Federal

  • December 16, 2024

    Tax Court Wrongly Cut Easement Deduction, 11th Circ. Told

    The U.S. Tax Court erred in drastically reducing a partnership's claimed $23 million deduction for donating a conservation easement in Georgia, the partnership told the Eleventh Circuit, saying the court improperly relied on a real estate expert's opinion to establish whether the land had mining value.

  • December 16, 2024

    Cos. Urge Judge To Maintain Injunction On Transparency Law

    A Texas federal judge doesn't need to stay his preliminary injunction on the rollout of new corporate transparency rules while the U.S. government's appeal of his decision is pending at the Fifth Circuit, a business lobbying group and others said Monday.

  • December 16, 2024

    Wyden Bill Would Nix Tax Perks For Private Placement Plans

    U.S. Senate Finance Committee Chairman Ron Wyden unveiled legislation Monday that would remove the tax benefits of a special type of private life insurance plan that he said high-net-worth individuals have been abusing to avoid paying taxes on their investments in the policies.

  • December 16, 2024

    High Court Passes On Protest Of IRS Social Security Levy

    The U.S. Supreme Court said Monday it won't review an Eleventh Circuit decision denying a woman's challenge to the IRS' garnishment of her Social Security payments, letting stand the circuit court's conclusion that her suit was barred because she failed to exhaust administrative remedies.

  • December 16, 2024

    Applicable Federal Rates Set To Increase Again In Jan.

    Applicable federal rates for income tax purposes will increase across the board in January, a second straight month of increases after a string of months that saw declining rates, the Internal Revenue Service said Monday.

  • December 16, 2024

    Justices Won't Review Man's Demand For Dad's Tax Info

    The U.S. Supreme Court on Monday let stand a D.C. Circuit decision tossing a man's suit against the IRS for withholding his dead father's tax records, a ruling the man claimed had deepened a circuit split over the correct process for obtaining personal tax documents.

  • December 16, 2024

    IRS Issues Corp. Bond Monthly Yield Curve For Dec.

    The Internal Revenue Service published the corporate bond monthly yield curve for December for use in calculations for defined benefit plans Monday, as well as corresponding segment rates and other related provisions.

  • December 16, 2024

    IRS Corrects Regs On Direct Pay Of Partnership Tax Credit

    Internal Revenue Service issued a correction Monday to final regulations that make it easier for tax-exempt entities that co-own development projects to qualify for a direct cash payment of clean energy tax credits by electing out of their partnership tax status.

  • December 16, 2024

    LegalZoom Launches Strategic Alliance With 1-800Accountant

    LegalZoom announced Monday that it will launch a multiyear strategic partnership with financial services firm 1-800Accountant by the start of the new year.

  • December 14, 2024

    IRS Criminal Probes On Worker Retention Cases Still Early

    The Internal Revenue Service's criminal arm is still in the early stage of investigating the most extremely fraudulent claims of a tax credit intended to reward businesses for retaining employees during the COVID-19 pandemic, an official said Saturday.

  • December 13, 2024

    IRS Aims To Ramp Up Partnership Audits, Official Says

    The Internal Revenue Service plans to ramp up partnership audits in the next couple of years to boost the current audit rate of 0.05% as the agency props up a new unit that solely focuses on examining large partnerships, an agency attorney said Friday.

  • December 13, 2024

    IRS To Wrap Up Worker Retention Credits In 2025, Werfel Says

    The Internal Revenue Service plans to wrap up processing next year for thousands of claims for tax credits meant to provide incentives for businesses that retained employees during the COVID-19 pandemic, agency Commissioner Daniel Werfel said Friday.

  • December 13, 2024

    IRS Extends Relief For Partnership Exchange Filing Penalties

    The Internal Revenue Service on Friday extended its temporary pause on imposing penalties on taxpayers who failed to provide correct payee statements as part of a partnership interest exchange to those that failed to do so in 2024.

  • December 13, 2024

    CFC Tax Issues Can't Be Solved Via Treaties, Officials Say

    Bilateral treaties between the U.S. and other countries where a controlled foreign corporation may face withholding tax issues aren't able to effectively resolve those disputes, Internal Revenue Service and Treasury officials said Friday.

  • December 13, 2024

    IRS Mulls Turning Off Foreign Currency Rules For CFCs

    The Internal Revenue Service is in the early stages of considering whether foreign currency gain or loss recognition rules could be turned off in certain situations for controlled foreign corporations, an agency official said Friday.

