Federal
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October 25, 2024
Virgin Islands Looks To Recoup Ocwen's $8.6M Tax Refund
The U.S. Virgin Islands' revenue bureau mistakenly paid an $8.6 million tax refund to mortgage company Ocwen based on a 90% economic development credit that shouldn't have been allowed, the islands' government told a federal court as it seeks to take back the money.
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October 25, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included final rules that ended an income inclusion associated with intangibles for companies in some cases when transferring intellectual property from abroad back to the U.S.
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October 25, 2024
MVP: Wachtell's Tijana J. Dvornic
Wachtell Lipton Rosen & Katz's Tijana J. Dvornic led the firm's tax team in representing Lumen Technologies in the largest liability management transaction outside of bankruptcy protections, including addressing over $15 billion of existing debt, earning her a spot as one of the 2024 Law360 Tax MVPs.
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October 24, 2024
IRS To End Automatic Foreign Gift Reporting Penalty
Internal Revenue Service Commissioner Danny Werfel told the UCLA Tax Controversy Conference audience on Thursday that the agency will no longer automatically assess penalties for the late reporting of large foreign gifts, with the announcement eliciting applause from the audience of several hundred tax attorneys and tax professionals.
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October 24, 2024
Couple Owes Tax, Frivolous Arguments Penalty, 9th Circ. Says
The U.S. Tax Court correctly found that a Washington couple who repeatedly filed frivolous returns and claimed their wages are tax-free owe about $9,000 in taxes for 2017 and 2018, the Ninth Circuit said Thursday.
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October 24, 2024
Tax Court Affirms Rejection Of $94K In Deduction Claims
The Internal Revenue Service correctly disallowed a couple's nearly $94,000 in claimed individual and business deductions, the U.S. Tax Court said Thursday, while also finding them liable for nearly $11,000 in accuracy-related penalties.
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October 24, 2024
IRS Forming Transfer Pricing Team To Aid Real-Time Audits
The Internal Revenue Service is establishing a dedicated team to tackle transfer pricing issues that arise in real-time audits of companies participating in its compliance assurance process program, which should allow those issues to be handled more efficiently, an agency official said Thursday.
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October 24, 2024
Tax Court Nixes IRS Agent's $126K In Deductions
An Internal Revenue Service agent is not entitled to $126,000 in deductions for supposed medical expenses and charitable donations, the U.S. Tax Court ruled Thursday, saying the worker couldn't prove the payments were actually made.
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October 24, 2024
Wyden's Pharma Probe Could Build Case For Int'l Tax Reforms
Senate Finance Committee Chairman Ron Wyden's investigation into the tax planning of major U.S. pharmaceutical companies could help fuel an effort to revamp U.S. international tax laws next year when Congress addresses expiring provisions of the Tax Cuts and Jobs Act.
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October 24, 2024
Defunct Yoga Biz Co-Owner Cops To Tax-Dodging Conspiracy
A Seattle-area computer programmer who co-owned the defunct Yoga to the People business told a Manhattan federal judge on Thursday that he schemed to short the IRS on over $4 million of income, copping to a tax fraud conspiracy count.
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October 24, 2024
IRS Proposes Rules To Calculate Efficient Home Energy Credit
The Internal Revenue Service proposed rules Thursday for calculating a homeowner tax credit for improving energy efficiency and released guidance for manufacturers of improvement products that have complained about a government registration system set to take effect next year.
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October 24, 2024
Ex-Moody's GC Gets Prison For Tax-Filing Fail On $54M In Pay
The former general counsel for Moody's Corp. was sentenced Thursday to eight months in prison for willfully failing to file federal income tax returns for four years in which he collected $54 million in income.
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October 24, 2024
MVP: Sidley's Rachel D. Kleinberg
Rachel D. Kleinberg, a co-leader of the global tax practice at Sidley Austin LLP, headed up a tax team to represent investors in a consortium that led to the $6.05 billion sale of the NFL's Washington Commanders, earning her a spot as one of the 2024 Law360 Tax MVPs.
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October 24, 2024
IRS Schedules November Advisory Council Meeting
The Internal Revenue Service Advisory Council will hold its next meeting Nov. 20, the agency announced Thursday.
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October 24, 2024
Mining Eligible In Final Regs For Energy Manufacturing Credit
The U.S. Treasury Department's final rules released Thursday on a valuable tax credit for manufacturing key components and materials used in clean energy technologies allow producers to take into account the costs to mine and extract critical minerals.
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October 23, 2024
IRS To Split Pass-Through, Energy Credit Work Into 2 Units
The IRS is planning to split up its Pass-Throughs and Special Industries office into two separate divisions, including one that will focus in part on energy credits enacted under the 2022 landmark climate law, an agency official said Wednesday.
