Federal
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September 25, 2024
Direct File Needs Security, Testing Improvements, TIGTA Says
While the deployment of the Internal Revenue Service's pilot of its free online Direct File program was largely successful, the agency must address some security lapses and testing deficiencies, the Treasury Inspector General for Tax Administration said Wednesday.
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September 25, 2024
Basis-Shifting Regs May Add Accounting Fixes, IRS Atty Says
The Internal Revenue Service may include in upcoming proposed regulations a solution for partnership basis-shifting for taxpayers that want to adjust accounting methods so prior transactions can be compliant with economic substance laws, an agency attorney said Wednesday.
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September 25, 2024
Wyden Calls On 2025 Tax Bill To Include Partnership Reform
Lawmakers should consider next year how to revise partnership tax laws to better collect on large businesses' income without harming smaller entities as Congress debates over how to address expiring tax provisions, Senate Finance Committee Chairman Ron Wyden said Wednesday.
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September 25, 2024
House Bill Proposes Housing Incentive For Disabled Veterans
A bill introduced in the U.S. House of Representatives would exclude veteran disability benefits from the income calculation for the low-income housing tax credit.
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September 25, 2024
Chicago School Contractor Loses Energy Efficiency Tax Break
The owner of a Chicago-based electrical contracting company isn't entitled to an over $459,000 tax refund for upgrading Chicago Public Schools buildings with energy-efficient lighting because his company didn't design the systems, only installed them, an Illinois federal judge ruled.
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September 25, 2024
Puerto Rico Seeking Input On Implementing Global Min. Tax
Puerto Rico's Department of the Treasury is looking for public comments regarding possible implementation of the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities.
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September 24, 2024
1st Circ. Affirms Tossing Of IRS Crypto Doc Seizure Case
A New Hampshire federal court correctly dismissed a bitcoin investor's claim that the IRS violated his privacy and property rights when it seized his records from the cryptocurrency exchange Coinbase, the First Circuit ruled Tuesday, agreeing that he lacked a reasonable expectation that his account information would be kept private.
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September 24, 2024
Estate's Value Shouldn't Be Increased, Tax Court Says
The estate of a Maryland doctor who died in a car accident does not have to increase its taxable value by more than $19 million to account for the proceeds of two life insurance policies held by a family trust, the U.S. Tax Court ruled Tuesday.
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September 24, 2024
Halliburton Tardy In Contesting $35M Deduction, US Says
A Halliburton Co. lawsuit claiming a deduction for a $35 million payoff to a foreign country must be dismissed because the company waited too long to start its action, the U.S. told a Texas federal court.
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September 24, 2024
IRS Received $226K In Prohibited Levy Payments In 2023
The Internal Revenue Service collected more than $226,000 in levy payments in the 2023 fiscal year in collection due process cases that involved prohibited levies, but affected taxpayers were made whole, according to a watchdog report released Tuesday.
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September 24, 2024
IRS Largely Complies With Levy Requirements, TIGTA Says
A review of more than 48,000 levies issued by IRS field collection officers from July 2022 through June 2023 found that they were mostly compliant with both legal and administrative requirements, but the Treasury Inspector General for Tax Administration identified over 1,900 instances of noncompliance, it said Tuesday.
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September 24, 2024
Digital Asset Rules Coming By Year's End, Treasury Atty Says
The U.S. Treasury Department and the Internal Revenue Service intend to release rules "later this year" on additional reporting requirements for brokers of digital assets such as cryptocurrency and nonfungible tokens, a senior Treasury attorney said Tuesday.
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September 24, 2024
Wyden, House Dem Float Small-Biz Wage, Investment Credits
Senate Finance Committee Chairman Ron Wyden and a House Democratic tax writer proposed legislation that would provide small-business wage and investment tax credits, according to a Tuesday statement.
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September 24, 2024
Abbott Seeks $24M Refund Over Transfer Pricing Adjustments
Healthcare products giant Abbott Laboratories is owed $24.3 million for overpaid taxes after the IRS incorrectly adjusted its intragroup income and payments this year, the company told the U.S. Tax Court in a petition.
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September 24, 2024
Defunct Cannabis Co. Says It's Owed $1.4M In Worker Credits
A Seattle cannabis company that was administratively dissolved this year is entitled to roughly $1.4 million in tax credits for continuing to pay employees when its business dropped off during the COVID-19 pandemic, the company's receivership estate told a Washington federal court.
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September 24, 2024
IRS Wary Of Adding Complexity In Min. Tax Regs, Official Says
The IRS opted to use existing tax rules in proposed guidance to address risks that the U.S. corporate alternative minimum tax could count offshore income twice, an agency official said Tuesday, noting a more precise method would increase complexity.
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September 24, 2024
Treasury To Allow 3 AMT Transition Methods, Official Says
Final rules on the new corporate alternative minimum tax are expected to adopt the proposed regulations' three ways for companies to transition to the regime, and the U.S. Treasury Department is open to other ways as well, a department official said Tuesday.
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September 24, 2024
Insurer Wants Quick Appeal At 8th Circ. In DOL Tax Fight
A health insurer will seek the Eighth Circuit's review after a federal judge refused to toss a suit from the U.S. Department of Labor claiming the company unlawfully took at least $66.8 million in Minnesota state tax liability from plans it administered to pay in-network providers.
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September 24, 2024
Exxon Claims It Beat Weak Defense In $1.8B Tax Trial
Exxon Mobil urged a Texas federal judge to find that it defeated what it called a scattered defense by the U.S. government during a five-day bench trial in April when the company argued for a $1.8 billion tax refund on its natural gas deal with Qatar, according to newly released filings.
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September 24, 2024
Applications For Low-Income Energy Tax Breaks Due In Oct.
With more than 50,000 applications for the low-income communities clean energy bonus credit program submitted, three U.S. government agencies announced Tuesday that they will be accepting applications on a rolling basis for most categories through Oct. 10 to make sure they are timely processed.
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September 24, 2024
Tax Data Consent Practices Need Shoring Up, TIGTA Says
The Internal Revenue Service must take steps to make sure any tax software companies that collect taxpayer information include consent statements that are clear about the intended purpose of the disclosure of that information and the specific recipients of it, the Treasury Inspector General for Tax Administration said.
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September 24, 2024
Miller & Chevalier Adds Federal Tax Expert From White & Case
Miller & Chevalier Chtd. announced that it added a former partner at White & Case LLP to its tax controversy and litigation practice.
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September 23, 2024
Clean Energy Safe Harbor Applies To Direct Pay, Official Says
The safe harbor for the bonus clean energy tax credits' domestic content rules applies to all applicable project owners, including tax-exempt entities that are eligible to get a direct cash payment of the credits, a U.S. Treasury Department attorney said Monday.
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September 23, 2024
Energy Bonus Credit Penalty Guidance Coming, Atty Says
The U.S. Treasury Department will soon release additional guidance on penalties for clean energy developers that initially failed to meet the prevailing wage requirements tied to claiming bonus tax credits on their development projects, a Treasury attorney said Monday.
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September 23, 2024
Some Former IRS Contractors Not Purged From Systems
An analysis of over 1,800 former Internal Revenue Service contractors who were incorrectly listed as active found a number of them still possessed network permissions, IRS hardware or identification cards giving them access to agency facilities, the Treasury Inspector General for Tax Administration said Monday.
Expert Analysis
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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.
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7 E-Discovery Predictions For 2024 And Beyond
The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.