Federal
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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.
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August 26, 2024
Netflix Can't Shut Off 'Varsity Blues' Defamation Suit
A private equity executive who largely beat charges in the "Varsity Blues" college admissions case can proceed with a suit against Netflix claiming he and his son were defamed by the streaming giant's documentary about the scandal, a Massachusetts judge has ruled.
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August 26, 2024
Feds Want Prison For Ex-Atlanta CFO Who Stole City Funds
The former chief financial officer for the city of Atlanta who admitted to stealing city money and obstructing an IRS audit should spend at least about three years in prison, federal prosecutors argued ahead of his sentencing, saying he has been uncooperative since pleading guilty.
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August 23, 2024
Wash. Justices Affirm Convicted Ex-State Auditor Disbarment
The Washington Supreme Court affirmed a recommendation to disbar convicted former state auditor Troy X. Kelley after he was imprisoned on felony theft charges, finding that Kelley's crimes justified the disbarment sanction.
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August 23, 2024
Chamber Backs Doctor In Tax Court Economic Substance Suit
The U.S. Chamber of Commerce lent its support to an eye doctor and his wife's U.S. Tax Court case disputing accuracy-related penalties that the Internal Revenue Service plans to impose on their microcaptive insurance arrangements for lacking economic substance.
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August 23, 2024
Intended Financial Harm Counts In Sentencing, 4th Circ. Says
A split Fourth Circuit panel on Friday upheld a South Carolina woman's 30-month sentence for filing false tax returns and making false statements on applications for Paycheck Protection Program loans, finding that a sentencing range can be calculated using the total amount of intended financial harm.
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August 23, 2024
IRS Spinoff Guidance Sparks Worries About Short-Term Debt
Companies that intend to give creditors equity tied to a spinoff transaction won't get early tax-free approval if the exchange involves recently acquired debt under IRS guidance that practitioners say draws an arbitrary line without accounting for ordinary business operations.
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August 23, 2024
Alvarez & Marsal Adds Transfer Pricing Expert From EY
A former EY partner joined Alvarez & Marsal LLC to serve as managing director of its transfer pricing line of services in its New York office, the firm announced.
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August 23, 2024
Crypto Exec To Appeal IRS Bank Summons Ruling
A cryptocurrency executive charged in a 2020 bitcoin fraud investigation told a Texas federal court that he will appeal a decision this month that granted the Internal Revenue Service's request to review his and his company's sequestered bank records.
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August 23, 2024
US Trying Illegal Property Grab For Dad's Tax Debt, Son Says
The son of a man serving a 22-year fraud sentence told a Georgia federal court that the federal government is violating his constitutional rights in trying to take his property to satisfy his parents' tax debts, saying he had nothing to do with his father's crimes.
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August 23, 2024
Tax Deadlines In South Dakota Delayed After Storms
Taxpayers in South Dakota will be given until Feb. 3 to file individual and business tax returns and make payments after areas of the state were hit by severe storms, straight-line winds and flooding in June, the Internal Revenue Service said Friday.
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August 23, 2024
Utah Plumbing Supply Co.'s Microcaptive Suit Tossed
A Utah federal judge dismissed Friday a plumbing supply company and its owners' bid to set aside the IRS' 2016 notice that imposed additional reporting requirements for certain microcaptive insurance arrangements under the threat of penalty, saying the court lacks jurisdiction to do so.
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August 23, 2024
Gov't Too Late In $2.3M Estate Tax Suit, Court Rules
The U.S. government waited too long to pursue more than $2.3 million in estate taxes from a Florida man accused of using his late mother's estate's funds to pay mortgage payments instead of taxes, a federal court ruled.
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August 23, 2024
IRS Delays Tax Deadlines In Puerto Rico After Tropical Storm
Taxpayers in Puerto Rico will be given until Feb. 3 to file individual and business tax returns and make payments after the island was hit by Tropical Storm Ernesto, the Internal Revenue Service said Friday.
