Federal
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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October 21, 2024
Justices Won't Review IRS' Additions To Developer's $2M Deal
The U.S. Supreme Court said Monday it wouldn't review an Eleventh Circuit decision allowing the Internal Revenue Service to back out of a deal to settle an Alabama real estate developer's tax debt for $2 million.
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October 21, 2024
New ABA Tax Chair-Elect Aims To Expand Leadership Paths
The new chair-elect of the American Bar Association Section of Taxation told Law360 that she wants to broaden the pathways to leadership for members, including those early in their careers, as part of the section's diversity, equity and inclusion initiatives. Here, Megan Brackney shares more about her background and goals for the section.
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October 18, 2024
Law360 MVP Awards Go To Top Attys From 74 Firms
The attorneys chosen as Law360's 2024 MVPs have distinguished themselves from their peers by securing hard-earned successes in high-stakes litigation, complex global matters and record-breaking deals.
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October 18, 2024
FTC Won't Disqualify ALJ in H&R Block False Ad Fight
The Federal Trade Commission denied a request by H&R Block to stop an administrative law judge from overseeing a proceeding that accuses the tax preparation company of deceptive advertising, saying Friday that ALJs don't have unconstitutional job protections as the company claimed.
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October 18, 2024
IRS Releases Sustainable Airplane Fuel Credit Guidance
Taxpayers using a certain safe harbor to calculate their emissions reduction percentage with regard to sustainable airplane fuel credit claims on the sale or use of qualified mixtures after a certain date must use an updated model, the IRS said Friday.
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October 18, 2024
Tax Court Gave Short Shrift To Land Donors, 11th Circ. Told
The owners of a waterfront property in Georgia who protected 500 acres for conservation told the Eleventh Circuit that the U.S. Tax Court drastically undercut the value of their gift and its corresponding tax deduction by accepting flawed evidence provided by the government's sole witness.
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October 18, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included final regulations that impose additional reporting requirements under the threat of penalty for partnerships that abuse a conservation easement tax deduction.
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October 18, 2024
IRS OKs Rules On Withholding For Pension Payments
The Internal Revenue Service released final rules Friday covering certain retirement plans' obligation to withhold income tax when they make payments or distributions to taxpayers outside the U.S. starting in 2026.
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October 18, 2024
Taxation With Representation: Baker, Simpson, Ropes
In this week's Taxation With Representation, Lundbeck inks a $2.6 billion cash deal for Longboard, Silver Lake agrees to buy Zuora for $1.7 billion, and PPG and American Industrial Partners reach a $550 million deal.
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October 17, 2024
Liberty Global Shouldn't Get $248M Tax Credit, 10th Circ. Told
Liberty Global distorted the language and statutory scheme of the U.S. tax code's foreign tax credit regulations to falsely claim $248 million in credits, the U.S. government told the Tenth Circuit on Thursday.
Expert Analysis
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How Associates Can Build A Professional Image
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.
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Navigating New Safe Harbor For Domestic Content Tax Credits
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.
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Firms Must Rethink How They Train New Lawyers In AI Age
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.
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'Energy Communities' Update May Clarify Tax Credit Eligibility
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.
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Think Like A Lawyer: Always Be Closing
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.
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
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.
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Lean Into The 'Great Restoration' To Retain Legal Talent
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.
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How Cannabis Rescheduling May Alter Paraphernalia Imports
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.
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NCAA Settlement May End The NIL Model As We Know It
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.
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Fishing Makes Me A Better Lawyer
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.
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A Healthier Legal Industry Starts With Emotional Intelligence
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.
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To Make Your Legal Writing Clear, Emulate A Master Chef
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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Circuit Judge Writes An Opinion, AI Helps: What Now?
Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.