Federal

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • A Proposal For Fairer, More Efficient Innocent Spouse Relief

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    Adding a simple election to the current regulatory framework for innocent spouse claims would benefit both taxpayers and the Internal Revenue Service by alleviating the undue burdens placed on those the program was intended to help and improving agency collections in such cases, says Laurie Kazenoff at Kazenoff Tax.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • Proposed Hydrogen Tax Credit Regs May Be Legally Flawed

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    While the recently proposed regulations for the new clean hydrogen production tax credit have been lauded by some in the environmental community, it is unclear whether they are sufficiently grounded in law, result from valid rulemaking processes, or accord with other administrative law principles, say Hunter Johnston and Steven Dixon at Steptoe.

  • Navigating ACA Reporting Nuances As Deadlines Loom

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    Stephanie Lowe at Liebert Cassidy walks employers through need-to-know elements of Affordable Care Act reporting, including two quickly approaching deadlines, the updated affordability threshold, strategies for choosing an affordability safe harbor, and common coding pitfalls.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • Why Biz Groups Disagree On Ending Chevron Deference

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    Two amicus briefs filed in advance of last month's U.S. Supreme Court oral arguments in Loper Bright Enterprises v. Raimondo highlight contrasting views on whether the doctrine of Chevron deference promotes or undermines the stable regulatory environment that businesses require, say Wyatt Kendall and Sydney Brogden at Morris Manning.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Look Ahead For The Electric Vehicle Charging Industry

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    This will likely be an eventful year for the electric vehicle market as government efforts to accelerate their adoption inevitably clash with backlash from supporters of the petroleum industry, say Rue Phillips at SkillFusion and Enid Joffe at Green Paradigm Consulting.

  • A Post-Mortem Analysis Of Stroock's Demise

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    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.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    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.

  • Planning A Defense As IRS Kicks Off Sports Losses Campaign

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    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.

  • What New Calif. Strike Force Means For White Collar Crimes

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    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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