Federal

  • August 30, 2024

    Partnership Can't Save Premature Tax Court Appeal, Feds Say

    The IRS is urging the Eleventh Circuit to throw out a Tax Court appeal that a partnership formed by two former Atlanta Braves players filed over a slashed $47.6 million conservation easement deduction, since the appeal was improperly filed before a final decision was entered.

  • August 30, 2024

    3 Ways Justices' SEC Fraud Ruling Could Affect Tax Disputes

    The U.S. Supreme Court's groundbreaking decision to curb the U.S. Securities and Exchange Commission's in-house fraud enforcement could hamper the IRS' ability to assert certain penalties, including in contested conservation easement cases, and challenge the U.S. Tax Court's authority to review them. Here, Law360 examines three arenas in which the Supreme Court decision could shake up tax administration and litigation.

  • August 30, 2024

    Alvarez & Marsal Appoints Tax Experts As Managing Directors

    Alvarez & Marsal Tax LLC appointed tax experts from Anderson and Deloitte as its new managing directors, the firm announced.

  • August 30, 2024

    Danish Gov't Pledges No Ponzi Analogies At $2.1B Tax Trial

    The Danish tax authority won't compare pension funds, investors and attorneys it has accused of defrauding Denmark in a $2.1 billion tax refund scheme to a Ponzi scheme or infamous perpetrator Bernie Madoff, it said Friday in New York federal court.

  • August 30, 2024

    Whistleblower Seeks 2nd Bid At $690M Claim In DC Circ.

    A whistleblower denied up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program asked for a D.C. Circuit panel to rehear his case Friday, saying its original opinion included numerous mistakes and misunderstandings.

  • August 30, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included an announcement of the reopening of a voluntary disclosure program for businesses that think they improperly received COVID-19-era employee retention credits.

  • August 30, 2024

    Partnership Asks 11th Circ. To Restore $9M Easement Break

    A partnership asked the Eleventh Circuit to reinstate its nearly $9 million deduction for donating a conservation easement in Georgia, saying the U.S. Tax Court erroneously limited the deduction to its cost basis by claiming partners who contributed the property had held it as inventory.

  • August 30, 2024

    IRS Corrects Proposed Rules To Address Pillar 2 Losses

    The Internal Revenue Service issued corrections Friday to proposed rules 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.

  • August 30, 2024

    Dow Seeks To Add 7 Chemicals To IRC Taxable Substances

    The Internal Revenue Service said Friday that it is looking for public comments on proposals by Dow Chemical to add seven chemicals to the Internal Revenue Code's list of taxable substances.

  • August 30, 2024

    Taxation With Representation: Kirkland, Paul Weiss, Squire

    In this week's Taxation With Representation, Oneok reaches two agreements with energy infrastructure companies worth a total $5.9 billion, McKesson inks a $2.49 billion deal for a cancer center, and First Busey and CrossFirst Bankshares agree to a $917 million merger.

  • August 30, 2024

    Rule Aims To Widen Low-Income Green Electricity Tax Credits

    Geothermal, hydropower, nuclear fusion and nuclear fission projects would be among the types of electricity facilities that could be eligible for clean electricity low-income community bonus credit amounts starting in 2025, the Internal Revenue Service and U.S. Treasury Department said in proposed rules released Friday.

  • August 29, 2024

    9th Circ. Says IRS Properly Rejected Payment Compromise

    A man who owed $50 million in taxes and offered to settle part of his debt was correctly denied a compromise, the Ninth Circuit affirmed Thursday, rejecting his argument that his offer should have been deemed accepted because the agency missed the two-year deadline for rejecting it.

  • August 29, 2024

    Tax Court Rejects Bid To Change Ruling Post-Chevron

    The U.S. Supreme Court's recent overturning of the Chevron standard of judicial deference to agencies when interpreting statutes does not justify reconsidering a Cayman Islands partnership's tax liability, the U.S. Tax Court ruled.

