Federal
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November 04, 2024
2nd Circ. Rejects Man's Challenge To IRS Lien For $4.2M
The U.S. Tax Court correctly found that the IRS appeals office didn't abuse its powers by approving the agency's federal tax lien to collect $4.2 million from a man with a court-ordered payment plan, the Second Circuit said.
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November 04, 2024
Ga. Tax Preparer Gets 28 Months In $5M Tax Scheme
A Georgia accountant was sentenced to more than two years in prison for his role in promoting syndicated conservation easements that resulted in a $5 million tax loss to the Internal Revenue Service, the U.S. Department of Justice announced.
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November 04, 2024
US Must Pay Legal Fees To Challenger Of IRS Guidance
A Michigan federal judge ordered the U.S. to pay roughly $220,000 in attorney fees to a construction company that won its challenge to Internal Revenue Service penalties and overturned underlying agency guidance, rejecting a magistrate judge's recommendation that the company foot its own bill.
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November 04, 2024
Ukrainian Pleads To $11M Tax Fraud, Immigration Scheme
A Ukrainian national charged for immigration fraud and money laundering has pled guilty and could face 20 years in prison, the U.S. Justice Department announced.
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November 04, 2024
Justices Won't Hear UBS Suit Over Disclosed Account Info
The U.S. Supreme Court declined Monday to hear a couple's suit accusing UBS of fraudulently flagging an account to the Internal Revenue Service in violation of civil provisions under the Racketeer Influenced and Corrupt Organizations Act.
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November 04, 2024
Justices Let Stand Bar On Late-Filed Returns In Bankruptcy
The U.S. Supreme Court said Monday it would let stand a Ninth Circuit decision finding late-filed returns prevented a taxpayer from discharging his federal tax debt in bankruptcy, rejecting the taxpayer's request to resolve what he described as a significant circuit split.
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November 04, 2024
IRS Finalizes Seized Property Rules To Include Online Sales
The Internal Revenue Service issued final rules Monday meant to modernize regulations governing the seizure of property by levy, including facilitating the online sale of a property and the agency's ability to maximize sale proceeds for the property owner's benefit.
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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
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.
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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
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.
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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.
Expert Analysis
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Why Attorneys Should Consider Community Leadership Roles
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.
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Firms Must Offer A Trifecta Of Services In Post-Chevron World
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.
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5 Tips To Succeed In A Master Of Laws Program And Beyond
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.
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Pros, Cons Of Disclosing Improper Employee Retention Credit
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.
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How Law Firms Can Avoid 'Collaboration Drag'
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.
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Litigation Funding Disclosure Key To Open, Impartial Process
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.
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Whistleblowers Must Note 5 Key Differences Of DOJ Program
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.
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What NFL Draft Picks Have In Common With Lateral Law Hires
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.
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Replacing The Stigma Of Menopause With Law Firm Support
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.
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Planning Law Firm Content Calendars: What, When, Where
During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.
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Brownfield Questions Surround IRS Tax Credit Bonus
Though the IRS has published guidance regarding the Inflation Reduction Act's 10% adder for tax credits generated by renewable energy projects constructed on brownfield sites, considerable guesswork remains as potential implications seem contrary to IRS intentions, say Megan Caldwell and Jon Micah Goeller at Husch Blackwell.
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Law Firms Should Move From Reactive To Proactive Marketing
Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.
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The Big Issues A BigLaw Associates' Union Could Address
A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.