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October 23, 2024
Tax Court Says Trucker Can't Deduct Reimbursed Expenses
The Internal Revenue Service correctly disallowed a Georgia truck driver's unreimbursed business expense deduction claims, because he was in fact reimbursed for the various expenses, the U.S. Tax Court said Wednesday.
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October 23, 2024
Microsemi's Fines Mostly Adhered To Rules, Tax Court Says
The Internal Revenue Service obtained the proper written approval of penalties on most of the tax code violations it brought against semiconductor manufacturer Microsemi but left room for doubt on two penalties, the U.S. Tax Court said.
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October 23, 2024
Foley & Lardner Adds Burr & Forman Corporate Duo In Fla.
Foley & Lardner LLP has ramped up its innovative technology sector and transactions practice group with two former Burr & Forman LLP partners in Jacksonville, Florida, where a Foley & Lardner leader said their arrival aligned with the firm's strategic focus on four key sectors of the economy.
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October 23, 2024
9th Circ. Orders Michael Avenatti To Be Resentenced
The Ninth Circuit on Wednesday ordered the resentencing of Michael Avenatti over his California conviction for tax violations and stealing from clients, saying the lower court made multiple mistakes when it handed down a 14-year prison term to the onetime celebrity attorney.
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October 23, 2024
CPAs Prepare For Uncertainty As TCJA Expiration Looms
Certified public accountants and financial planners are preparing to help their clients navigate the uncertainty around next year's expiration of major parts of the Tax Cuts and Jobs Act as lawmakers gear up to decide who will bear the brunt of any resulting tax changes.
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October 23, 2024
ABA Tax Section Pushes IRS To Narrow Pillar 2 Regulations
Proposed regulations outlining when foreign taxes under the Pillar Two international minimum tax agreement trigger U.S. rules against benefiting twice from the same economic loss should be narrowed to limit their applicability, the American Bar Association Tax Section told the IRS.
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October 23, 2024
IRS Grants Tax-Exempt Entities Relief From Corp. AMT Filing
Tax-exempt entities are not obligated to file the corporate alternative minimum tax form for the 2023 tax year with the Internal Revenue Service, but they should still maintain the document for recordkeeping purposes, the agency announced Wednesday.
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October 23, 2024
Judge Threatens To Toss Gov't's $4.9M Son-Of-Boss Claim
A federal judge warned government attorneys Wednesday that she would dismiss their case against an estate for $4.9 million in taxes if they didn't explain why they weren't actively pursuing their accusations that a Michigan couple schemed to artificially cancel out capital gains
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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.
Expert Analysis
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Maximizing Law Firm Profitability In Uncertain Times
As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.
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Enforcement Of International Tax Reporting Is Heating Up
Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.
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How Gov't Agencies Will Fare In The Event Of A Shutdown
With a federal shutdown potentially set to begin at the end of this month, it may be useful to consider the approximate timelines that agencies such as the Federal Trade Commission and IRS have announced for curtailing operations, and potential strategies for mitigating challenges that may arise while agency functions are limited, say attorneys at Cleary.
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IRS Notice Clarifies R&E Amortization, But Questions Remain
The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.
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Preparing Your Legal Department For Pillar 2 Compliance
Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.
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What Large Language Models Mean For Document Review
Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.
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Participating In Living History Makes Me A Better Lawyer
My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.
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Private Equity Owners Can Remedy Law Firms' Agency Issues
Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.
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Kentucky Tax Talk: Taking Up The Dormant Commerce Clause
Attorneys at Frost Brown examine whether the U.S. Supreme Court is likely to review Foresight Coal Sales v. Kent Chandler to consider whether a Kentucky utility rate law discriminates against interstate commerce, and how the decision may affect dormant commerce clause jurisprudence.
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Prevailing Wage Rules Complicate Inflation Act Tax Incentives
Nicole Elliott and Timothy Taylor at Holland & Knight discuss the intersection between tax and labor newly created by the Inflation Reduction Act, and focus on aspects of recent U.S. Department of Labor and U.S. Department of the Treasury rules that may catch tax-incentive seekers off guard.
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Payroll Tax Evasion Notice Suggests FinCEN's New Focus
The Financial Crimes Enforcement Network’s recent notice advising U.S. financial institutions to report payroll tax evasion and workers' compensation schemes in the construction industry suggests a growing interest in tax enforcement and IRS collaboration, as well as increased scrutiny in the construction sector, say Andrew Weiner and Jay Nanavati at Kostelanetz.
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How Taxpayers Can Prep As Justices Weigh Repatriation Tax
The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.
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IRS Foreign Tax Credit Pause Is Welcome Course Correction
A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.