Federal

  • December 13, 2024

    Feds Narrow Drug Case Against Wife Of Convicted Drexel Prof

    Prosecutors have told a New Jersey federal judge that they would drop one of three drug distribution charges against the wife of a convicted former Drexel University professor, saying their evidence might not establish intent after the U.S. Supreme Court raised the burden of proof for such cases in 2022.

  • December 13, 2024

    Halliburton Consistent On Claims For $35M Refund, Court Told

    Halliburton has not changed its reasons for claiming a tax refund on a $35 million payment it made to a foreign government to protect its employees from harassment, the company told a Texas federal court, saying the U.S. wrongly accused it of a flip-flop.

  • December 13, 2024

    Taxation With Representation: Kirkland, Davis Polk, Wachtell

    In this week's Taxation With Representation, Google and TPG Rise Climate partner with Intersect Power, Gen Digital Inc. acquires MoneyLion Inc., Patient Square Capital acquires Patterson Companies Inc., and the Buffalo Bills and Miami Dolphins sell minority ownership shares to private equity firms.

  • December 13, 2024

    Contractor Loses Bail For Texting Alleged Tax Cheat Allies

    A District of Columbia federal judge revoked bail for a former defense contractor accused of running a $350 million tax-evasion scheme that prosecutors call one of the largest in U.S. history, after the government said he'd been texting his alleged co-conspirators.

  • December 13, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included final regulations for the advanced manufacturing production credit for manufacturing key components and materials used in clean energy technologies.

  • December 13, 2024

    Loper Bright May Influence Tax Less, IRS Chief Counsel Says

    The U.S. Supreme Court decision this year overturning a decades-long standard to defer to federal agencies' regulatory interpretations has encouraged the Internal Revenue Service to better explain its rules, its outgoing chief counsel said Friday.

  • December 12, 2024

    'Housewives' Figure Touts Social Media Posts In Leniency Bid

    Former "Real Housewives of Atlanta" cast member Peter Anthony Thomas asked a North Carolina federal judge on Thursday to give him a prison sentence below federal guidelines for not paying $2.5 million in employment taxes, stating he has used his public platform to encourage his followers to pay their own taxes.

  • December 12, 2024

    Bitcoin Investor Gets 2 Years For Tax Fraud In Landmark Case

    An investor who concealed millions of dollars he earned in bitcoin and became the first person criminally charged for failing to report gains from the sale of cryptocurrency by filing false returns was sentenced to two years in federal prison Thursday.

  • December 12, 2024

    IRS Wants Choice Retained In Dual Loss Rules, Official Says

    The Internal Revenue Service is working to preserve flexibility for taxpayers in rules aimed at preventing companies from using the same economic loss twice after concerns were raised about how the rules could negatively interact with the Pillar Two global minimum tax, an official said Thursday.

  • December 12, 2024

    IRS Seeks Feedback On Limits In Previous Taxed Profit Rules

    The Internal Revenue Service will consider whether rules included in recently proposed guidance on previously taxed earnings and profits to limit instances where U.S. multinationals may use basis to offset gain are too restrictive, an official said Thursday.

  • December 12, 2024

    IRS Chief Makes Case To Restore $20B Funding Shortfall

    Congress should reverse a $20 billion IRS funding gap in a year-end budget bill to help the agency modernize its technology, improve customer service and collect unpaid taxes from wealthy businesses and individuals, Internal Revenue Commissioner Daniel Werfel said Thursday.

  • December 12, 2024

    2nd Circ. Won't Rethink Dual Citizen's FBAR Penalties

    The Second Circuit will not review its September decision finding that a dual U.S.-French citizen is liable for tax penalties for failing to file reports of foreign bank and financial accounts, the court said Thursday.

  • December 12, 2024

    IRS Expands Business Tax Account Program To Corp. Leaders

    The Internal Revenue Service's business tax account online self-service tool is now available to C corporations, while the agency is opening access to the program to certain officers of both C and S corporations, the agency said Thursday.

  • December 12, 2024

    IRS Hopes To Issue Amount B Pricing Guidance Within Weeks

    Treasury is working to finish its guidance on the simplified transfer pricing approach to baseline marketing and distribution known as Amount B by the end of the year, a U.S. official said Thursday.

  • December 12, 2024

    Ex-FBI Informant Admits To False Accusations In Biden Case

    A former FBI informant accused of making fake criminal accusations against President Joe Biden and his son, Hunter Biden, will plead guilty to tax evasion and falsifying records in a federal investigation, according to a deal filed Thursday in a California federal court.

  • December 12, 2024

    Treasury Seeks To Pause Anti-Laundering Law Injunction

    The U.S. Treasury Department asked a Texas federal judge to pause his nationwide preliminary injunction of the Corporate Transparency Act pending an appeal of his recent decision that found Congress likely overstepped its constitutional authority when it wrote the anti-money laundering law.

  • December 12, 2024

    IRS Electronic Tax Committee To Meet In January

    The Internal Revenue Service's Electronic Tax Administration Advisory Committee will hold its next meeting Jan. 8, the agency said Thursday.

