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The Federal Trade Commission has come to an agreement with H&R Block to settle claims of deceptive advertising and has withdrawn its complaint in order for the full commission to vote on the deal.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

    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

    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

    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

  • Avoid Getting Burned By Agencies' Solar Financing Spotlight

    Author Photo

    Recently coordinated reports and advisories from the U.S. Department of the Treasury, the Consumer Financial Protection Bureau and the Federal Trade Commission maximize the spotlight on the consumer solar financing market and highlight pitfalls for lenders to avoid in this burgeoning field, says Mercedes Tunstall at Cadwalader.

  • Tax Traps In Acquisitions Of Financially Distressed Targets

    Excerpt from Practical Guidance
    Author Photo

    Parties to the acquisition of an insolvent or bankrupt company face myriad tax considerations, including limitations on using the distressed company's tax benefits, cancellation of indebtedness income, tax lien issues and potential tax reorganizations.

  • Navigating A Potpourri Of Possible Transparency Act Pitfalls

    Author Photo

    Despite the Financial Crimes Enforcement Network's continued release of guidance for complying with the Corporate Transparency Act, its interpretation remains in flux, making it important for companies to understand potentially problematic areas of ambiguity in the practical application of the law, say attorneys at Sidley.

  • How Methods Are Evolving In Textualist Interpretations

    Author Photo

    Textualists at the U.S. Supreme Court are increasingly considering new methods such as corpus linguistics and surveys to evaluate what a statute's text communicates to an ordinary reader, while lower courts even mull large language models like ChatGPT as supplements, says Kevin Tobia at Georgetown Law.

  • Why Attorneys Should Consider Community Leadership Roles

    Author Photo

    Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.

  • Firms Must Offer A Trifecta Of Services In Post-Chevron World

    Author Photo

    After the U.S. Supreme Court’s Loper Bright Enterprises v. Raimondo decision overturning Chevron deference, law firms will need to integrate litigation, lobbying and communications functions to keep up with the ramifications of the ruling and provide adequate counsel quickly, says Neil Hare at Dentons.

  • 5 Tips To Succeed In A Master Of Laws Program And Beyond

    Author Photo

    As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.

  • Pros, Cons Of Disclosing Improper Employee Retention Credit

    Author Photo

    Employers considering the Internal Revenue Service’s second voluntary disclosure program, which allows companies to avoid penalties for erroneously claiming employee retention credits for the 2021 tax year by repaying the credits and naming the tax advisers who encouraged these abusive practices, should carefully weigh the program’s benefits against its potential drawbacks, say attorneys at Winston & Strawn.

  • How Law Firms Can Avoid 'Collaboration Drag'

    Author Photo

    Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.

  • Litigation Funding Disclosure Key To Open, Impartial Process

    Author Photo

    Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.

  • Whistleblowers Must Note 5 Key Differences Of DOJ Program

    Author Photo

    The U.S. Department of Justice’s recently unveiled whistleblower awards program diverges in key ways from similar programs at other agencies, and individuals must weigh these differences and look first to programs with stronger, proven protections before blowing the whistle, say Stephen Kohn and Geoff Schweller at Kohn Kohn.

  • What NFL Draft Picks Have In Common With Lateral Law Hires

    Author Photo

    Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.

  • Replacing The Stigma Of Menopause With Law Firm Support

    Author Photo

    A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.