Federal

  • September 06, 2024

    FDII Covers Overseas Services For US Gov't, Memo Says

    Government contractors that provide services to U.S. operations overseas are allowed to claim the deduction for foreign-derived intangible income, the IRS said in one of two internal memos released Friday that address foreign income issues.

  • September 06, 2024

    IRS Project Collected $172M From Rich Nonfilers In 6 Months

    About 21,000 wealthy taxpayers who had failed to file tax returns since 2017 have paid $172 million in taxes under a project the Internal Revenue Service launched in February, the agency and the U.S. Department of the Treasury announced Friday.

  • September 06, 2024

    4 Key Complications 3 Years After Pillar 2

    Three years ago, countries around the world outlined an agreed-upon minimum corporate tax system in an eight-page document that couldn't have foreseen the full scope of complications that later emerged during implementation, including frictions with existing tax laws. Here, Law360 looks at four key issues that countries and multinational corporations are grappling with as Pillar Two turns three.

  • September 06, 2024

    IRS Issues 2025 Table For Premium Tax Credit Calculations

    The Internal Revenue Service published the table used to determine the 2025 premium tax credit Friday.

  • September 06, 2024

    Taxation With Representation: Debevoise, Bennett, Orrick

    In this week's Taxation With Representation, Verizon reaches a deal to absorb Frontier in a deal worth $20 billion, First Majestic agrees to buy Gatos Silver for $970 million, and Epam Systems inks a $630 million purchase of Neoris.

  • September 06, 2024

    Man Disguised Businesses To Duck Tax, US Says In $1.9M Suit

    A retired business owner who the U.S. government said removed his mailbox to avoid receiving letters from the IRS owes nearly $1.9 million in unpaid tax liabilities, some stemming from pretending to operate his companies as religious ministries, the government said in a suit in Florida federal court.

  • September 06, 2024

    Vialto Partners Member Joins Baker McKenzie As Partner

    Baker McKenzie has hired a tax partner in Washington, D.C., from Vialto Partners, a business consulting firm, the firm announced Thursday.

  • September 06, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included updated interest rates for overpayments and underpayments of tax for the fourth quarter of 2024.

  • September 05, 2024

    Unconstitutionality Of Transparency Act Clear, 11th Circ. Told

    A small business group and one of its members have told the Eleventh Circuit that an Alabama federal judge correctly ruled that the Corporate Transparency Act is unconstitutional, so there was no need for them to demonstrate that the law fails to pass constitutional muster.

  • September 05, 2024

    Liberty Global Urges 10th Circ. To Grant $248M Tax Credit

    The U.S. Tax Court improperly applied an Internal Revenue Code provision to some of the $2.8 billion gain from Liberty Global's sale of a Japanese entity, the telecommunications company said in urging the Tenth Circuit to overturn the resulting rejection of a $248 million tax credit.

  • September 05, 2024

    Holland & Knight Appoints Former Perkins Coie Tax Partner

    Holland & Knight LLP appointed a partner to its Portland, Oregon, office who previously served as a partner in energy tax law for Perkins Coie LLP, the firm announced.

  • September 05, 2024

    $70M Bill Came Too Late, Tax Court Says In Tossing IRS Claim

    Partners in a subscription business don't owe around $70 million in taxes as the IRS claimed because the agency notified them too late and couldn't extend the deadline by proving the partners had filed fraudulent returns, the U.S. Tax Court said in rulings Thursday.

  • September 05, 2024

    Sen. Finance Panel To Hold Hearing On Tax Policy, Avoidance

    The Senate Finance Committee will hold a hearing Sept. 12 covering the 2025 tax policy debate and tax avoidance strategies, it announced Thursday.

  • September 05, 2024

    CPAs Seek Guidance On Business Interest Expense Deduction

    The American Institute of Certified Public Accountants requested Thursday that the Internal Revenue Service and U.S. Treasury Department issue guidance clarifying that new limits on business interest expenses included in the 2017 federal tax overhaul apply after an election to capitalize interest expenses.

  • September 05, 2024

    Two Sentenced To Prison In $111M Tax Fraud Scheme

    Two members of a crime ring who admitted to participating in a $111 million tax fraud scheme involving stealing the identities of accountants and taxpayers were sentenced to prison, according to Texas federal court documents.

  • September 05, 2024

    IRS Seeks Input On Treasury Retirement Match Contributions

    The Internal Revenue Service said Thursday it is looking for comments regarding two portions of the Secure 2.0 Act of 2022 related to matching contributions paid by the U.S. Treasury Department to certain retirement savings vehicles for eligible people who make qualified contributions.

