Federal

  • September 19, 2024

    Death Doesn't Preclude FBAR Penalties, Judge Says

    The death of a U.S. citizen who failed to file reports of foreign bank and financial accounts doesn't stop the U.S. government from enforcing penalties against his estate, a New York federal judge ruled.

  • September 19, 2024

    Senate Tees Up Vote On Tax Court Nominee

    The U.S. Senate set the stage Thursday to proceed with a vote on one of President Joe Biden's picks to fill an open seat on the U.S. Tax Court.

  • September 19, 2024

    GAO Says IRS Can Be Better Prepped For Reporting Changes

    While the Internal Revenue Service could collect billions thanks to recent reporting requirement changes, particularly those related to cryptocurrency, the agency needs to take further steps to be prepared for the changes, the Government Accountability Office said Thursday.

  • September 19, 2024

    H&R Block Again Asks 8th Circ. To Remove ALJs In Ad Suit

    H&R Block asked the Eighth Circuit to reconsider its denial of the company's request to stop administrative law judges from presiding over its coming false-advertising hearing before the Federal Trade Commission, saying the court's one-sentence ruling lacked any explanation despite the significant constitutional issues involved.

  • September 19, 2024

    IRS Warns Taxpayers Of Offer-In-Compromise 'Mills'

    The IRS urged taxpayers to be careful about working with promoters that claim to provide necessary services in order to comply with the agency's offer-in-compromise program, saying Thursday that these "mills" only bring "empty promises and steep costs."

  • September 18, 2024

    Tax Chiefs Eye Crypto Payment Cos., OTC Traders, IRS Says

    Tax investigators in the U.S., U.K., Canada, Australia and the Netherlands are preparing guidance on red flags for cryptocurrency payment providers and over-the-counter trading desks following a joint operation this week, a special agent with the Internal Revenue Service said Wednesday.

  • September 18, 2024

    IRS Publishes Guidance For Issuers Of Tax-Exempt Bonds

    The Internal Revenue Service published guidance Wednesday for issuers of tax-exempt and other tax-advantaged bonds in terms of procedures for filing claims for recovery of overpayments of rebate payments and other processes.

  • September 18, 2024

    Dems Block Bill Targeting Foreign Funding Of Campaign Gifts

    Democrats blocked the House of Representatives from sending legislation to the Senate that would restrict contributions to political committees by tax-exempt entities that receive foreign funds.

  • September 18, 2024

    Tax Court Wrongly Denied Premium Deduction, 5th Circ. Told

    A Texas couple asked the Fifth Circuit on Wednesday to reverse a U.S. Tax Court decision denying their bid to deduct more than $1 million in premiums paid to insurance companies they owned, arguing the Tax Court misclassified underlying insurance arrangements.

  • September 18, 2024

    IRS On Track With Updated Tool, But Some Risk Remains

    While the IRS' project modernizing its individual tax processing engine met its performance goals ahead of the updated system's planned 2025 rollout, the ending of a process for solving issues between the new and old systems creates greater risk, the Treasury Inspector General for Tax Administration said Wednesday.

  • September 18, 2024

    Jury Finds Eatery Owner Guilty Of COVID Fraud, Tax Crimes

    A San Diego restaurant owner who worked with food delivery services during the pandemic and saw his business improve was convicted by a California federal jury of tax crimes and lying on loan applications to obtain more than $1.7 million in COVID-19 funds meant for struggling businesses.

  • September 18, 2024

    House GOP Vows Blowback Over OECD's Min. Tax Backstop

    House Republicans again warned the OECD that Congress will retaliate against countries that implement a backstop measure to the 15% global minimum tax, saying China will cheat the system and it will cost U.S. taxpayers about $120 billion.

  • September 18, 2024

    Tips Lead To $263M IRS Settlement In Offshore Evasion Case

    Tips from three whistleblowers have led to the IRS reaching a $263 million settlement with a taxpayer in an offshore tax evasion case, concluding one of the largest-ever tax whistleblower cases, a law firm involved in the case said Wednesday.

  • September 18, 2024

    IRS Delays Deadlines For Pa. Victims Of Tropical Storm

    Taxpayers in four Pennsylvania counties will have until Feb. 3, 2025, to file individual and business tax returns and make payments after portions of the state were hit by Tropical Storm Debby, the Internal Revenue Service said Wednesday.

