing H&R Block of deceptive advertising agreed to pause, while the company appeals her refusal, a district court case in which the company has argued that administrative judges should be booted from the proceedings.

  • August 19, 2024

    IRS Expands Business Tax Account Program Payment Options

    The Internal Revenue Service's business tax account online self-service tool for business taxpayers will now allow taxpayers to view and make balance-due payments, the agency announced Monday, also saying the service is now available in Spanish.

  • August 19, 2024

    Treasury Floats Timing Shift For Foreign Currency Accounting

    The U.S. Treasury Department proposed regulations Monday that would adjust the timing for when companies could opt to use the so-called mark-to-market accounting method for gains or losses that arise from foreign currency transactions.

  • August 16, 2024

    Drexel Accounting Prof Convicted Of Evading Tax On $3.3M

    New Jersey federal jurors have convicted a Drexel University accounting professor on charges of tax evasion and filing false tax returns after the government accused him of failing to report $3.3 million in income from a Trenton pharmacy.

  • August 16, 2024

    Kyocera Says It Doesn't Need Records For R&D Credits

    Multinational electronics maker Kyocera said Friday that it wasn't required to keep any specific paperwork to back up its claim to research tax credits, contrary to the U.S. government's claims, according to a filing in South Carolina federal court.

  • August 16, 2024

    Harris Proposes Tax Break For Homebuilders

    Vice President Kamala Harris, the presumptive Democratic nominee for president, proposed several housing-related tax proposals, including creating a tax incentive for homebuilders that sell to first-time homebuyers, during a campaign speech Friday.

  • August 16, 2024

    Democratic Gov't Control Could Bolster US' Pillar 2 Plans

    Vice President Kamala Harris and congressional Democrats would likely double down on plans to align the U.S. tax code with the global minimum tax designed by the Organization for Economic Cooperation and Development if they win total control of the federal government in the November elections.

  • August 16, 2024

    TCJA's Estate Tax Treatment Shouldn't Change, Panel Told

    If the Tax Cuts and Jobs Act's estate tax exemption increase is allowed to lapse in 2025, many family farms in the Midwest would face tough choices, including whether to sell to large corporations, panelists told the House of Representatives' Ways and Means Committee on Friday.

  • August 16, 2024

    IRS To Let Private Cos. Into Real-Time Biz Audit Program

    The Internal Revenue Service is opening its compliance assurance process real-time audit program to privately held C corporations, including foreign-owned ones, for 2025, the agency announced.

  • August 16, 2024

    North Carolina Joins Direct File, Maine Plans To Follow

    The Internal Revenue Service's free electronic filing tax program, Direct File, will be available in North Carolina for the 2025 tax filing season, the IRS and U.S. Department of the Treasury announced Friday, and Maine is also planning to join.

  • August 16, 2024

    Ch. 7 Trustee Can't Recover Tax Payment, States Tell Justices

    A group of roughly two dozen states threw their support behind the federal government in asking the U.S. Supreme Court to overturn a ruling that forced the IRS to return a tax payment after a bankruptcy trustee argued it was a fraudulent transfer and recoverable under state law.

  • August 16, 2024

    IRS, State Agencies, Tax Industry Create Anti-Scam Task Force

    The Internal Revenue Service announced Friday that it is teaming with state tax agencies and tax industry representatives to create a task force to combat a growing number of scams and schemes targeting taxpayers.

  • August 16, 2024

    IRS Issues Corp. Bond Monthly Yield Curve For August

    The Internal Revenue Service published Friday the corporate bond monthly yield curve for August for use in calculations for defined benefit plans, as well as corresponding segment rates and other related provisions.

  • August 16, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included the final labor rules for clean energy projects seeking to significantly boost the value of their tax credits.

  • August 16, 2024

    Taxation With Representation: Cleary, Kirkland, Skadden

    In this week's Taxation with Representation, Mars Inc. sets a 2024 record with its $36 billion acquisition of Kellanova, Carlyle inks a $3.8 billion purchase with Baxter International Inc., and Performance Food Group Co. agrees to a $2.1 billion cash deal with Cheney Bros. Inc.

  • August 15, 2024

    Doctor Wants Contempt Fine Dropped In Foreign Asset Case

    A doctor who incurred $1.1 million in liabilities for failing to report his foreign bank accounts is asking a Michigan federal court to waive his $20,000 civil contempt fine because the court restricted his only financial assets to paying the liabilities.

  • August 15, 2024

    Applicable Federal Interest Rates To Drop In September

    Applicable federal rates for income tax purposes will decrease in September, the Internal Revenue Service said Thursday, the third month-to-month drop in a row.

  • August 15, 2024

    IRS Nix Of $52M Easement Deduction Invalid, Donor Says

    An Alabama partnership asked the U.S. Tax Court to reverse an Internal Revenue Service adjustment that cut its roughly $52 million deduction for its donation of a conservation easement, saying, among other things, that the IRS defied the Administrative Procedure Act.

  • August 15, 2024

    Partnership's $47M Easement Deduction Is Fraud, IRS Says

    A North Carolina partnership lied and hid details related to a fraudulent conservation easement donation for 2018, the Internal Revenue Service told the U.S. Tax Court, saying the partnership is wrong in claiming the IRS improperly slashed its almost $47 million corresponding tax deduction.

  • August 15, 2024

    Tax Pros Navigate Chaos, Rewards In Climate Law's 2nd Year

    Energy tax attorneys have been knee-deep in project finance deals for the past year since the Inflation Reduction Act of 2022 triggered a flurry of clean energy investments, but the work, they say, has been fulfilling as part of broader efforts to save the environment.

  • August 15, 2024

    IRS Reopens Improper Retention Credit Disclosure Program

    Businesses that think they improperly received COVID-era employee retention credits have another chance to apply for a voluntary disclosure program that could reduce their penalty and allow them to avoid future audits, penalties and interest, the Internal Revenue Service said Thursday.

Expert Analysis

  • Anticipating Intensified Partnership Enforcement From IRS

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    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

  • Newman Suspension Shows Need For Judicial Reform

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    The recent suspension of U.S. Circuit Judge Pauline Newman following her alleged refusal to participate in a disability inquiry reveals the need for judicial misconduct reforms to ensure that judges step down when they can no longer serve effectively, says Aliza Shatzman at The Legal Accountability Project.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

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    Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • 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.

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