  • September 05, 2024

    Hunter Biden Pleads Guilty To Tax Charges In Surprise Move

    Hunter Biden entered a surprise guilty plea to nine criminal tax charges in California federal court on Thursday, bringing a dramatic conclusion to the case following a dizzying series of events on what was set to be the first day of his trial.

  • September 04, 2024

    Judge Chides IRS, Preparers Over $167M Refund For ID Fees

    A D.C. federal judge has declined to approve the IRS' roughly $167 million refund proposal for a putative class of tax-return preparers for charging them excessive fees for special identification numbers, saying the agency failed to address problems the preparers raised with its calculations.

  • September 04, 2024

    IRS' Economic Substance Authority Has Limits, Tax Court Told

    The U.S. Tax Court and other federal courts have the authority to conduct an initial analysis of a transaction in cases where the Internal Revenue Service is challenging the economic substance of the transaction, a manufacturers advocacy group said Wednesday in an amicus brief.

  • September 04, 2024

    Harris Floats Capital Gains Tax Hike To 28% For High Earners

    The tax on long-term capital gains would increase to 28% from 20% for taxpayers who earn $1 million or more under a proposal unveiled Wednesday by Vice President and Democratic presidential nominee Kamala Harris ahead of a campaign rally in New Hampshire.

  • September 04, 2024

    Woman Owes Taxes On Share Of Sold Biz, Tax Court Says

    A woman whose ex-husband told a bankruptcy court that he was the sole owner of a business they had started together was actually a 50% shareholder when it was sold and is liable for capital gains, the U.S. Tax Court ruled Wednesday.

  • September 04, 2024

    Tax Court OKs $465K Gambling Losses Deduction Amount

    An Indiana woman adequately proved she had more than $465,000 in substantiated gambling losses over six years, the U.S. Tax Court said Wednesday, though she failed to substantiate her claimed business losses.

  • September 04, 2024

    Warren Urges IRS To Look At Possible REIT Tax Break Abuse

    The Internal Revenue Service should increase its scrutiny of real estate investment trusts to determine whether companies are benefiting from REIT tax benefits while flouting rules, including those that limit the level of a REIT's ownership in a company, Sen. Elizabeth Warren told the agency's commissioner.

  • September 04, 2024

    Maryland Joining IRS Direct File Next Year

    Maryland will join the IRS' free electronic tax filing program known as Direct File in 2025, the U.S. Department of the Treasury and the Internal Revenue Service announced Wednesday.

  • September 04, 2024

    Ex-Mass. Pol 'A Little Sloppy' But Not Criminal, Jurors Told

    Former Massachusetts state Sen. Dean A. Tran denied charges Wednesday that he stole pandemic unemployment assistance and cheated on his taxes, with his attorney telling a jury that Tran simply made a series of paperwork "mistakes."

Expert Analysis

  • How Law Firms Can Use Account-Based Marketing Strategies

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    Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.

  • While Risks Exist, AI Could Transform IRS Enforcement

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    The Internal Revenue Service's recently announced use of artificial intelligence could revolutionize the agency's enforcement efforts, and transparency about its use and a forum for challenging AI findings could help mitigate fears that the technology will increase bias, say attorneys at Lewis Brisbois.

  • Strategic Succession Planning At Law Firms Is Crucial

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    Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.

  • Maximizing Law Firm Profitability In Uncertain Times

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    As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • How Gov't Agencies Will Fare In The Event Of A Shutdown

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    With a federal shutdown potentially set to begin at the end of this month, it may be useful to consider the approximate timelines that agencies such as the Federal Trade Commission and IRS have announced for curtailing operations, and potential strategies for mitigating challenges that may arise while agency functions are limited, say attorneys at Cleary.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

  • Kentucky Tax Talk: Taking Up The Dormant Commerce Clause

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    Attorneys at Frost Brown examine whether the U.S. Supreme Court is likely to review Foresight Coal Sales v. Kent Chandler to consider whether a Kentucky utility rate law discriminates against interstate commerce, and how the decision may affect dormant commerce clause jurisprudence.

  • Prevailing Wage Rules Complicate Inflation Act Tax Incentives

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    Nicole Elliott and Timothy Taylor at Holland & Knight discuss the intersection between tax and labor newly created by the Inflation Reduction Act, and focus on aspects of recent U.S. Department of Labor and U.S. Department of the Treasury rules that may catch tax-incentive seekers off guard.

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