  • August 29, 2024

    4th Circ. Won't Revive Whistleblower's Credit Suisse Tax Suit

    The Fourth Circuit upheld the dismissal of a former Credit Suisse employee's whistleblower case that alleged the Swiss bank continued to help clients evade taxes after it made a related plea deal with the U.S., saying a 2023 U.S. Supreme Court decision on the False Claims Act could not save the case.

  • August 29, 2024

    Convicted Drexel Prof Says Records Would've Swayed Jury

    A Drexel University accounting professor convicted on charges of tax evasion and filing false tax returns after the government accused him of failing to report $3.3 million in income from a Trenton pharmacy has asked a New Jersey federal judge for a new trial.

  • August 29, 2024

    IRS Lacking In Limiting Below-$400K Audits, TIGTA Says

    The IRS has made only partial progress toward complying with a U.S. Treasury Department directive to develop methodology to ensure the agency doesn't increase the audit rate for businesses and households with annual incomes below $400,000, the Treasury Inspector General for Tax Administration reported Thursday.

  • August 29, 2024

    GAO Suggests IRS Improve Retirement Account Oversight

    The Internal Revenue Service needs to beef up its oversight of conflicts of interest between fiduciaries and individual retirement account investors, according to a U.S. Government Accountability Office report.

  • August 29, 2024

    Applications Open For $6B In Advanced Energy Tax Credits

    Full applications are now open for manufacturers seeking a share of a second-round $6 billion tax-credit allocation for their development projects that support the clean energy industry, the Internal Revenue Service and U.S. Department of Energy said Thursday.

  • August 29, 2024

    Colo. Group Asks US Justices To Revive Ballot Law Dispute

    A Colorado organization asked the U.S. Supreme Court to review a lower-court decision upholding a state law requiring financial impacts be included in the titles of some tax-related ballot initiatives.

  • August 29, 2024

    Couple Not Entitled To Seek $480K Refund, US Tells 5th Circ.

    A couple claiming they paid their tax bill should not be allowed to sue the Internal Revenue Service for a refund in a federal district court, the government told the Fifth Circuit on Thursday, saying the agency thinks the couple still owes about $480,000.

  • August 29, 2024

    Day Pitney Lands Former Reuters Tax Counsel In Conn.

    Day Pitney LLP continued its recent growth in its tax practice in Connecticut with the addition of an experienced tax attorney from Thomson Reuters.

  • August 29, 2024

    IRS Expands Accounting Change Waiver Eligibility

    The Internal Revenue Service adjusted a previous notice Thursday to modify certain procedures for obtaining automatic consent of the agency commissioner to change methods of accounting for expenditures paid or incurred in taxable years beginning after 2021.

  • August 29, 2024

    Churches Attack Nonprofit Politics Ban As Unconstitutional

    Churches and Christian advocacy groups asked a Texas federal court to declare unconstitutional a provision in the Internal Revenue Code that prevents tax-exempt nonprofits from endorsing political candidates, saying the IRS discriminates against conservative religious groups and churches in applying the law.

  • August 29, 2024

    IRS Corrects Partnership Conservation Easement Limit Rules

    The Internal Revenue Service issued corrections Thursday to finalized rules that curb the conservation easement tax deduction claimed by certain partnerships under the Secure 2.0 Act.

  • August 28, 2024

    Hunter Biden's Addiction Expert Knocked Out Of Tax Trial

    A California federal judge on Tuesday barred Hunter Biden's expected addiction expert from testifying in his upcoming trial on tax charges, saying the expert's opinions hadn't been clearly linked to the specifics of Biden's own struggle.

Expert Analysis

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    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.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    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.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    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.

  • Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules

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    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.

  • Employee Experience Strategy Can Boost Law Firm Success

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    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.

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    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.

  • Lessons From Country Singer's Personal Service Saga

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    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.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    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.

  • 5 Litigation Funding Trends To Note In 2024

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    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.

  • Tech CEO Tax Ruling A Warning For Forward Contracts

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    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.

  • 4 Legal Ethics Considerations For The New Year

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    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.

  • What The Law Firm Of The Future Will Look Like

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    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.

  • 4 PR Pointers When Your Case Is In The News

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    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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