  • December 13, 2024

    Feds Narrow Drug Case Against Wife Of Convicted Drexel Prof

    Prosecutors have told a New Jersey federal judge that they would drop one of three drug distribution charges against the wife of a convicted former Drexel University professor, saying their evidence might not establish intent after the U.S. Supreme Court raised the burden of proof for such cases in 2022.

  • December 13, 2024

    Halliburton Consistent On Claims For $35M Refund, Court Told

    Halliburton has not changed its reasons for claiming a tax refund on a $35 million payment it made to a foreign government to protect its employees from harassment, the company told a Texas federal court, saying the U.S. wrongly accused it of a flip-flop.

  • December 13, 2024

    Taxation With Representation: Kirkland, Davis Polk, Wachtell

    In this week's Taxation With Representation, Google and TPG Rise Climate partner with Intersect Power, Gen Digital Inc. acquires MoneyLion Inc., Patient Square Capital acquires Patterson Companies Inc., and the Buffalo Bills and Miami Dolphins sell minority ownership shares to private equity firms.

  • December 13, 2024

    Contractor Loses Bail For Texting Alleged Tax Cheat Allies

    A District of Columbia federal judge revoked bail for a former defense contractor accused of running a $350 million tax-evasion scheme that prosecutors call one of the largest in U.S. history, after the government said he'd been texting his alleged co-conspirators.

  • December 13, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included final regulations for the advanced manufacturing production credit for manufacturing key components and materials used in clean energy technologies.

  • December 13, 2024

    Loper Bright May Influence Tax Less, IRS Chief Counsel Says

    The U.S. Supreme Court decision this year overturning a decades-long standard to defer to federal agencies' regulatory interpretations has encouraged the Internal Revenue Service to better explain its rules, its outgoing chief counsel said Friday.

  • December 12, 2024

    'Housewives' Figure Touts Social Media Posts In Leniency Bid

    Former "Real Housewives of Atlanta" cast member Peter Anthony Thomas asked a North Carolina federal judge on Thursday to give him a prison sentence below federal guidelines for not paying $2.5 million in employment taxes, stating he has used his public platform to encourage his followers to pay their own taxes.

  • December 12, 2024

    Bitcoin Investor Gets 2 Years For Tax Fraud In Landmark Case

    An investor who concealed millions of dollars he earned in bitcoin and became the first person criminally charged for failing to report gains from the sale of cryptocurrency by filing false returns was sentenced to two years in federal prison Thursday.

  • December 12, 2024

    IRS Wants Choice Retained In Dual Loss Rules, Official Says

    The Internal Revenue Service is working to preserve flexibility for taxpayers in rules aimed at preventing companies from using the same economic loss twice after concerns were raised about how the rules could negatively interact with the Pillar Two global minimum tax, an official said Thursday.

  • December 12, 2024

    IRS Seeks Feedback On Limits In Previous Taxed Profit Rules

    The Internal Revenue Service will consider whether rules included in recently proposed guidance on previously taxed earnings and profits to limit instances where U.S. multinationals may use basis to offset gain are too restrictive, an official said Thursday.

Expert Analysis

  • Striking A Balance Between AI Use And Attorney Well-Being

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    As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.

  • Takeaways From The IRS' Crypto Doc Summons Win

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    A recent First Circuit decision holding that taxpayers do not have a Fourth Amendment reasonable expectation of privacy in cryptocurrency transaction records should prompt both taxpayers and exchanges to take stock of past transactions and future plans, say attorneys at BakerHostetler.

  • How Judiciary Can Minimize AI Risks In Secondary Sources

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    Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.

  • How Attorneys Can Break Free From Career Enmeshment

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    Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.

  • Ex-Chicago Politician's Case May Further Curb Fraud Theories

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    The U.S. Supreme Court recently agreed to hear Thompson v. U.S. to determine whether a statement that is misleading but not false still violates federal law, potentially heralding the court’s largest check yet on prosecutors’ expansive fraud theories, with significant implications for sentencing, say attorneys at the Law Offices of Alan Ellis.

  • Lawyers With Disabilities Are Seeking Equity, Not Pity

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    Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.

  • Judicial Committee Best Venue For Litigation Funding Rules

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    The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.

  • The Strategic Advantages Of Appointing A Law Firm CEO

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    The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.

  • Tariffs' Economic Downsides Outweigh Potential Revenue

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    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.

  • Navigating The Last Leg Of The Worker Retention Tax Credit

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    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.

  • How Cos. Can Build A Strong In-House Pro Bono Program

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    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.

  • Home Canning Makes Me A Better Lawyer

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    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.

  • Use The Right Kind Of Feedback To Help Gen Z Attorneys

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    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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