  • December 11, 2024

    Bloomberg Entitled To Use $4B In Receipts For Deductions

    Bloomberg incorrectly allocated gross receipts between software and services related to access to the Bloomberg Terminal, its interactive financial analysis product, but the company ultimately had $4.1 billion in gross receipts that could be used to calculate a deduction for domestic production from 2008 to 2010, the U.S. Tax Court found Wednesday.

  • December 11, 2024

    Temp Agency Owner Gets Prison For $2M Tax Scheme

    A temp agency owner was sentenced to a year and a day in prison after pleading guilty in Massachusetts federal court to paying employees under-the-table wages to avoid $2.1 million in taxes.

  • December 11, 2024

    Tax Preparers Fabricated Expenses, US Says

    Two tax preparers and their company should be barred from owning or operating tax preparation services because they fabricated business income and expenses for clients, the federal government told a Texas federal court.

  • December 11, 2024

    Exxon Tax Ruling Doesn't Help Liberty Global, 10th Circ. Told

    Liberty Global cannot use a recent ruling that allowed Exxon Mobil a tax deduction for interest payments to claim a deduction for dividends that arose from its intragroup shuffling of a Belgian affiliate, the U.S. government told the Tenth Circuit on Wednesday.

  • December 11, 2024

    Beyoncé Fends Off Most Of $3M Tax Bill In Deal With IRS

    Pop star Beyoncé owes only about $700 of what the IRS had claimed was $3 million in outstanding taxes and penalties, according to a U.S. Tax Court ruling Wednesday that approved a settlement between the star and the agency.

  • December 11, 2024

    17M Won't Benefit From Full Child Tax Credit, Report Says

    Roughly 17 million children under 17 — or roughly a quarter of all U.S. children — will live in families that cannot claim the full child tax credit in 2025 because they make too little, the Urban-Brookings Tax Policy Center said in a report.

  • December 11, 2024

    Judge Orders Home Sale To Pay Down $1.7M Tax Debt

    A California federal judge ordered the private sale of a deceased couple's home to pay down a $700,000 tax bill that has been accruing interest for 20 years and now stands at roughly $1.7 million.

  • December 10, 2024

    FinCEN Says CTA Still Constitutional In Post-Injunction Alert

    The Financial Crimes Enforcement Network has alerted companies that they do not currently need to file so-called beneficial ownership information with the agency after a federal judge's nationwide preliminary injunction blocking the Corporate Transparency Act, though the bureau maintained that the law calling for such information is constitutional.

Expert Analysis

  • Reading Between The Lines Of Justices' Moore Ruling

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    The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.

  • A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates

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    Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.

  • States Should Loosen Law Firm Ownership Restrictions

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    Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.

  • After Chevron: Uniform Tax Law Interpretation Not Guaranteed

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    The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.

  • Texas Ethics Opinion Flags Hazards Of Unauthorized Practice

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    The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • How High Court Approached Time Limit On Reg Challenges

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    The U.S. Supreme Court's decision in Corner Post v. Federal Reserve Board effectively gives new entities their own personal statute of limitations to challenge rules and regulations, and Justice Brett Kavanaugh's concurrence may portend the court's view that those entities do not need to be directly regulated, say attorneys at Snell & Wilmer.

  • How To Clean Up Your Generative AI-Produced Legal Drafts

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    As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.

  • A Tale Of 2 Trump Cases: The Rule Of Law Is A Live Issue

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    The U.S. Supreme Court’s decision this week in Trump v. U.S., holding that former President Donald Trump has broad immunity from prosecution, undercuts the rule of law, while the former president’s New York hush money conviction vindicates it in eight key ways, says David Postel at Henein Hutchison.

  • Industry Self-Regulation Will Shine Post-Chevron

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    The U.S. Supreme Court's Loper decision will shape the contours of industry self-regulation in the years to come, providing opportunities for this often-misunderstood practice, says Eric Reicin at BBB National Programs.

  • 3 Ways Agencies Will Keep Making Law After Chevron

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    The U.S. Supreme Court clearly thinks it has done something big in overturning the Chevron precedent that had given deference to agencies' statutory interpretations, but regulated parties have to consider how agencies retain significant power to shape the law and its meaning, say attorneys at K&L Gates.

  • Atty Well-Being Efforts Ignore Root Causes Of The Problem

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    The legal industry is engaged in a critical conversation about lawyers' mental health, but current attorney well-being programs primarily focus on helping lawyers cope with the stress of excessive workloads, instead of examining whether this work culture is even fundamentally compatible with lawyer well-being, says Jonathan Baum at Avenir Guild.

  • Tracking Implementation Of IRA Programs As Election Nears

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    As the Biden administration races to cement key regulations implementing the Inflation Reduction Act, a number of the law's programs and incentives are at risk of delay or repeal if Republicans retake control of Congress, the White House or both — so stakeholders should closely watch ongoing IRA implementation and guidance, say attorneys at Squire Patton.

  • Unpacking The Circuit Split Over A Federal Atty Fee Rule

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    Federal circuit courts that have addressed Rule 41(d) of the Federal Rules of Civil Procedure are split as to whether attorney fees are included as part of the costs of a previously dismissed action, so practitioners aiming to recover or avoid fees should tailor arguments to the appropriate court, says Joseph Myles and Lionel Lavenue at Finnegan.

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