Federal

  • 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. 

  • September 19, 2024

    Death Doesn't Preclude FBAR Penalties, Judge Says

    The death of a U.S. citizen who failed to file reports of foreign bank and financial accounts doesn't stop the U.S. government from enforcing penalties against his estate, a New York federal judge ruled.

  • September 19, 2024

    Senate Tees Up Vote On Tax Court Nominee

    The U.S. Senate set the stage Thursday to proceed with a vote on one of President Joe Biden's picks to fill an open seat on the U.S. Tax Court.

  • September 19, 2024

    GAO Says IRS Can Be Better Prepped For Reporting Changes

    While the Internal Revenue Service could collect billions thanks to recent reporting requirement changes, particularly those related to cryptocurrency, the agency needs to take further steps to be prepared for the changes, the Government Accountability Office said Thursday.

  • September 19, 2024

    H&R Block Again Asks 8th Circ. To Remove ALJs In Ad Suit

    H&R Block asked the Eighth Circuit to reconsider its denial of the company's request to stop administrative law judges from presiding over its coming false-advertising hearing before the Federal Trade Commission, saying the court's one-sentence ruling lacked any explanation despite the significant constitutional issues involved.

  • September 19, 2024

    IRS Warns Taxpayers Of Offer-In-Compromise 'Mills'

    The IRS urged taxpayers to be careful about working with promoters that claim to provide necessary services in order to comply with the agency's offer-in-compromise program, saying Thursday that these "mills" only bring "empty promises and steep costs."

  • September 18, 2024

    Tax Chiefs Eye Crypto Payment Cos., OTC Traders, IRS Says

    Tax investigators in the U.S., U.K., Canada, Australia and the Netherlands are preparing guidance on red flags for cryptocurrency payment providers and over-the-counter trading desks following a joint operation this week, a special agent with the Internal Revenue Service said Wednesday.

  • September 18, 2024

    IRS Publishes Guidance For Issuers Of Tax-Exempt Bonds

    The Internal Revenue Service published guidance Wednesday for issuers of tax-exempt and other tax-advantaged bonds in terms of procedures for filing claims for recovery of overpayments of rebate payments and other processes.

  • September 18, 2024

    Dems Block Bill Targeting Foreign Funding Of Campaign Gifts

    Democrats blocked the House of Representatives from sending legislation to the Senate that would restrict contributions to political committees by tax-exempt entities that receive foreign funds.

  • September 18, 2024

    Tax Court Wrongly Denied Premium Deduction, 5th Circ. Told

    A Texas couple asked the Fifth Circuit on Wednesday to reverse a U.S. Tax Court decision denying their bid to deduct more than $1 million in premiums paid to insurance companies they owned, arguing the Tax Court misclassified underlying insurance arrangements.

  • September 18, 2024

    IRS On Track With Updated Tool, But Some Risk Remains

    While the IRS' project modernizing its individual tax processing engine met its performance goals ahead of the updated system's planned 2025 rollout, the ending of a process for solving issues between the new and old systems creates greater risk, the Treasury Inspector General for Tax Administration said Wednesday.

  • September 18, 2024

    Jury Finds Eatery Owner Guilty Of COVID Fraud, Tax Crimes

    A San Diego restaurant owner who worked with food delivery services during the pandemic and saw his business improve was convicted by a California federal jury of tax crimes and lying on loan applications to obtain more than $1.7 million in COVID-19 funds meant for struggling businesses.

  • September 18, 2024

    House GOP Vows Blowback Over OECD's Min. Tax Backstop

    House Republicans again warned the OECD that Congress will retaliate against countries that implement a backstop measure to the 15% global minimum tax, saying China will cheat the system and it will cost U.S. taxpayers about $120 billion.

  • September 18, 2024

    Tips Lead To $263M IRS Settlement In Offshore Evasion Case

    Tips from three whistleblowers have led to the IRS reaching a $263 million settlement with a taxpayer in an offshore tax evasion case, concluding one of the largest-ever tax whistleblower cases, a law firm involved in the case said Wednesday.

  • September 18, 2024

    IRS Delays Deadlines For Pa. Victims Of Tropical Storm

    Taxpayers in four Pennsylvania counties will have until Feb. 3, 2025, to file individual and business tax returns and make payments after portions of the state were hit by Tropical Storm Debby, the Internal Revenue Service said Wednesday.

  • September 18, 2024

    Treasury Floats Tax Credit Regs For EV Charging Property

    The U.S. Treasury Department proposed regulations Wednesday to define which electric vehicle charging ports, hydrogen fueling stations and other infrastructure that businesses, people and tax-exempt entities can build in underserved communities to qualify for a tax credit of up to 30% of installation costs.

Expert Analysis

  • Anticipating Intensified Partnership Enforcement From IRS

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    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

  • Newman Suspension Shows Need For Judicial Reform

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    The recent suspension of U.S. Circuit Judge Pauline Newman following her alleged refusal to participate in a disability inquiry reveals the need for judicial misconduct reforms to ensure that judges step down when they can no longer serve effectively, says Aliza Shatzman at The Legal Accountability Project.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

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    Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • 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.

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