Federal
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August 28, 2024
IRS Corrects Proposed Foreign Currency Accounting Regs
The Internal Revenue Service issued corrections Wednesday to proposed rules that would adjust the timing for when companies could opt to use what is known as the mark-to-market accounting method for gains or losses that arise from foreign currency transactions.
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August 28, 2024
NY Firm Calls Gas Co.'s Contract And Fee Claims Duplicative
Albany, New York-based Whiteman Osterman & Hanna LLP has moved to trim breach of contract and disgorgement of fees claims brought by a former client over allegedly bungled tax advice, telling a New York federal judge the claims are redundant when the ex-client is also pursuing a legal malpractice cause of action.
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August 28, 2024
Atlanta's Ex-CFO Gets 3 Years For 'Triple-Dipping' In Coffers
Atlanta's former chief financial officer became the latest city hall official to head to prison on corruption charges Tuesday, after getting hit with a three-year prison sentence for what prosecutors called a "triple-dipping" scheme into city coffers to pay for swanky vacations and illegal firearms.
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August 28, 2024
Jury Justified In Dismissing $2.2M FBAR Case, Court Rules
A financial adviser will not face a new trial after an Arizona federal court ruled there was sufficient evidence for a jury to clear him in January of failing to report foreign bank accounts, sparing him at least $2.2 million in penalties.
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August 28, 2024
Sysco, IRS Asked To Address Varian's Foreign Dividend Win
The U.S. Tax Court asked food services giant Sysco and the IRS to address how a tax dispute between them is affected by a recent ruling in a similar case that found medical device company Varian can claim a deduction for foreign dividends.
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August 28, 2024
Farm Co. Defends Switch To Amortization In 8th Circ. Tax Fight
An Arkansas company that leases land eligible for government farm subsidies was entitled to start amortizing the acres for better tax treatment without notifying the IRS, the company told the Eighth Circuit, asking the court to overturn a decision denying its related deductions for 2013 and 2014.
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August 28, 2024
Treasury To Require Reports On All-Cash Real Estate Deals
Anyone who transfers real estate to a legal entity in an all-cash transaction, including attorneys, will be required starting Dec. 1, 2025, to inform the U.S. Treasury Department about that entity's beneficial owners and their identification numbers under a final rule issued Wednesday.
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August 28, 2024
Greenberg Traurig Builds PE Team With Kirkland Hires
Greenberg Traurig LLP has brought on two fund formation partners from Kirkland & Ellis LLP to continue its growth into the private equity space, according to an announcement this week by the firm.
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August 28, 2024
IRS Art Advisory Panel To Discuss Appraisals In Sept.
The Internal Revenue Service's Art Advisory Panel will meet next month to discuss fair market appraisals of pieces of art for tax purposes, the agency said Wednesday.
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August 28, 2024
Virgin Islands Tax Deadlines Delayed After Tropical Storm
Taxpayers in the U.S. Virgin Islands will be given until Feb. 3 to file individual and business tax returns and make payments after the area was hit by Tropical Storm Ernesto this month, the Internal Revenue Service said Wednesday.
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August 28, 2024
Atty Can't Escape Danish Tax Agency's $2.1B Tax Fraud Suit
An attorney in a $2.1 billion tax fraud case brought by the Danish tax authority cannot argue that a suit filed against him as an individual should be dismissed because it was filed late, a New York federal court ruled.
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August 27, 2024
Gov't Says Doctor Can't Escape Contempt Fine In FBAR Case
A doctor challenging his $20,000 civil contempt fine for failing to follow a court order to repatriate money from his foreign bank account to cover $1.1 million in tax liabilities shouldn't be allowed to escape the penalty, the U.S. government argued Tuesday.
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August 27, 2024
TIGTA Flags Due Process Issues In IRS' Lien Practices
The Treasury Inspector General for Tax Administration found that the Internal Revenue Service had numerous issues that affected due process for taxpayers whom it filed lien notices against, according to a report published Tuesday.
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August 27, 2024
Treasury Asked To Scrap Stock Buyback Tax's Funding Rule
Business groups urged the U.S. Treasury Department on Tuesday to remove what's known as the funding rule in forthcoming final regulations on the stock buyback tax, saying the provision would go beyond Congress' intentions for the levy, which aims to deter companies from giving outsize rewards to shareholders.
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August 27, 2024
TIGTA Calls For Better Guarding Of Shared Tax Info
The Treasury Inspector General for Tax Administration identified ways Tuesday it said the Internal Revenue Service should work with state agencies to improve the handling of federal tax information it shares with them, including nudging them to file required security reports.
