Federal
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October 24, 2024
IRS To End Automatic Foreign Gift Reporting Penalty
Internal Revenue Service Commissioner Danny Werfel told the UCLA Tax Controversy Conference audience on Thursday that the agency will no longer automatically assess penalties for the late reporting of large foreign gifts, with the announcement eliciting applause from the audience of several hundred tax attorneys and tax professionals.
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October 24, 2024
Couple Owes Tax, Frivolous Arguments Penalty, 9th Circ. Says
The U.S. Tax Court correctly found that a Washington couple who repeatedly filed frivolous returns and claimed their wages are tax-free owe about $9,000 in taxes for 2017 and 2018, the Ninth Circuit said Thursday.
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October 24, 2024
Tax Court Affirms Rejection Of $94K In Deduction Claims
The Internal Revenue Service correctly disallowed a couple's nearly $94,000 in claimed individual and business deductions, the U.S. Tax Court said Thursday, while also finding them liable for nearly $11,000 in accuracy-related penalties.
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October 24, 2024
IRS Forming Transfer Pricing Team To Aid Real-Time Audits
The Internal Revenue Service is establishing a dedicated team to tackle transfer pricing issues that arise in real-time audits of companies participating in its compliance assurance process program, which should allow those issues to be handled more efficiently, an agency official said Thursday.
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October 24, 2024
Tax Court Nixes IRS Agent's $126K In Deductions
An Internal Revenue Service agent is not entitled to $126,000 in deductions for supposed medical expenses and charitable donations, the U.S. Tax Court ruled Thursday, saying the worker couldn't prove the payments were actually made.
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October 24, 2024
Defunct Yoga Biz Co-Owner Cops To Tax-Dodging Conspiracy
A Seattle-area computer programmer who co-owned the defunct Yoga to the People business told a Manhattan federal judge on Thursday that he schemed to short the IRS on over $4 million of income, copping to a tax fraud conspiracy count.
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October 24, 2024
IRS Proposes Rules To Calculate Efficient Home Energy Credit
The Internal Revenue Service proposed rules Thursday for calculating a homeowner tax credit for improving energy efficiency and released guidance for manufacturers of improvement products that have complained about a government registration system set to take effect next year.
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October 24, 2024
Ex-Moody's GC Gets Prison For Tax-Filing Fail On $54M In Pay
The former general counsel for Moody's Corp. was sentenced Thursday to eight months in prison for willfully failing to file federal income tax returns for four years in which he collected $54 million in income.
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October 24, 2024
MVP: Sidley Austin's Rachel D. Kleinberg
Rachel D. Kleinberg, a co-leader of the global tax practice at Sidley Austin LLP, headed up a tax team to represent investors in a consortium that led to the $6.05 billion sale of the NFL's Washington Commanders, earning her a spot as one of the 2024 Law360 Tax MVPs.
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October 24, 2024
IRS Schedules November Advisory Council Meeting
The Internal Revenue Service Advisory Council will hold its next meeting Nov. 20, the agency announced Thursday.
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October 23, 2024
IRS To Split Pass-Through, Energy Credit Work Into 2 Units
The IRS is planning to split up its Pass-Throughs and Special Industries office into two separate divisions, including one that will focus in part on energy credits enacted under the 2022 landmark climate law, an agency official said Wednesday.
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October 23, 2024
Tax Court Says Trucker Can't Deduct Reimbursed Expenses
The Internal Revenue Service correctly disallowed a Georgia truck driver's unreimbursed business expense deduction claims, because he was in fact reimbursed for the various expenses, the U.S. Tax Court said Wednesday.
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October 23, 2024
Microsemi's Fines Mostly Adhered To Rules, Tax Court Says
The Internal Revenue Service obtained the proper written approval of penalties on most of the tax code violations it brought against semiconductor manufacturer Microsemi but left room for doubt on two penalties, the U.S. Tax Court said.
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October 23, 2024
Foley & Lardner Adds Burr & Forman Corporate Duo In Fla.
Foley & Lardner LLP has ramped up its innovative technology sector and transactions practice group with two former Burr & Forman LLP partners in Jacksonville, Florida, where a Foley & Lardner leader said their arrival aligned with the firm's strategic focus on four key sectors of the economy.
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October 23, 2024
9th Circ. Orders Michael Avenatti To Be Resentenced
The Ninth Circuit on Wednesday ordered the resentencing of Michael Avenatti over his California conviction for tax violations and stealing from clients, saying the lower court made multiple mistakes when it handed down a 14-year prison term to the onetime celebrity attorney.
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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.
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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.
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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.
Wyden's Pharma Probe Could Build Case For Int'l Tax Reforms
Senate Finance Committee Chairman Ron Wyden's investigation into the tax planning of major U.S. pharmaceutical companies could help fuel an effort to revamp U.S. international tax laws next year when Congress addresses expiring provisions of the Tax Cuts and Jobs Act.
Mining Eligible In Final Regs For Energy Manufacturing Credit
The U.S. Treasury Department's final rules released Thursday on a valuable tax credit for manufacturing key components and materials used in clean energy technologies allow producers to take into account the costs to mine and extract critical minerals.
CPAs Prepare For Uncertainty As TCJA Expiration Looms
Certified public accountants and financial planners are preparing to help their clients navigate the uncertainty around next year's expiration of major parts of the Tax Cuts and Jobs Act as lawmakers gear up to decide who will bear the brunt of any resulting tax changes.
Featured Stories
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Wyden's Pharma Probe Could Build Case For Int'l Tax Reforms
Senate Finance Committee Chairman Ron Wyden's investigation into the tax planning of major U.S. pharmaceutical companies could help fuel an effort to revamp U.S. international tax laws next year when Congress addresses expiring provisions of the Tax Cuts and Jobs Act.
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CPAs Prepare For Uncertainty As TCJA Expiration Looms
Certified public accountants and financial planners are preparing to help their clients navigate the uncertainty around next year's expiration of major parts of the Tax Cuts and Jobs Act as lawmakers gear up to decide who will bear the brunt of any resulting tax changes.
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New ABA Tax Chair-Elect Aims To Expand Leadership Paths
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.
Expert Analysis
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Tariffs' Economic Downsides Outweigh Potential Revenue
Import tariffs proposed by the campaign of former president Donald Trump would generate revenue like other taxes, but policymakers must consider the net-negative impact of associated consumer and downstream-industry costs, harm to exporters, potential foreign retaliation and reduction in economic output, says Erica York at the Tax Foundation.
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Navigating The Last Leg Of The Worker Retention Tax Credit
Whether a business has applied for the pandemic-era employee retention tax credit, received a denial letter or is still considering making a claim before the April 15 deadline, it should examine recent developments significantly affecting the program before planning next steps, say attorneys at Nixon Peabody.
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How Cos. Can Build A Strong In-House Pro Bono Program
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.
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Home Canning Makes Me A Better Lawyer
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.
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
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.
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Congress Can And Must Enact A Supreme Court Ethics Code
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.
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What To Make Of Dueling Corporate Transparency Act Rulings
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.
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Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan
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.
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State Of The States' AI Legal Ethics Landscape
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.
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8 Childhood Lessons That Can Help You Be A Better Attorney
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.
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How The 2025 Tax Policy Debate Will Affect The Energy Sector
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.
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This Election, We Need To Talk About Court Process
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.
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Mental Health First Aid: A Brief Primer For Attorneys
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.