Federal
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January 17, 2025
Par Funding's Fraud Caused $288M In Losses, Pa. Judge Says
Par Funding caused $288 million in losses stemming from a scheme to defraud investors who poured money into its cash advance business, a Pennsylvania federal judge said Friday, days after holding an evidentiary hearing where the government and the defendants sparred over dueling loss amounts.
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January 17, 2025
Feds Say Pa. Investment Adviser Stole $20M From Clients
A Pennsylvania investment adviser's alleged misappropriation of more than $20 million worth of client funds has landed him criminal charges and civil enforcement action from U.S. Securities and Exchange Commission.
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January 17, 2025
Bill Aims To Extend Biogas Investment Credit Through 2025
A bill in the U.S. House of Representatives would extend the clean energy investment tax credit available for certain biogas facilities' equipment through the end of 2025 instead of at the end of 2024, the bill's sponsors said Friday.
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January 17, 2025
11th Circ. Urged To Reject Biz Owners' Tax Penalty Challenge
The owners of an electronic parts company who asked the Eleventh Circuit to reverse a tax penalty and find that Tax Court judges have unconstitutional job protections failed to link the two and are not entitled to tax relief, the U.S. government said Friday.
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January 17, 2025
LA Crypto 'Godfather' Admits To $36M Meta Hacking Fraud
A Los Angeles-based cryptocurrency founder who called himself "The Godfather" will plead guilty to earning $36 million through the sale of hacked Meta Platforms advertising accounts and evading taxes on the fraudulent profits, according to federal court documents unsealed Friday,
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January 17, 2025
IRS Rewrites Residential Green Energy Credit FAQ
The Internal Revenue Service made substantial changes Friday to its fact sheet for the energy efficient home improvement and residential clean energy property tax credits.
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January 17, 2025
Meet The Key Players In Tom Goldstein's Tax-Crimes Case
The tax-evasion indictment of U.S. Supreme Court expert lawyer and SCOTUSblog publisher Tom Goldstein features an eclectic cast of characters linked to his purported side career as a high-stakes poker player, including law firm partners, professional gamblers, a Texas billionaire, a movie producer and an actor.
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January 17, 2025
Taxation With Representation: Simpson Thacher, Covington
In this week's Taxation With Representation, Eli Lilly and Co. buys a precision breast cancer program, Applied Digital Corp. enters a financing agreement for its high-performance computing business, Clearwater Analytics buys Enfusion, and Lantheus Holdings Inc. buys Life Molecular Imaging Ltd.
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January 17, 2025
Ex-Pol's Atty Chided For Early Morning Sentencing Memo
The lawyer for a former Massachusetts state senator convicted of tax and pandemic aid fraud was scolded by a federal judge on Friday for filing a sentencing memo at 3:30 a.m. on the day of the hearing, then showing up late to court, forcing a postponement.
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January 17, 2025
Co. Suggests 4 Chemicals For Taxable Substances List
The Internal Revenue Service is seeking comments on proposals from Occidental Chemical Corp. to add four chemicals to the Internal Revenue Code's list of taxable substances, the agency said Friday.
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January 17, 2025
IRS Commissioner To Step Down As Trump Takes Office
Internal Revenue Commissioner Daniel Werfel is stepping down from his position in light of President-elect Donald Trump's intent to nominate former Rep. Billy Long to replace him, Werfel said in a message to the agency's employees Friday.
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January 17, 2025
Vanguard To Pay SEC, States $106M Over Surprise Tax Bills
The U.S. Securities and Exchange Commission was joined by dozens of state regulators Friday in announcing a $106.4 million settlement with The Vanguard Group Inc. over claims that the company misled investors about the heightened capital gains taxes they would have to pay on certain retirement savings accounts.
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January 17, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included revised rules for companies that file consolidated federal income tax returns to modernize previous rules' terminology, including removing gender-specific pronouns.
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January 16, 2025
Tax Court Denies Late Pass For Identity Theft
A California couple cannot challenge an Internal Revenue Service decision to levy their state tax refund because they missed the deadline for filing a petition by four years, the U.S. Tax Court said Thursday, rejecting their request for an extension for dealing with identity theft.
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January 16, 2025
DOJ Tax Chief Touts Winning Court Record On Appeals
The U.S. Department of Justice's Tax Division won an overwhelming majority of appeals in tax cases last year by prioritizing strong legal arguments in disputes that had the potential to significantly affect federal tax administration, the head of the division said Thursday.