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August 27, 2024
Candidates' Plans To End Tip Taxes Spark Fairness Concerns
The Democratic and Republican presidential nominees have both proposed eliminating taxes on tips for restaurant and hospitality workers, but tax experts say such a policy would unfairly pick winners and losers among workers and its benefits would be unevenly spread.
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August 27, 2024
Gov't Urged To Stem Abuse Of Carbon Capture Credits
The federal government should take measures to stop the abuse of tax credits for carbon capture and storage, more than 100 environmental groups told the U.S. Treasury Department and the Environmental Protection Agency in a letter released Tuesday.
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August 27, 2024
Biz Owner Gets 22 Months For Keeping $2.5M In Payroll Tax
A man who ran construction companies was sentenced to nearly two years in prison and ordered to pay about $2.5 million in restitution to the federal government after admitting he didn't pay employment taxes, the U.S. Attorney's Office for the Northern District of Georgia said Tuesday.
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August 27, 2024
Ex-Trooper Asks To Delay Prison In OT Scam Amid Appeal
A former Massachusetts state trooper asked to stay his five-year prison sentence for stealing overtime pay, lying on his taxes and cheating to get student aid for his son — a request prosecutors said was "yet another attempt to delay justice in this case."
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August 27, 2024
Maine Joining IRS' Free E-File Program In 2025
The Internal Revenue Service's free electronic tax filing program, Direct File, will be available in Maine for the 2025 tax filing season, the IRS and U.S. Treasury Department announced Tuesday.
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August 26, 2024
Ex-Braves Tell 11th Circ. Easement Appeal Not Premature
A partnership created by former Atlanta Braves players urged the Eleventh Circuit to review its $47 million conservation easement lawsuit, saying the IRS' motion to dismiss the appeal for premature filing was a mere attempt to sow confusion in the proceedings.
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August 26, 2024
Varian Entitled To Foreign Dividend Break, Tax Court Says
California-based medical device company Varian Medical Systems is entitled to a deduction for dividends received from its foreign subsidiaries, the U.S. Tax Court ruled Monday in a unanimous opinion.
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August 26, 2024
US Should Extend Expiring TCJA Tax Cuts, Chamber Says
The expiration of the 2017 Tax Cuts and Jobs Act in 2025 gives the next Congress an opportunity to pass pro-growth tax policies, the U.S. Chamber of Commerce said Monday.
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August 26, 2024
Kyocera's Gross-Up Doesn't Grant $143M Tax Break, US Says
Electronics maker Kyocera cannot be allowed to take a $143 million tax deduction for distributions received under a 2017 tax law based on a separate statute's gross-up for paid foreign tax credits, the government told a South Carolina federal court.
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August 26, 2024
10th Circ. Won't Rethink Toss Of Insurers' $2M Tax Appeal
Captive insurance companies that claim the U.S. Tax Court improperly rejected their request to invalidate tax deficiency notices in their case challenging $2 million in liabilities must wait until the court issues a final decision before they can appeal, the Tenth Circuit reaffirmed.
Expert Analysis
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.
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Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules
Regulations recently proposed by the IRS and the U.S. Department of the Treasury concerning two types of tax credits for clean hydrogen production facilities should resolve many of the most pressing questions around qualification for the credits — albeit in a relatively stringent manner, say attorneys at Morgan Lewis.
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Employee Experience Strategy Can Boost Law Firm Success
Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.
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6 Practice Pointers For Pro Bono Immigration Practice
An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.
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Lessons From Country Singer's Personal Service Saga
Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.
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7 E-Discovery Predictions For 2024 And Beyond
The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.
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5 Litigation Funding Trends To Note In 2024
Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.
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Tech CEO Tax Ruling A Warning For Forward Contracts
In McKelvey v. Commissioner, the U.S. Tax Court decided that deceased Monster.com founder Andrew McKelvey terminated his underlying obligations when he extended variable prepaid forward contracts, demonstrating why startup founders, early employees and investors should think carefully before amending derivative agreements, say Daren Shaver and Trent Tanzi at Hanson Bridgett.
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4 Legal Ethics Considerations For The New Year
As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.
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What The Law Firm Of The Future Will Look Like
As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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4 PR Pointers When Your Case Is In The News
Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.
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Unpacking The Proposed Production Tax Credit Regulations
Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.
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10 Considerations For Litigating A New York Tax Case
While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.