Federal

  • October 04, 2024

    Taxation With Representation: Gibson Dunn, Weil, Simpson

    In this week's Taxation with Representation, DirectTV buys EchoStar's video business for $10 billion, Marsh McLennan inks a $7.75 billion deal for McGriff Insurance, and PepsiCo closes a $1.2 billion deal to purchase Siete Foods.

  • October 04, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included proposed regulations that would define which electric vehicle charging ports and other similar infrastructure that taxpayers can build in underserved communities to qualify for a tax credit.

  • October 03, 2024

    12 Lawyers Who Are The Future Of The Supreme Court Bar

    One attorney hasn't lost a single U.S. Supreme Court case she's argued, or even a single justice's vote. One attorney is perhaps "the preeminent SCOTUS advocate." And one may soon become U.S. solicitor general, despite acknowledging there are "judges out there who don't like me." All three are among a dozen lawyers in the vanguard of the Supreme Court bar's next generation, poised to follow in the footsteps of the bar's current icons.

  • October 03, 2024

    US Partnership Excluded From Tax Treaty, Irish Court Says

    A Delaware corporation with three Irish subsidiaries must pay Irish taxes on distributions to its U.S. partners because a U.S.-Ireland tax treaty designed to prevent double taxation does not apply, the Irish High Court ruled.

  • October 03, 2024

    Assisted Living Owner Can't Deduct Losses, Tax Court Says

    The owner of an assisted living company may not deduct passive losses for a group home he renovated because he spent too few hours working on repairs to qualify as a real estate professional, the U.S. Tax Court ruled Thursday.

  • October 03, 2024

    TIGTA Says $12.9B In Early Distributions Missing Added Tax

    Roughly 2.8 million taxpayers in 2021 received early retirement distributions totaling $12.9 billion but did not pay the additional 10% tax or file for an exception, the Treasury Inspector General for Tax Administration said Thursday.

  • October 03, 2024

    Bankruptcy Doesn't Pause Tipster's Case, Tax Court Says

    A tax tipster's bankruptcy filing doesn't pause his U.S. Tax Court case challenging the Internal Revenue Service's denial of his request for a whistleblower award, the Tax Court ruled Thursday, saying the award case doesn't concern his tax liability.

  • October 03, 2024

    IRS Expanding Scope Of Free Online Tax-Filing Program

    The Internal Revenue Service will expand its free online tax-filing program to accommodate more types of income, credits and deductions in 2025, Commissioner Daniel Werfel said Thursday.

  • October 03, 2024

    3M Tells 8th Circ. Chevron's End Dooms IRS In $24M Dispute

    Multinational conglomerate 3M said Thursday that the U.S. Supreme Court's striking down of Chevron deference dictates that the Eighth Circuit overturn a U.S. Tax Court decision that supported the IRS' reallocation of $24 million from the company's Brazilian affiliate.

  • October 03, 2024

    IRS Used $2B Of Funding Boost For Operating Expenses

    The IRS has used $2 billion of the funding boost it received under the Inflation Reduction Act to supplement its annual funding, according to the Treasury Inspector General for Tax Administration.

  • October 03, 2024

    IRS Missing Out On $1.4B In Taxes On Gambling Winnings

    The Internal Revenue Service's failure to enforce income tax filing requirements for recipients of a form to report gambling winnings has cost it an estimated roughly $1.4 billion in additional tax revenue, the Treasury Inspector General for Tax Administration said Thursday.

  • October 03, 2024

    IRS Issues Part-Time Worker 403(b) Retirement Plan Guidance

    The Internal Revenue Service and U.S. Treasury Department published guidance Thursday on how long-term, part-time employees' Internal Revenue Code Section 403(b) retirement plans will be affected by the Secure 2.0 Act of 2022, which will apply to such plans starting in 2025.

  • October 03, 2024

    K&L Gates Boosts Houston Shop With Ernst & Young Tax Ace

    K&L Gates LLP strengthened its Houston office this week with the hire of a tax partner with nearly three decades of expertise in advising multinational corporations on U.S. taxation on cross-border acquisitions and other transactions.

  • October 03, 2024

    Calif. Can't Delay Bank's $20.7M Tax Refund, FDIC Tells Court

    A California tax collection agency shouldn't be allowed to delay a $20.7 million tax refund it owes the shuttered Signature Bank, the Federal Deposit Insurance Corp. told a New York federal court, saying that as the bank's receiver, it's entitled to the money now.

  • October 03, 2024

    Tax Deadlines Delayed For Victims Of Wash. Reservation Fires

    Taxpayers on the Yakama Nation's reservation in Washington state will have until Feb. 3 to file individual and business tax returns and make payments following wildfires, the Internal Revenue Service said Thursday.

  • October 03, 2024

    Ch. 7 Invalidates $4M Worker Retention Credit Suit, Gov't Says

    A road construction company can't sue the Internal Revenue Service for a tax refund for pandemic-era worker credits because its claims stemmed from Chapter 7 bankruptcy proceedings, the federal government told a Florida federal court.