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January 16, 2025
Tax Court Rejects Explanation For Unreported Wages
A woman owes taxes on nearly $19,000 of unreported income she said she reported on a gift tax return, the U.S. Tax Court ruled Thursday, rejecting her argument that wages reported as gifts would not incur taxes.
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January 16, 2025
Tax Court Tosses Some Of Ind. Couple's Deduction Claims
The U.S. Tax Court had mixed responses Thursday related to an Indiana couple's claimed business deductions tied to a rental property as well as itemized deductions related to the husband's work as an electrician, allowing some while saying others weren't properly substantiated.
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January 16, 2025
IRS Explains Changing Elective Payment Accounting Periods
The IRS provided procedures Thursday for certain entities — including Native American tribes and state governments — that aren't required to file federal income tax returns but have chosen to make elective payments and want to change their taxable years to match their accounting periods.
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January 16, 2025
AmEx Inks $230M Deal Over DOJ, Fed Small Biz Sales Claims
American Express has signed a nonprosecution agreement and said Thursday it will pay about $230 million to end investigations by the Department of Justice and the Federal Reserve into the financial services company's previous sales practices for some small business customers in the U.S.
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January 16, 2025
Tax Court's 90-Day Deadline Is Not Fixed, 6th Circ. Told
A woman who missed the 90-day deadline for challenging her liabilities in the U.S. Tax Court told the Sixth Circuit on Thursday that the Internal Revenue Service has wrongly argued that case law proves the deadline is set in stone.
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January 16, 2025
SCOTUSblog Publisher Tom Goldstein Indicted In Tax Case
Tom Goldstein, a publisher of SCOTUSblog and one of the most experienced U.S. Supreme Court lawyers in the country, was indicted Thursday in Maryland federal court on charges he schemed to evade paying taxes for years and used funds from his boutique law firm to cover gambling debts.
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January 16, 2025
OECD To Release List Of Abusive Transactions Under Pillar 2
The Organization for Economic Cooperation and Development is putting together a list of intercompany transactions that may raise red flags as attempts to undermine an international minimum tax agreement known as Pillar Two, an OECD official said Thursday.
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January 16, 2025
Morrison Foerster Adds Tax Group Co-Chair From Jones Day
Morrison Foerster LLP announced it has added a partner from Jones Day to serve as co-chair of the firm's global tax group in its New York office.
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January 16, 2025
Atty Gets 5-Year NJ Suspension After Tax Fraud Conviction
A Philadelphia-based personal injury attorney convicted for not paying income tax on more than $8 million in revenue he earned and for failing to pay almost $60,000 in payroll taxes received a five-year suspension from New Jersey's Supreme Court but will keep his law license in the state.
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January 16, 2025
IRS Corrects Simplified Foreign Currency Rules
The Internal Revenue Service issued corrections Thursday to finalized regulations that aim to simplify aspects of how corporations determine taxable income or loss with respect to certain affiliates that conduct business in a foreign currency.
US Guidance On Amount B Carries Potential For Disputes
Recent IRS guidance on a simplified and streamlined transfer pricing method for certain cross-border transactions, known as Amount B, suggests rulemakers want feedback on how it would work if it were made mandatory, but that approach could lead to controversy without global cooperation.
Trump's Treasury Pick Calls For Permanently Extending TCJA
Congress must permanently extend the Tax Cuts and Jobs Act provisions set to expire this year to prevent the largest tax increase in history, Scott Bessent, President-elect Donald Trump's pick for Treasury secretary, told the Senate Finance Committee on Thursday.
IRS Mulling Widened Early Application Of Offshore Profit Regs
The Internal Revenue Service is considering expanding the early application option for proposed regulations designed to help U.S. multinational corporations properly account for previously taxed earnings and profits, an agency official said Wednesday.
Featured Stories
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US Guidance On Amount B Carries Potential For Disputes
Recent IRS guidance on a simplified and streamlined transfer pricing method for certain cross-border transactions, known as Amount B, suggests rulemakers want feedback on how it would work if it were made mandatory, but that approach could lead to controversy without global cooperation.
