Federal
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September 23, 2024
More Needed On Energy Tax Credit Monetization, TIGTA Says
The Internal Revenue Service has taken steps to facilitate the sale or transfer of the Inflation Reduction Act's clean energy tax credits, but it must develop more processes to accommodate the credits, the Treasury Inspector General for Tax Administration reported.
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September 23, 2024
Senate Confirms 3rd Tax Court Judge In 2 Months
The U.S. Senate approved one of President Joe Biden's nominees to serve on the U.S. Tax Court on Monday, marking the third time the chamber has confirmed a judge to the court in the past two months.
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September 23, 2024
Tax Court Allows Woman's Gambling Loss Deduction
A California woman made good-faith attempts to substantiate her gambling losses and therefore may claim a roughly $62,000 tax deduction, but she is still liable for an accuracy-related penalty for the year in question, the U.S. Tax Court said Monday.
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September 23, 2024
DOJ Seeing Deluge Of Attacks In Tax Cases After Loper Bright
The U.S. Department of Justice's Tax Division is seeing its casework flooded with taxpayer arguments citing the U.S. Supreme Court's decision in Loper Bright overturning the Chevron doctrine, and that's not likely to change soon, a division chief said Monday.
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September 23, 2024
Vanguard Agrees To Settle Investors' Tax Liability Suit
Vanguard agreed to settle a proposed class action by investors who accused the company of violating its fiduciary duties when it triggered a sell-off of assets that left them with massive tax bills, according to a Pennsylvania federal court order Monday.
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September 23, 2024
Profs, Retired Judges Ask Justices To Uphold Return Of Taxes
Two former bankruptcy judges and a group of law professors threw their support behind the bankruptcy trustee of a Utah transportation company seeking to convince the U.S. Supreme Court that the IRS, like any other creditor, should have to return payments deemed fraudulent under state law.
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September 23, 2024
IRS Finalizing Pricing Pact Guidance, Official Says
The Internal Revenue Service is in the final stages of updating revenue procedures to help multinational corporations pursue advance pricing agreements and resolve tax treaty disputes, and it will release the guidance soon, an agency official said Monday.
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September 23, 2024
IRS Names Chief Of Appeals Office
The Internal Revenue Service elevated the acting chief of its Independent Office of Appeals to the position permanently, the agency announced Monday.
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September 23, 2024
Squire Patton Tax Ace Joins Winston & Strawn In Dallas
Winston & Strawn LLP announced Monday it has expanded its tax offerings with the addition of an experienced attorney from Squire Patton Boggs LLP in Texas.
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September 23, 2024
Julie Chrisley Fights For Sentence Cut After 11th Circ. Ruling
Former reality TV star Julie Chrisley asked a Georgia federal judge on Friday to resentence her to no more than five years for her role in a $36 million tax evasion and fraud scheme, arguing against prosecutors' insistence that the seven-year sentence she was previously given be kept intact.
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September 20, 2024
Family Owes $81M Taxes On 'Son-Of-Boss' Scheme, DOJ Says
Former shareholders of a family-owned holding company owe the IRS nearly $81 million for participating in what is known as a Son-of-Boss arrangement, which generated fake capital losses in the 2022 sale of company stock, the U.S. Department of Justice told a New York federal court.
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September 20, 2024
8th Circ. To Hear Args In 3M's $24M Tax Case Next Month
The Eighth Circuit said Friday that it will hear oral arguments next month in 3M's transfer pricing appeal, in which the multinational conglomerate is challenging the Internal Revenue Service's authority to reallocate to the company $24 million from a Brazilian affiliate.
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September 20, 2024
IRS Updates Per-Diem Deduction Rates For Business Travel
The per-diem rates used to compute business travel expense tax deductions will be $319 for travel to high-cost areas and $225 for travel to low-cost areas starting in October, the Internal Revenue Service said Friday.
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September 20, 2024
Divestiture Counts As Reorganization, IRS Says
A domestic corporation with some foreign shareholders that is required to divest itself of one of its businesses by using a newly created corporation as an intermediary for the distribution qualifies as a tax-free reorganization, the IRS said in a private letter ruling released Friday.
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September 20, 2024
IRS Special Trial Attorney Joins Hochman Salkin In California
When Hochman Salkin Toscher Perez PC's newest principal, Sebastian Voth, was studying at Emory University School of Law, a former chief counsel for the Internal Revenue Service told students that the IRS was a great place to start their careers. After 15 years as an IRS attorney, Voth found that the agency was also a great place to work, he told Law360 Pulse in an interview Friday.