  • October 02, 2024

    NY Man Posed As Exec To Steal $810K Tax Refund, Feds Say

    A New York man has been charged with intercepting an unnamed Connecticut investment firm's $810,337 tax refund and then impersonating an executive of the company to steal most of it.

  • October 02, 2024

    IRS Makes Progress On Retention Credit Fraud, TIGTA Says

    The IRS has made multiple improvements to address false claims for the COVID-19-era employee retention credit, including updating messaging and beefing up certain tax return filters to identify problematic claims, but there is still room for improvement, the Treasury Inspector General for Tax Administration said Wednesday.

  • October 02, 2024

    Stopgap Gov't Funding Law May Hinder IRS Improvements

    The IRS may need to redirect funds from its 2022 funding boost intended for agency improvements in order to cover routine operations, reducing funds available for planned upgrade projects, due to the stopgap appropriations bill Congress passed last week.

  • October 02, 2024

    9th Circ. Upholds 14 Years For Ex-Deputy's Tax, Fraud Crimes

    A former sheriff's deputy who was ordered to pay $7.6 million in restitution and sentenced to 14 years in prison for tax crimes and wire fraud lost his bid to vacate his sentence Wednesday when the Ninth Circuit decided he wasn't unfairly denied a new attorney.

  • October 02, 2024

    IRS Says European Energy Exchange Is A Qualified Exchange

    The European Energy Exchange is a qualified board or exchange for purposes of mark-to-market contracts under Internal Revenue Code Section 1256(g)(7)(C), the Internal Revenue Service said Wednesday. 

  • October 02, 2024

    IRS Too Lax On Tax Prep Partners' Data Practices, TIGTA Says

    The IRS isn't doing enough to oversee the data protection practices of the tax preparation businesses in its Free File program and has never removed a partner from the program despite some having been sanctioned for unauthorized disclosures of taxpayer information, the Treasury Inspector General for Tax Administration said Wednesday.

  • October 02, 2024

    US Seeks To Drop $1M Tax Suit Against Sleep Clinic Founder

    The U.S. government seeks to drop its case against a sleep clinic founder and his wife, whom it had accused of hiding assets, after the couple agreed to pay their tax liabilities in full, according to a filing in California federal court Wednesday.

  • October 01, 2024

    VP Nominees Vance, Walz Spar Over Tax Cuts

    Vice presidential candidates Sen. J.D. Vance, R-Ohio, and Gov. Tim Walz, D-Mich., laid out their plans for federal tax cuts to create affordable housing and child care, spark new business growth and increase manufacturing during a nationally televised debate Tuesday night.

  • October 01, 2024

    IRS Delays Deadlines, Grants Other Relief Following Helene

    Taxpayers in all or part of seven states will have until May 1 to file individual and business tax returns and make payments after Hurricane Helene hit the area, the Internal Revenue Service said Tuesday, while also granting dyed diesel penalty relief as well.

Expert Analysis

  • Money, Money, Money: Limiting White Collar Wealth Evidence

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    As courts increasingly recognize that allowing unfettered evidence of wealth could prejudice a jury against a defendant, white collar defense counsel should consider several avenues for excluding visual evidence of a lavish lifestyle at trial, says Jonathan Porter at Husch Blackwell.

  • How Associates Can Build A Professional Image

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    As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.

  • Navigating New Safe Harbor For Domestic Content Tax Credits

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    The U.S. Department of the Treasury’s recent notice simplifying domestic content calculations for certain solar, onshore wind and battery storage projects, which directly acknowledges the difficulty for taxpayers in gathering data to support a domestic content analysis, should make it easier to qualify additional domestic content bonus tax credits, say attorneys at A&O Shearman.

  • Firms Must Rethink How They Train New Lawyers In AI Age

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    As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.

  • 'Energy Communities' Update May Clarify Tax Credit Eligibility

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    A recent IRS notice that includes updated lists of locations where clean energy projects can qualify for additional tax credits — based 2023 unemployment data and placed-in-service dates — should help provide clarity regarding project eligibility that sponsors and developers need, say attorneys at Troutman Pepper.

  • Think Like A Lawyer: Always Be Closing

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    When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.

  • How Cannabis Rescheduling May Alter Paraphernalia Imports

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    The Biden administration's recent proposal to loosen federal restrictions on marijuana use raises questions about how U.S. Customs and Border Protection enforcement policies may shift when it comes to enforcing a separate federal ban on marijuana accessory imports, says R. Kevin Williams at Clark Hill.

  • NCAA Settlement May End The NIL Model As We Know It

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    The recent House v. NCAA settlement in California federal court, in which the NCAA agreed to allow schools to directly pay March Madness television revenue to their athletes, may send outside name, image and likeness collectives in-house, says Mike Ingersoll at Womble Bond.

  • Fishing Makes Me A Better Lawyer

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    Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.

  • A Healthier Legal Industry Starts With Emotional Intelligence

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    The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.

  • To Make Your Legal Writing Clear, Emulate A Master Chef

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    To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.

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