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August 23, 2024
Business Or Home? The $1M Question, Judge Says
A family-run company that spent $7.3 million on a house overlooking San Francisco Bay may have used it for business and so the family's trust could be entitled to a $1 million tax refund for related operating losses, a Florida federal judge said.
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August 23, 2024
DC Eyes Joining IRS Direct File For 2026, Revenue Rep Says
The District of Columbia is considering joining the Internal Revenue Service's free electronic tax filing program, Direct File, in 2026, a representative of the district's tax agency said Friday.
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August 23, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included proposed regulations that outline when foreign taxes under the Pillar Two international minimum tax agreement could trigger long-standing U.S. rules that aim to prevent companies from what is known as double-dipping the same economic loss.
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August 23, 2024
Taxation With Representation: Latham, Wachtell, Paul Weiss
In this week's Taxation With Representation, Arch Resources merges with Consol Energy in a deal worth $5.2 billion, Advanced Micro Devices agrees to purchase ZT Systems for $4.9 billion, and Japanese tobacco company JT Group inks a deal to buy Vector Group for $2.4 billion.
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August 22, 2024
5th Circ. Says No Tolling For COVID, Trims Atty's Conviction
The Fifth Circuit on Thursday knocked a false statement charge off Houston attorney Richard Plezia's conviction for his involvement in a multimillion-dollar ambulance-chasing kickback scheme but upheld the rest of his conviction, including conspiracy to defraud the U.S. by helping another lawyer evade federal income taxes.
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August 22, 2024
Justices Disfavor External Consistency Test, Mass. Atty Says
The U.S. Supreme Court likely will decline to hear a construction company's argument that South Dakota's refusal to apportion use tax on its equipment was unconstitutional, a Massachusetts tax agency attorney predicted Thursday, saying the justices have no appetite for applying the external consistency test anymore.
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August 22, 2024
NC Hot Rod Shop Owner Admits To Not Paying $2M In Taxes
A North Carolina automotive business owner has pled guilty to failing to pay more than $2 million in employment taxes and not filing employment tax returns, the U.S. Department of Justice announced Thursday.
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August 22, 2024
Tax Co. Owner Didn't Fraudulently Fail To File, Tax Court Says
An owner of financial and tax services companies who earned about $1 million annually and failed to file returns for four years doesn't have to pay a roughly $1.2 million fraud penalty assessed by the Internal Revenue Service, the U.S. Tax Court ruled Thursday.
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August 22, 2024
Tax Court OKs IRS Rejection Of Tax Liability Compromise
An Internal Revenue Service settlement officer didn't abuse her discretion when she decided to reject an offer from a Maryland couple to settle their more than $103,000 in outstanding tax debts by paying just over $1,800, the Tax Court said Thursday.
Expert Analysis
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A Look Ahead For The Electric Vehicle Charging Industry
This will likely be an eventful year for the electric vehicle market as government efforts to accelerate their adoption inevitably clash with backlash from supporters of the petroleum industry, say Rue Phillips at SkillFusion and Enid Joffe at Green Paradigm Consulting.
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A Post-Mortem Analysis Of Stroock's Demise
After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.
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SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
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Planning A Defense As IRS Kicks Off Sports Losses Campaign
Sports team owners and partnerships face potential examination under the Internal Revenue Service’s recently announced sports industry losses campaign, and should be preparing to explain what drove their reported losses and assembling documentation to support their tax return positions and accounting methods, say Sheri Dillon and Jennifer Breen at Morgan Lewis.
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What New Calif. Strike Force Means For White Collar Crimes
The recently announced Central District of California strike force targeting complex corporate and securities fraud — following the Northern District of California's model — combines experienced prosecutorial leadership and partnerships with federal agencies like the IRS and FBI, and could result in an uptick in the number of cases and speed of proceedings, say attorneys at MoFo.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.
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As Promised, IRS Is Coming For Crypto Tax Evaders
The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.
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5 Reasons Associates Shouldn't Take A Job Just For Money
As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.
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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.