Federal

  • October 23, 2024

    MVP: Sullivan & Cromwell's Eric Wang

    Sullivan & Cromwell's S. Eric Wang advised clients on the tax law implications of major deals over the past year, including a transaction that created the largest gas utility company in North America, earning him a spot as one of the 2024 Law360 2024 Tax MVPs.

  • October 23, 2024

    IRS Schedules Electronic Tax Committee Meeting For Nov.

    The Internal Revenue Service's Electronic Tax Administration Advisory Committee will hold its next meeting Nov. 14, the agency said Wednesday.

  • October 22, 2024

    FTC On Cusp Of H&R Block False Ad Settlement

    The Federal Trade Commission has come to an agreement with H&R Block to settle claims of deceptive advertising and has withdrawn its complaint in order for the full commission to vote on the deal.

  • October 22, 2024

    8th Circ. Judge Presses IRS On 3M Transfer Pricing Tax Ruling

    An Eighth Circuit judge cast doubt during oral arguments Tuesday on the government's interpretation of regulations the IRS relied on to reallocate almost $24 million of income to 3M from its Brazilian affiliate that was subject to legal restrictions on royalty payments.

  • October 22, 2024

    New IRS Unit Starts Work On Pass-Through Compliance

    A new Internal Revenue Service unit focused on the compliance of pass-through entities of all sizes and forms, such as partnerships, S corporations and trusts, has officially started work, the agency said Tuesday.

  • October 22, 2024

    Cannabis Cos. Need Guidance For Rescheduling, CPAs Say

    The Internal Revenue Service and U.S. Treasury Department should preemptively issue guidance covering the tax implications of the proposed rescheduling of marijuana in order to make sure affected businesses are prepared for the changes, the American Institute of Certified Public Accountants said.

  • October 22, 2024

    Wash. Man Must Pay $43K Tax Bill, Court Affirms

    A Washington state resident failed to provide any evidence counter to the Internal Revenue Service's determination that he owed over $43,000 in unpaid taxes and penalties, the U.S. Tax Court said Tuesday, upholding the agency's findings.

  • October 22, 2024

    Tax Court Says It Can't Rule On FBAR Challenge

    The U.S. Tax Court said Tuesday that it lacks the authority to rule on a couple's claim that the Internal Revenue Service wrongly denied them a chance to challenge penalties for failing to report their foreign bank accounts.

  • October 22, 2024

    Wafer Factories Qualify For CHIPS Tax Credit In Final Regs

    Semiconductor wafer production facilities will qualify for the 25% investment tax credit that incentivizes advanced chip manufacturing development projects under final regulations the U.S. Department of the Treasury released Tuesday.

  • October 22, 2024

    IRS Working On Proposed Spinoff Rules, Agency Official Says

    The Internal Revenue Service is planning to propose regulations that may amend positions in an existing revenue procedure that narrowed the range of spinoff transactions the agency will approve as tax-free ahead of time, an IRS official said Tuesday.

  • October 22, 2024

    Winston & Strawn Boosts Transactions Team With NY Tax Atty

    As Winston & Strawn LLP continues to build out its transactions team, the firm has hired a new attorney from Hunton Andrews Kurth LLP with a focus on the tax aspects of real estate financing.

  • October 22, 2024

    Madigan Ally's Favors Were '100% Legal,' Not Bribes, Jury Told

    Counsel for an ex-lobbyist standing trial on public corruption charges alongside former Illinois House Speaker Michael Madigan told an Illinois federal jury Tuesday that the government is treating legal lobbying activity as bribery, and that his client did "100% legal favors" for Madigan to establish trust and maintain access to the powerful politician.

  • October 22, 2024

    Standard Deduction To Get $400 Bump For 2025 Tax Year

    The standard deduction will rise by $400, to $15,000, for individuals and married couples filing separately for the 2025 tax year, the IRS said Tuesday in announcing inflation adjustments to over 60 tax provisions.

  • October 22, 2024

    9th Circ. Asked To Revive $13M Bad Debt Deduction

    The U.S. Tax Court wrongly barred a business owner from taking a $13 million bad debt deduction for loans he made to his companies, he told the Ninth Circuit, saying the lower court treated the debt inconsistently.

  • October 22, 2024

    How Law Firms Get And Keep Elite Status

    For decades, a handful of New York-based law firms thoroughly dominated the national consciousness when it came to power, profitability and prestige. But in today's legal market, increased movement of partners and clients from one firm to the next has begun to shake things up and create opportunities for go-getters to ascend the ranks.

  • October 22, 2024

    The 2024 Prestige Leaders

    Check out our Prestige Leaders ranking, analysis and interactive graphics to see which firms stand out for their financial performance, attractiveness to attorneys and law students, ability to secure accolades and positive legal news media representation.