  • September 18, 2024

    Treasury Floats Tax Credit Regs For EV Charging Property

    The U.S. Treasury Department proposed regulations Wednesday to define which electric vehicle charging ports, hydrogen fueling stations and other infrastructure that businesses, people and tax-exempt entities can build in underserved communities to qualify for a tax credit of up to 30% of installation costs.

  • September 18, 2024

    Sidley Can't Escape Malpractice Suit In Ga. Over Tax Scheme

    A Georgia federal judge has found that Sidley Austin LLP must face its former clients' legal malpractice claims alleging they participated in a tax scheme under the firm's guidance, but threw out indemnity claims seeking reimbursement for paying the IRS $7 million over the scheme.

  • September 18, 2024

    Latham Adds A&O Shearman Energy Group Co-Lead In DC

    Latham & Watkins LLP has hired the former co-head of Allen Overy Shearman Sterling's U.S. energy, natural resources and infrastructure group to its team of transactional tax partners based in Washington, D.C., the firm announced Monday.

  • September 18, 2024

    Staffing Co. Owed $5M In Worker Retention Credits, Suit Says

    An industrial staffing company that was forced to stop holding job fairs during the pandemic claims the IRS hasn't paid it $5.1 million in federal tax credits it's owed for having continued paying employees, according to a complaint in Ohio federal court.

  • September 18, 2024

    8th Circ. Considers Chevron's End In 3M's $24M Tax Case

    The Eighth Circuit signaled it would consider an argument by 3M that the U.S. Supreme Court's overturning of Chevron deference warranted a reversal in a transfer pricing case in which 3M is challenging the IRS' reallocation of $24 million from a Brazilian affiliate.

  • September 18, 2024

    IRS Issues Corp. Bond Monthly Yield Curve For Sept.

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

  • September 17, 2024

    Revocation Of Interests In QTIP Trust Was Gift, Tax Court Says

    An agreement in which two children gave up their interests in a qualified terminable interest property trust that held the remainder of their mother's nearly $60 million estate resulted in a taxable gift to the children's father, the U.S. Tax Court said Tuesday.

  • September 17, 2024

    Tax Court Denies Mineral Co.'s $1.1M Microcaptive Deduction

    A mineral rights leasing company set up by an Oklahoma oil businessman can't take a $1.1 million deduction for what was presented as a microcaptive insurance transaction, the U.S. Tax Court ruled, saying the transaction was not a legitimate insurance arrangement.

  • September 17, 2024

    Chrisley Sentence Should Stick Despite 11th Circ., Feds Argue

    Julie Chrisley's prison sentence shouldn't change even as a Georgia federal judge considers the former reality TV star's smaller role in a $36 million tax evasion and fraud scheme, prosecutors told the court Monday, noting that her time has already been shortened for other considerations.

  • September 17, 2024

    Duane Morris Atty Asks Court To Keep Proposed Class Alive

    A Duane Morris LLP attorney asked a California federal court to keep her proposed class action against the firm alive, alleging the BigLaw firm is mischaracterizing her claims that it underpaid and misclassified employees.

  • September 17, 2024

    Blumenauer Pushes House Speaker To Put Pot Bill To Vote

    U.S. Rep. Earl Blumenauer, D-Ore., on Monday urged House Speaker Mike Johnson to bring bipartisan cannabis legislation to a vote following revelations that Richard Nixon admitted privately that marijuana was "not particularly dangerous" while he publicly waged the war on drugs.

Expert Analysis

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Liability Exposure For Unpaid Payroll Taxes May Surprise You

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    The Ninth Circuit’s recent decision in Richard W. York v. U.S. offers important lessons for business owners and others who may be responsible for a company's checkbook about how someone else's failure to submit payroll taxes can result in their personal liability, says Douglas Charnas at McGlinchey Stafford.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

  • Finding Focus: Strategies For Attorneys With ADHD

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    Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.

  • Unlocking Value In Carve-Out M&A Transactions

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    Some of the largest mergers and acquisitions in 2023 were carve-out transactions, and despite their unique intricacies and challenges, these transactions offer both buyers and sellers the opportunity to generate outsized returns in an otherwise vigorously competitive landscape, when carefully planned and diligently executed, say Kevin Crews and Rami Totari at Kirkland.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

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    After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.

  • Tips For Litigating Against Pro Se Parties In Complex Disputes

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    Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.

  • 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.

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