Federal
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December 16, 2024
Tax Court Says Couple Must Recalculate $36M Loss Claims
An Illinois couple must recalculate the more than $36 million in net operating loss carryforward deductions they claimed in 2008 and 2009, the U.S. Tax Court said Monday, siding with the Internal Revenue Service's determination that they had improperly included a number of losses.
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December 16, 2024
Tax Court Wrongly Cut Easement Deduction, 11th Circ. Told
The U.S. Tax Court erred in drastically reducing a partnership's claimed $23 million deduction for donating a conservation easement in Georgia, the partnership told the Eleventh Circuit, saying the court improperly relied on a real estate expert's opinion to establish whether the land had mining value.
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December 16, 2024
Cos. Urge Judge To Maintain Injunction On Transparency Law
A Texas federal judge doesn't need to stay his preliminary injunction on the rollout of new corporate transparency rules while the U.S. government's appeal of his decision is pending at the Fifth Circuit, a business lobbying group and others said Monday.
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December 16, 2024
Wyden Bill Would Nix Tax Perks For Private Placement Plans
U.S. Senate Finance Committee Chairman Ron Wyden unveiled legislation Monday that would remove the tax benefits of a special type of private life insurance plan that he said high-net-worth individuals have been abusing to avoid paying taxes on their investments in the policies.
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December 16, 2024
High Court Passes On Protest Of IRS Social Security Levy
The U.S. Supreme Court said Monday it won't review an Eleventh Circuit decision denying a woman's challenge to the IRS' garnishment of her Social Security payments, letting stand the circuit court's conclusion that her suit was barred because she failed to exhaust administrative remedies.
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December 16, 2024
Applicable Federal Rates Set To Increase Again In Jan.
Applicable federal rates for income tax purposes will increase across the board in January, a second straight month of increases after a string of months that saw declining rates, the Internal Revenue Service said Monday.
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December 16, 2024
Justices Won't Review Man's Demand For Dad's Tax Info
The U.S. Supreme Court on Monday let stand a D.C. Circuit decision tossing a man's suit against the IRS for withholding his dead father's tax records, a ruling the man claimed had deepened a circuit split over the correct process for obtaining personal tax documents.
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December 16, 2024
IRS Issues Corp. Bond Monthly Yield Curve For Dec.
The Internal Revenue Service published the corporate bond monthly yield curve for December for use in calculations for defined benefit plans Monday, as well as corresponding segment rates and other related provisions.
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December 16, 2024
IRS Corrects Regs On Direct Pay Of Partnership Tax Credit
Internal Revenue Service issued a correction Monday to final regulations that make it easier for tax-exempt entities that co-own development projects to qualify for a direct cash payment of clean energy tax credits by electing out of their partnership tax status.
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December 16, 2024
LegalZoom Launches Strategic Alliance With 1-800Accountant
LegalZoom announced Monday that it will launch a multiyear strategic partnership with financial services firm 1-800Accountant by the start of the new year.
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December 14, 2024
IRS Criminal Probes On Worker Retention Cases Still Early
The Internal Revenue Service's criminal arm is still in the early stage of investigating the most extremely fraudulent claims of a tax credit intended to reward businesses for retaining employees during the COVID-19 pandemic, an official said Saturday.
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December 13, 2024
IRS Aims To Ramp Up Partnership Audits, Official Says
The Internal Revenue Service plans to ramp up partnership audits in the next couple of years to boost the current audit rate of 0.05% as the agency props up a new unit that solely focuses on examining large partnerships, an agency attorney said Friday.
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December 13, 2024
IRS To Wrap Up Worker Retention Credits In 2025, Werfel Says
The Internal Revenue Service plans to wrap up processing next year for thousands of claims for tax credits meant to provide incentives for businesses that retained employees during the COVID-19 pandemic, agency Commissioner Daniel Werfel said Friday.
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December 13, 2024
IRS Extends Relief For Partnership Exchange Filing Penalties
The Internal Revenue Service on Friday extended its temporary pause on imposing penalties on taxpayers who failed to provide correct payee statements as part of a partnership interest exchange to those that failed to do so in 2024.
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December 13, 2024
CFC Tax Issues Can't Be Solved Via Treaties, Officials Say
Bilateral treaties between the U.S. and other countries where a controlled foreign corporation may face withholding tax issues aren't able to effectively resolve those disputes, Internal Revenue Service and Treasury officials said Friday.
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December 13, 2024
IRS Mulls Turning Off Foreign Currency Rules For CFCs
The Internal Revenue Service is in the early stages of considering whether foreign currency gain or loss recognition rules could be turned off in certain situations for controlled foreign corporations, an agency official said Friday.