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Meet The Key Players In Tom Goldstein's Tax-Crimes Case
The tax-evasion indictment of U.S. Supreme Court expert lawyer and SCOTUSblog publisher Tom Goldstein features an eclectic cast of characters linked to his purported side career as a high-stakes poker player, including law firm partners, professional gamblers, a Texas billionaire, a movie producer and an actor.
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The Tax Angle: GOP Lawmakers Grapple With TCJA Renewal
From a look at Congress setting parameters for consideration of legislation to renew the GOP's 2017 tax overhaul law to other upcoming tax action in the House and Senate, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
Expert Analysis
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Rethinking Litigation Risk And What It Really Means To Win
Attorneys have a tendency to overestimate litigation risk before summary judgment and underestimate risk after it, but an eight-stage litigation framework can clarify risk at different points and help litigators reassess what true success looks like in any particular case, says Joshua Libling at Arcadia Finance.
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Small Biz Caught In Corporate Transparency Act Crossfire
Despite compliance being put on hold due to a nationwide preliminary injunction, small businesses have been caught in the middle of the legal battle over the Corporate Transparency Act — and confusion over the law's requirements could result in major penalties, say attorneys at Snell & Wilmer.
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No, Litigation Funders Are Not 'Fleeing' The District Of Del.
A recent study claimed that litigation funders have “fled” Delaware federal court due to a standing order requiring disclosure of third-party financing, but responsible funders have no problem litigating in this jurisdiction, and many other factors could explain the decline in filings, say Will Freeman and Sarah Tsou at Omni Bridgeway.
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Hydrogen Regs Will Provide More Certainty — If They Survive
Newly finalized regulations implementing the Section 45V clean hydrogen tax credit allow producers more flexibility, and should therefore help put the industry on more solid footing — but the incoming Trump administration and Republican Congress will have multiple options for overturning or altering the regulations, say attorneys at Steptoe.
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5 E-Discovery Predictions For 2025 And Beyond
In the year to come, e-discovery will be shaped by new and emerging trends, from the adoption of artificial intelligence provisions in protective orders, to the proliferation of emojis as a source of evidence in contemporary litigation, say attorneys at Littler.
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What's Ahead As Transparency Act Comes To A Crossroads
Synthesizing the contrasting federal district and appellate court rulings on the Corporate Transparency Act’s validity reveals several main areas of debate that will likely remain at issue as challenges to the law continue winding through the courts, say attorneys at Farella Braun.
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Final Hydrogen Tax Credit Regs Add Flexibility For Producers
The recently released final regulations implementing the Inflation Reduction Act's clean hydrogen production tax credit offer taxpayers greater flexibility, reducing risk and creating more certainty for investments in the industry, thus diminishing — but not eliminating — the risk of legal challenges to the regulations, say attorneys at Steptoe.
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5 Evolving Concerns For Family Offices In 2025
Complex regulatory changes and emerging operational risks will force family offices to stay on their toes in 2025, with timely action particularly necessary to address several tax and reporting developments that may affect their investments and business operations, say attorneys at Morgan Lewis.
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7 Ways 2nd Trump Administration May Affect Partner Hiring
President-elect Donald Trump's return to the White House will likely have a number of downstream effects on partner hiring in the legal industry, from accelerated hiring timelines to increased vetting of prospective employees, say recruiters at Macrae.
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E-Discovery Quarterly: Rulings On Custodian Selection
Several recent rulings make clear that the proportionality of additional proposed custodians will depend on whether the custodians have unique relevant documents, and producing parties should consider whether information already in the record will show that they have relevant documents that otherwise might not be produced, say attorneys at Sidley.
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A Look At PCAOB's Record-Breaking Enforcement In 2024
The Public Company Accounting Oversight Board in 2024 brought more enforcement actions against auditors and imposed increasingly higher monetary penalties, showing that it was not afraid to exercise its power to fine and reprimand firms, a trend that will likely continue in 2025, say attorneys at Briglia Hundley.
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Exploring Venue Strategy For Trump-Era Regulatory Litigation
Litigation will likely play a prominent role in shaping policy outcomes during the second Trump administration, and stakeholders have several tools at their disposal to steer regulatory litigation toward more favorable venues, say attorneys at Covington.
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An Associate's Guide To Career Development In 2025
As the new year begins, associates at all levels should consider establishing career metrics, fostering key relationships and employing other specific strategies to help move through the complexities of the legal profession with confidence and emerge as trailblazers, say EJ Stern and Amanda George at Fractional Law Firm.