Federal

  • October 23, 2024

    ABA Tax Section Pushes IRS To Narrow Pillar 2 Regulations

    Proposed regulations outlining when foreign taxes under the Pillar Two international minimum tax agreement trigger U.S. rules against benefiting twice from the same economic loss should be narrowed to limit their applicability, the American Bar Association Tax Section told the IRS.

  • October 23, 2024

    IRS Grants Tax-Exempt Entities Relief From Corp. AMT Filing

    Tax-exempt entities are not obligated to file the corporate alternative minimum tax form for the 2023 tax year with the Internal Revenue Service, but they should still maintain the document for recordkeeping purposes, the agency announced Wednesday. 

  • October 23, 2024

    Judge Threatens To Toss Gov't's $4.9M Son-Of-Boss Claim

    A federal judge warned government attorneys Wednesday that she would dismiss their case against an estate for $4.9 million in taxes if they didn't explain why they weren't actively pursuing their accusations that a Michigan couple schemed to artificially cancel out capital gains

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The Federal Trade Commission has come to an agreement with H&R Block to settle claims of deceptive advertising and has withdrawn its complaint in order for the full commission to vote on the deal.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

    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

    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

    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

    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.

Featured Stories

  • New ABA Tax Chair-Elect Aims To Expand Leadership Paths

    Kat Lucero

    The new chair-elect of the American Bar Association Section of Taxation told Law360 that she wants to broaden the pathways to leadership for members, including those early in their careers, as part of the section's diversity, equity and inclusion initiatives. Here, Megan Brackney shares more about her background and goals for the section.

  • New ABA Tax Chair Wants To Revamp Practice's Dry Image

    Kat Lucero

    The new chair of the American Bar Association Section of Taxation told Law360 she wants to boost the section's recent efforts to revamp the tax practice's image as a boring, numbers-intensive profession with limited opportunities to improve society and inspire more students to enter tax law. Here, she shares her background and goals for the tax section.

  • Disputes May Loom Over Dividend Deductions For CFCs

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    U.S. multinational corporations are concerned that rulemakers' interpretation of a law allowing tax-free repatriation of certain overseas earnings could lead to controversy after the Internal Revenue Service published a memo indicating the break is unavailable for controlled foreign corporations.

Expert Analysis

  • How Cos. Can Build A Strong In-House Pro Bono Program

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    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.

  • 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.

  • Use The Right Kind Of Feedback To Help Gen Z Attorneys

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    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.

  • Congress Can And Must Enact A Supreme Court Ethics Code

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    As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.

  • What To Make Of Dueling Corporate Transparency Act Rulings

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    Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.

  • Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan

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    Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.

  • State Of The States' AI Legal Ethics Landscape

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    Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.

  • 8 Childhood Lessons That Can Help You Be A Better Attorney

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    A new school year is underway, marking a fitting time for attorneys to reflect on some fundamental life lessons from early childhood that offer a framework for problems that no legal textbook can solve, say Chris Gismondi and Chris Campbell at DLA Piper.

  • How The 2025 Tax Policy Debate Will Affect The Energy Sector

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    Regardless of the outcome of the upcoming U.S. election, 2025 will bring a major tax policy debate that could affect the energy sector more than any other part of the economy — so stakeholders who could be affected should be engaging now to make sure they understand the stakes, say attorneys at Mayer Brown.

  • This Election, We Need To Talk About Court Process

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    In recent decades, the U.S. Supreme Court has markedly transformed judicial processes — from summary judgment standards to notice pleadings — which has, in turn, affected individuals’ substantive rights, and we need to consider how the upcoming presidential election may continue this pattern, says Reuben Guttman at Guttman Buschner.

  • Mental Health First Aid: A Brief Primer For Attorneys

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    Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.

  • The Trade And Tax Issues Behind US-Canada Digital Tax Clash

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    The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.

  • Litigation Inspiration: Honoring Your Learned Profession

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    About 30,000 people who took the bar exam in July will learn they passed this fall, marking a fitting time for all attorneys to remember that they are members in a specialty club of learned professionals — and the more they can keep this in mind, the more benefits they will see, says Bennett Rawicki at Hilgers Graben.