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September 20, 2024
IRS Not Meeting Disclosure Requirements For Joint Returns
The Internal Revenue Service did not uniformly follow joint return disclosure requirements on collection information requests, burdening taxpayers with additional delays resolving their tax matters and possibly violating their privacy rights, the Treasury Inspector General for Tax Administration said Friday.
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September 20, 2024
Tribe's Stateless Status Undoes $1.9M Construction Suit
A Massachusetts federal judge on Thursday tossed a New York construction company's $1.9 million lawsuit against the Mashpee Wampanoag Tribe, finding the tribe's stateless position leaves the court with no jurisdiction to decide the case.
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September 20, 2024
Taxation With Representation: Gibson Dunn, Holland & Knight
In this week's Taxation With Representation, CACI International buys Azure Summit Technology, Hotel Engine lands a valuation led by Permira, and Knowles Corp. sells its microphone business to Syntiant Corp.
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September 20, 2024
IRS Must Credit Overpayments, Couple Tell 5th Circ.
A couple claiming they should be allowed to sue the IRS for a roughly $500,000 tax refund in federal court because they overpaid their taxes told the Fifth Circuit that the agency is out of time to challenge their overpayments and must credit their account.
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September 20, 2024
IRS Corrects Proposed Clean Electricity Bonus Credit Regs
The Internal Revenue Service issued corrections Friday to proposed regulations that would broaden the types of power facilities that could be eligible for clean electricity low-income community bonus credit amounts starting in 2025.
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September 20, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included proposed regulations that would adjust the timing for when companies could opt to use the so-called mark-to-market accounting method for gains or losses that arise from foreign currency transactions.
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September 19, 2024
Ch. 7 Trustee Urges Justices To Uphold Return Of Taxes
The bankruptcy trustee of a defunct Utah transportation company warned the U.S. Supreme Court on Thursday that overturning a decision forcing the IRS to return tax payments made by company directors to cover their personal debts would encourage shareholder fraud.
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September 19, 2024
Convicted Drexel Professor Won't Get New Tax Evasion Trial
A Drexel University accounting professor was denied a new trial after being convicted on tax evasion charges for failing to report $3.3 million in income from a Trenton pharmacy, a New Jersey federal judge has ruled, reasoning that the professor's case was not prejudiced by keeping accounting records related to his tax returns from the jury.
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September 19, 2024
House Bill Proposes Tax Incentives For Military Housing
A bill introduced in the U.S. House of Representatives would seek to increase the availability and affordability of housing for service members in part by excluding the military's basic housing allowance from the income calculation for the low-income housing tax credit.
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September 19, 2024
Calif. Says FDIC's $20M Tax Refund Bid Must Wait
A California tax collection agency asked a New York federal court to throw out Federal Deposit Insurance Corp. claims seeking a more than $20 million tax refund on behalf of the shuttered Signature Bank, saying the agency is entitled to wait for a potential IRS audit to end.
Expert Analysis
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A Post-Mortem Analysis Of Stroock's Demise
After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.
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SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
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Planning A Defense As IRS Kicks Off Sports Losses Campaign
Sports team owners and partnerships face potential examination under the Internal Revenue Service’s recently announced sports industry losses campaign, and should be preparing to explain what drove their reported losses and assembling documentation to support their tax return positions and accounting methods, say Sheri Dillon and Jennifer Breen at Morgan Lewis.
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What New Calif. Strike Force Means For White Collar Crimes
The recently announced Central District of California strike force targeting complex corporate and securities fraud — following the Northern District of California's model — combines experienced prosecutorial leadership and partnerships with federal agencies like the IRS and FBI, and could result in an uptick in the number of cases and speed of proceedings, say attorneys at MoFo.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.
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As Promised, IRS Is Coming For Crypto Tax Evaders
The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.
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5 Reasons Associates Shouldn't Take A Job Just For Money
As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.
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Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules
Regulations recently proposed by the IRS and the U.S. Department of the Treasury concerning two types of tax credits for clean hydrogen production facilities should resolve many of the most pressing questions around qualification for the credits — albeit in a relatively stringent manner, say attorneys at Morgan Lewis.
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Employee Experience Strategy Can Boost Law Firm Success
Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.
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6 Practice Pointers For Pro Bono Immigration Practice
An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.
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Lessons From Country Singer's Personal Service Saga
Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.