Federal
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November 01, 2024
Previously Taxed Profit Rules Due By Year's End, Official Says
The Internal Revenue Service will publish the first tranche of long-awaited regulations on offshore earnings and profits previously taxed in the U.S. before the end of the year, an agency counsel said Thursday.
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November 01, 2024
NOL Rules May Retain Favorable Approach, IRS Counsel Says
New proposed regulations governing business net operating losses that could retain a popular provision allowing some businesses expanded use of those losses are a priority to be published next year, a top Internal Revenue Service lawyer said.
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November 01, 2024
Brazil Should Adopt Latest Pillar 2 Safe Harbor, NFTC Says
Brazil should include the latest updates to globally agreed-upon safe harbors in its legislation to enact an international minimum tax agreement known as Pillar Two, according to the National Foreign Trade Council, which said these measures help prevent double taxation.
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November 01, 2024
Couple Tries To Block IRS Summons Issued For Spain
A couple asked a California federal court to block an IRS summons for their financial information issued on behalf of Spain, saying the demand is tantamount to a fishing expedition meant to help the foreign government prosecute them.
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November 01, 2024
Taxation With Representation: Kirkland, Davis Polk, Wachtell
In this week's Taxation with Representation, BC Partners sells its majority equity interest in GardaWorld, Lone Star Funds sells specialty chemicals company AOC to Nippon Paint Holdings, Crescent Biopharma takes GlycoMimetics private, and Francisco Partners buys AdvancedMD from Global Payments.
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November 01, 2024
Danish Tax Agency To Settle With Atty In $2.1B Tax Fraud Suit
Denmark's tax authority has agreed to settle with an attorney whom it has accused of helping clients claim fraudulent tax refunds in a sprawling $2.1 billion case, according to a letter by its attorney in New York federal court.
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November 01, 2024
IRS Ups Contribution Limit For 401(k), Other Plans
The annual amount that employees can contribute to various retirement plans has been increased to $23,500 from $23,000 as part of cost-of-living adjustments released Friday by the IRS.
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November 01, 2024
CFC Dividend Tax Issue Brewing In Exams, IRS Official Says
A memorandum from the IRS chief counsel explaining why a controlled foreign corporation cannot claim a 100% deduction for certain foreign-based earnings was necessary to inform field agents dealing with the issue in the exam process, an agency official said Thursday.
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November 01, 2024
Accountant Gets 1 Year For Failing To Report Stolen Income
An accountant for a manufacturing company who embezzled more than $800,000 and failed to report it on his tax returns was sentenced to just over a year in prison and ordered to pay $1 million in restitution, according to New Jersey federal court documents.
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November 01, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the annual inflation adjustments to over 60 tax provisions.
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October 31, 2024
Man Didn't Justify His Claims He Couldn't Pay, Tax Court Says
The Internal Revenue Service didn't abuse its discretion when it upheld levies to collect over $58,000 in outstanding tax liabilities, including penalties and interest, after a man failed to substantiate his claims of medical hardship, the U.S. Tax Court said Thursday.
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October 31, 2024
Treasury Using Help To Clear Pillar 1 'Logjam,' Official Says
Other executive agencies in President Joe Biden's administration have backed the U.S. Treasury Department in urging negotiators at the Organization for Economic Cooperation and Development to reach a final deal on the international taxing rights overhaul known as Pillar One, a top Treasury official said Thursday.
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October 31, 2024
Exxon Entitled To Interest Deduction On Qatar Deal
Exxon Mobil is entitled to an interest expense deduction on payments to Qatar under a natural gas deal, a Texas federal judge ruled, rejecting the U.S. government's classification of an underlying transaction as a royalty rather than a loan.
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October 31, 2024
Treasury Official Previews M&A Details For Corp. AMT Rules
U.S. rulemakers plan to further address how the country's corporate alternative minimum tax applies to transactions including spinoffs and deals that involve a member of a tax consolidated group, a U.S. Treasury Department official said Thursday.
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October 31, 2024
Pro Baller Avoids Prison Over Tax, Child Support Scam
A professional basketball player was sentenced to three years of probation in Ohio federal court after being charged with conspiracy and wire fraud for allegedly attempting to avoid paying child support and taxes for several years.
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October 31, 2024
6th Circ. Wary Of Bid To Overturn $500M Win For Truck Co.
Sixth Circuit judges seemed skeptical Thursday of the government's $500 million bid to overturn a Tennessee jury's decision that a company's refurbished trucks qualified for a safe harbor from excise taxes, saying the government's reading of a tax provision was unclear.
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October 31, 2024
The 2024 Law360 Pulse Leaderboard
Check out the Law360 Pulse Leaderboard to see which firms made the list of leaders in all-around excellence this year.
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October 31, 2024
Firms' Hiring Strategies Are Evolving In Fight For Top Spot
Competition for top talent among elite law firms shows no signs of slowing down, even amid economic uncertainty, with financially strong firms deploying aggressive strategies to attract and retain skilled professionals to solidify their market position.
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October 31, 2024
11th Circ. Nixes ERISA Claim To John Hancock's $100M Credit
John Hancock Life Insurance Co. had no fiduciary duty to pass on to retirement plans $100 million in foreign tax credits that it had taken from taxes paid on foreign investments, a three-judge panel of the Eleventh Circuit said in upholding a lower court ruling.
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October 30, 2024
FinCEN Extends BOI Report Deadline For Hurricane Victims
The U.S. Department of the Treasury's Financial Crimes Enforcement Network has extended deadlines for submitting beneficial ownership information for victims of recent hurricanes, offering an additional six months to file or update reports, or to correct prior reports.