  • October 22, 2024

    MVP: Jones Day's Charles 'Chuck' Hodges

    Chuck Hodges, a tax partner with Jones Day, led a gravel company to victory in May at the U.S. Tax Court in a case regarding an $11.1 million sale of a freeway pit, helping him earn a spot as one of the 2024 Law360 Tax MVPs.

  • October 21, 2024

    US, Land Donor Settle Fight Over $1.9M Cut To Deduction

    The federal government settled a suit brought by a Louisiana partnership that accused the IRS of using a flawed appraisal to drive down its tax deduction for a land donation by nearly $1.9 million, according to Louisiana federal court filings.

  • October 21, 2024

    Tax Court Disallows More Of Couple's Real Estate Loss Claims

    The U.S. Tax Court on Monday increased the portion of real estate loss deductions claimed by a California couple that must be disallowed and instead carried forward because they failed to establish they were real estate professionals.

  • October 21, 2024

    Foreign Currency Regs Need Flexibility, Biz Group Says

    The U.S. Treasury Department should allow taxpayers with foreign personal holding companies to get automatic consent to revoke elections on the treatment of foreign currency gains or losses under proposed regulations to align such elections with rules on so-called mark-to-market accounting, the National Foreign Trade Council said.

  • October 21, 2024

    Tax Court Says Cannabis Co. Can't Deduct $13.3M

    A California medical cannabis dispensary's arguments that the Controlled Substances Act and part of the Internal Revenue Code were unconstitutional failed to sway the U.S. Tax Court, which on Monday affirmed an IRS determination disallowing over $13.3 million in deduction claims.

  • October 21, 2024

    Ga. Atty Admits To Role In $1.3B Tax Shelter Scheme

    A Georgia attorney has pled guilty in federal court related to helping orchestrate a $1.3 billion tax scheme involving fraudulent conservation easements, making him the 12th person convicted over the plot, including another attorney who was handed a 23-year prison sentence.

  • October 21, 2024

    MVP: Paul Weiss' Brian Krause

    Brian Krause of Paul Weiss Rifkind Wharton & Garrison LLP's tax practice designed a novel tax approach for the merger of World Wrestling Entertainment and Ultimate Fighting Championship, raced to create a tax-free deal in the final days of a Texas "wildcatter" hoping to sell his oil company, and advised Chevron in its $60 billion acquisition of Hess Corp., earning him a spot as one of the 2024 Law360 Tax MVPs.

  • October 21, 2024

    High Court Won't Review Couple's Anti-Tax Case

    The U.S. Supreme Court said Monday it wouldn't hear the arguments of a couple challenging the federal government's power to collect their income taxes, letting stand a Tenth Circuit opinion that all the couple's claims were meritless.

  • October 21, 2024

    IRS Issues Corp. Bond Monthly Yield Curve For Oct.

    The Internal Revenue Service published Monday the corporate bond monthly yield curve for October for use in calculations for defined benefit plans, as well as corresponding segment rates and other related provisions.

Expert Analysis

  • Money, Money, Money: Limiting White Collar Wealth Evidence

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    As courts increasingly recognize that allowing unfettered evidence of wealth could prejudice a jury against a defendant, white collar defense counsel should consider several avenues for excluding visual evidence of a lavish lifestyle at trial, says Jonathan Porter at Husch Blackwell.

  • How Associates Can Build A Professional Image

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    As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.

  • Navigating New Safe Harbor For Domestic Content Tax Credits

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    The U.S. Department of the Treasury’s recent notice simplifying domestic content calculations for certain solar, onshore wind and battery storage projects, which directly acknowledges the difficulty for taxpayers in gathering data to support a domestic content analysis, should make it easier to qualify additional domestic content bonus tax credits, say attorneys at A&O Shearman.

  • Firms Must Rethink How They Train New Lawyers In AI Age

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    As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.

  • 'Energy Communities' Update May Clarify Tax Credit Eligibility

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    A recent IRS notice that includes updated lists of locations where clean energy projects can qualify for additional tax credits — based 2023 unemployment data and placed-in-service dates — should help provide clarity regarding project eligibility that sponsors and developers need, say attorneys at Troutman Pepper.

  • Think Like A Lawyer: Always Be Closing

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    When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.

  • How Cannabis Rescheduling May Alter Paraphernalia Imports

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    The Biden administration's recent proposal to loosen federal restrictions on marijuana use raises questions about how U.S. Customs and Border Protection enforcement policies may shift when it comes to enforcing a separate federal ban on marijuana accessory imports, says R. Kevin Williams at Clark Hill.

  • NCAA Settlement May End The NIL Model As We Know It

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    The recent House v. NCAA settlement in California federal court, in which the NCAA agreed to allow schools to directly pay March Madness television revenue to their athletes, may send outside name, image and likeness collectives in-house, says Mike Ingersoll at Womble Bond.

  • Fishing Makes Me A Better Lawyer

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    Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.

  • A Healthier Legal Industry Starts With Emotional Intelligence

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    The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.

  • To Make Your Legal Writing Clear, Emulate A Master Chef

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    To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.

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