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December 13, 2024
Feds Narrow Drug Case Against Wife Of Convicted Drexel Prof
Prosecutors have told a New Jersey federal judge that they would drop one of three drug distribution charges against the wife of a convicted former Drexel University professor, saying their evidence might not establish intent after the U.S. Supreme Court raised the burden of proof for such cases in 2022.
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December 13, 2024
Halliburton Consistent On Claims For $35M Refund, Court Told
Halliburton has not changed its reasons for claiming a tax refund on a $35 million payment it made to a foreign government to protect its employees from harassment, the company told a Texas federal court, saying the U.S. wrongly accused it of a flip-flop.
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December 13, 2024
Taxation With Representation: Kirkland, Davis Polk, Wachtell
In this week's Taxation With Representation, Google and TPG Rise Climate partner with Intersect Power, Gen Digital Inc. acquires MoneyLion Inc., Patient Square Capital acquires Patterson Companies Inc., and the Buffalo Bills and Miami Dolphins sell minority ownership shares to private equity firms.
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December 13, 2024
Contractor Loses Bail For Texting Alleged Tax Cheat Allies
A District of Columbia federal judge revoked bail for a former defense contractor accused of running a $350 million tax-evasion scheme that prosecutors call one of the largest in U.S. history, after the government said he'd been texting his alleged co-conspirators.
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December 13, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included final regulations for the advanced manufacturing production credit for manufacturing key components and materials used in clean energy technologies.
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December 13, 2024
Loper Bright May Influence Tax Less, IRS Chief Counsel Says
The U.S. Supreme Court decision this year overturning a decades-long standard to defer to federal agencies' regulatory interpretations has encouraged the Internal Revenue Service to better explain its rules, its outgoing chief counsel said Friday.
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December 12, 2024
'Housewives' Figure Touts Social Media Posts In Leniency Bid
Former "Real Housewives of Atlanta" cast member Peter Anthony Thomas asked a North Carolina federal judge on Thursday to give him a prison sentence below federal guidelines for not paying $2.5 million in employment taxes, stating he has used his public platform to encourage his followers to pay their own taxes.
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December 12, 2024
Bitcoin Investor Gets 2 Years For Tax Fraud In Landmark Case
An investor who concealed millions of dollars he earned in bitcoin and became the first person criminally charged for failing to report gains from the sale of cryptocurrency by filing false returns was sentenced to two years in federal prison Thursday.
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December 12, 2024
IRS Wants Choice Retained In Dual Loss Rules, Official Says
The Internal Revenue Service is working to preserve flexibility for taxpayers in rules aimed at preventing companies from using the same economic loss twice after concerns were raised about how the rules could negatively interact with the Pillar Two global minimum tax, an official said Thursday.
Expert Analysis
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Why Attorneys Should Consider Community Leadership Roles
Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.
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Firms Must Offer A Trifecta Of Services In Post-Chevron World
After the U.S. Supreme Court’s Loper Bright Enterprises v. Raimondo decision overturning Chevron deference, law firms will need to integrate litigation, lobbying and communications functions to keep up with the ramifications of the ruling and provide adequate counsel quickly, says Neil Hare at Dentons.
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5 Tips To Succeed In A Master Of Laws Program And Beyond
As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.
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Pros, Cons Of Disclosing Improper Employee Retention Credit
Employers considering the Internal Revenue Service’s second voluntary disclosure program, which allows companies to avoid penalties for erroneously claiming employee retention credits for the 2021 tax year by repaying the credits and naming the tax advisers who encouraged these abusive practices, should carefully weigh the program’s benefits against its potential drawbacks, say attorneys at Winston & Strawn.
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How Law Firms Can Avoid 'Collaboration Drag'
Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.
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Litigation Funding Disclosure Key To Open, Impartial Process
Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.
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Whistleblowers Must Note 5 Key Differences Of DOJ Program
The U.S. Department of Justice’s recently unveiled whistleblower awards program diverges in key ways from similar programs at other agencies, and individuals must weigh these differences and look first to programs with stronger, proven protections before blowing the whistle, say Stephen Kohn and Geoff Schweller at Kohn Kohn.
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What NFL Draft Picks Have In Common With Lateral Law Hires
Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.
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Replacing The Stigma Of Menopause With Law Firm Support
A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.
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Planning Law Firm Content Calendars: What, When, Where
During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.
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Brownfield Questions Surround IRS Tax Credit Bonus
Though the IRS has published guidance regarding the Inflation Reduction Act's 10% adder for tax credits generated by renewable energy projects constructed on brownfield sites, considerable guesswork remains as potential implications seem contrary to IRS intentions, say Megan Caldwell and Jon Micah Goeller at Husch Blackwell.
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Law Firms Should Move From Reactive To Proactive Marketing
Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.
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The Big Issues A BigLaw Associates' Union Could Address
A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.