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October 30, 2024
Jury Finds Importer Didn't Report $17M On Tax Returns
A Los Angeles jury found an importer of Chinese clothing guilty of skirting more than $8 million in customs duties and failing to report more than $17 million in cash transactions on tax returns, federal prosecutors in California announced Wednesday.
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October 30, 2024
Tax Court Stands By Couple's Tax Liability After Remand
An investor couple whose case was remanded by the Sixth Circuit is still liable for over $603,000 in deficient taxes tied to $3 million in claimed losses from a complex foreign-exchange derivative arrangement since their actions were not made with legitimate intentions of turning a profit, the U.S. Tax Court said Wednesday.
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October 30, 2024
GOP Lawmakers Criticize Treasury's Start Of Taiwan Tax Talks
The top tax-writing Republicans in Congress said Wednesday that the U.S. Treasury Department's announcement that it would begin negotiations with Taiwan on a double-tax relief agreement risks undermining legislation to address the issue that is stalled in the Senate.
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October 30, 2024
Mayo Shouldn't Get Tax Break For Education, 8th Circ. Told
The Eighth Circuit should overturn a ruling that found the Mayo Clinic's intertwined medical and educational purposes qualified it for a tax exemption on certain business income for educational institutions, the U.S. government argued, saying a recent Fifth Circuit ruling supports its argument that only exclusively educational organizations qualify.
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October 30, 2024
IRS Seeks Taxpayer Advocacy Panel Members From 14 States
The Internal Revenue Service is accepting applications for its Taxpayer Advocacy Panel from 14 states and Puerto Rico, the agency said Wednesday.
GOP Gains Could Prompt Push For Endowment Tax Hike
If Republicans make significant gains in the upcoming elections, it could clear the way for GOP lawmakers to push to boost taxes on the endowments of some private colleges and universities.
4 Ways Congress Could Try To Close The Tax Gap
The gap between federal taxes owed and paid — recently estimated at $696 billion for 2022 — could be addressed in several ways, including increasing information reporting or simplifying the tax code, experts told Law360.
Pillar 2 Likely To Cast Shadow Over US Tax Bill Talks
The international minimum tax agreement known as Pillar Two won't officially factor into upcoming tax bill negotiations in the U.S. Congress, but the global regime's potential grab at U.S. tax revenue could informally influence policy choices.
GOP Gains Could Prompt Push For Endowment Tax Hike
If Republicans make significant gains in the upcoming elections, it could clear the way for GOP lawmakers to push to boost taxes on the endowments of some private colleges and universities.
4 Ways Congress Could Try To Close The Tax Gap
The gap between federal taxes owed and paid — recently estimated at $696 billion for 2022 — could be addressed in several ways, including increasing information reporting or simplifying the tax code, experts told Law360.
Pillar 2 Likely To Cast Shadow Over US Tax Bill Talks
The international minimum tax agreement known as Pillar Two won't officially factor into upcoming tax bill negotiations in the U.S. Congress, but the global regime's potential grab at U.S. tax revenue could informally influence policy choices.
Featured Stories
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GOP Gains Could Prompt Push For Endowment Tax Hike
If Republicans make significant gains in the upcoming elections, it could clear the way for GOP lawmakers to push to boost taxes on the endowments of some private colleges and universities.
-
4 Ways Congress Could Try To Close The Tax Gap
The gap between federal taxes owed and paid — recently estimated at $696 billion for 2022 — could be addressed in several ways, including increasing information reporting or simplifying the tax code, experts told Law360.
-
Pillar 2 Likely To Cast Shadow Over US Tax Bill Talks
The international minimum tax agreement known as Pillar Two won't officially factor into upcoming tax bill negotiations in the U.S. Congress, but the global regime's potential grab at U.S. tax revenue could informally influence policy choices.
Expert Analysis
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Takeaways From The IRS' Crypto Doc Summons Win
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A recent First Circuit decision holding that taxpayers do not have a Fourth Amendment reasonable expectation of privacy in cryptocurrency transaction records should prompt both taxpayers and exchanges to take stock of past transactions and future plans, say attorneys at BakerHostetler.
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Empathy In Mediation Offers A Soft Landing For Disputes
Experiencing a crash-landing on a recent flight underscored to me how much difference empathy makes in times of crisis or stress, including during mediation, says Eydith Kaufman at Alternative Resolution Centers.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
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Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Ex-Chicago Politician's Case May Further Curb Fraud Theories
The U.S. Supreme Court recently agreed to hear Thompson v. U.S. to determine whether a statement that is misleading but not false still violates federal law, potentially heralding the court’s largest check yet on prosecutors’ expansive fraud theories, with significant implications for sentencing, say attorneys at the Law Offices of Alan Ellis.
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
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The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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Tariffs' Economic Downsides Outweigh Potential Revenue
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Import tariffs proposed by the campaign of former president Donald Trump would generate revenue like other taxes, but policymakers must consider the net-negative impact of associated consumer and downstream-industry costs, harm to exporters, potential foreign retaliation and reduction in economic output, says Erica York at the Tax Foundation.
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Navigating The Last Leg Of The Worker Retention Tax Credit
Whether a business has applied for the pandemic-era employee retention tax credit, received a denial letter or is still considering making a claim before the April 15 deadline, it should examine recent developments significantly affecting the program before planning next steps, say attorneys at Nixon Peabody.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.
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Home Canning Makes Me A Better Lawyer
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Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.