Federal

  • June 07, 2024

    No Loss On Terminated Rate Agreements, Chief Counsel Says

    A company that executed forward-rate agreements cannot claim a loss in connection with the termination of the agreements because its adjusted basis in the agreements was zero, according to a memo released Friday by the IRS Office of Chief Counsel.

  • June 07, 2024

    IRS Updates EV Battery Reporting Guide For Tax Credits

    The Internal Revenue Service provided updated guidance Friday for automakers planning to provide a report on meeting the battery sourcing requirements that can qualify their new electric vehicle models for the consumer tax credit of up to $7,500.

  • June 07, 2024

    6th Circ. Finds Ethical Lapses Justify Bar On Firm's Outreach

    The Sixth Circuit said Thursday a Michigan federal judge shouldn't have faulted a law firm for attacking a proposed tax foreclosure class-action settlement in solicitation letters, but nevertheless upheld the judge's order barring contact with certain class members because of the firm's actual ethical lapses.

  • June 07, 2024

    Subsidiary Won't Lose Status Before Dissolving, IRS Says

    A court-ordered liquidation of an insurance company won't cause it to lose its status as a corporation before it completes its final dissolution, the Internal Revenue Service said in a private letter ruling released Friday.

  • June 07, 2024

    Dentons Adds Pair Of Husch Blackwell Tax Attys

    Two South Carolina tax attorneys have joined Dentons' corporate, tax and private client practice as partners after moving from Husch Blackwell LLP, the firm announced on Thursday.

  • June 07, 2024

    IRS Scrutinizing Hospitals' Tax Exemptions, Official Says

    The Internal Revenue Service's Tax-Exempt & Government Entities Division has started auditing tax-exempt hospitals to ensure they're complying with exemption requirements, an agency official said Friday.

  • June 07, 2024

    Halliburton Wrongly Denied $11.3M Deduction, Court Told

    The Internal Revenue Service is arbitrarily and wrongfully refusing to refund Halliburton over $11.3 million in tax deductions taken for a payment to a foreign government to secure the safety of the company's employees, Halliburton told a federal court.

  • June 07, 2024

    Fed. Circ. Panel Doubts Bid To Nix Actavis' $12M Deduction

    A Federal Circuit panel seemed skeptical of the government's bid to overturn a decision allowing drugmaker Actavis to deduct $12 million it spent fending off lawsuits as it secured approval to sell generics, raising the question during oral arguments Friday whether the company was being uniquely targeted.

  • June 07, 2024

    Taxation With Representation: Vinson, Latham, Ropes & Gray

    In this Week's Taxation with Representation, Waste Management buys Stericycle, Becton Dickinson pays $4.2 billion for Edwards Lifesciences' critical care products unit, Aquiline Capital Partners raises over $3.4 billion in fund capital, and Bain Capital buys PowerSchool Holdings.

  • June 07, 2024

    IRS Lists Shuttered Coal Areas For Energy Bonus Credits

    The Internal Revenue Service on Friday issued updated lists of areas, including closed coal mines and factories, where developers can qualify for additional tax credits for building their clean energy projects.

  • June 07, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, which included proposed foreign trust transaction reporting requirements.

  • June 06, 2024

    Medtronic Urges 8th Circ. To Back Its Transfer Pricing Method

    Medical device maker Medtronic reiterated Thursday its bid for the Eighth Circuit to revive its method for pricing intangible property that was licensed to a Puerto Rican affiliate, arguing the government's concessions show why the company's approach is more reliable.

  • June 06, 2024

    9th Circ. Denies Trust Refund Of Money Forfeited To IRS

    A trust lost its ownership claims to property when an Idaho federal court determined the property had been transferred to the trust fraudulently, the Ninth Circuit said Thursday, affirming a decision to deny a $225,000 tax refund.

  • June 06, 2024

    Estate Entitled To Deduct Payouts To Stepkids, 11th Circ. Told

    The U.S. Tax Court wrongly denied deductions to a former attorney's $81 million estate for million-dollar payouts it made to his stepchildren after they sued, the estate told the Eleventh Circuit, saying the payments satisfied legitimate claims against the estate and were therefore deductible.

  • June 06, 2024

    Tax Court Upholds Rejection Of Man's Biz Deductions

    A Floridian failed to adequately back up certain business loss deduction claims made on his tax return, the U.S. Tax Court said Thursday, backing the IRS' rejection of the claims and imposition of an accuracy-related penalty.

  • June 06, 2024

    'Brothel' Manager Violated Bail After $5.7M Sting, Feds Say

    A manager and bookkeeper facing federal charges connected to a COVID-19 grant and tax fraud scheme at a Connecticut strip club violated his bail conditions by showing up at the facility and "hanging out" with a potential witness, federal probation authorities have alleged.

  • June 06, 2024

    9th Circ. Won't Revive Org's Push To Restore Nonprofit Status

    The U.S. Tax Court's dismissal of an attempt to reinstate nonprofit status for a California organization that said its officers fell victim to a Ponzi scheme did not breach the group's constitutional rights, the Ninth Circuit said.

  • June 06, 2024

    Ex-IRS Worker Indicted In $2M Exxon Credit Theft Scheme

    A former Internal Revenue Service employee used his account management job at the agency to steal more than $2 million worth of tax credits from Exxon Mobil and pocket the money, according to a Utah federal grand jury indictment.

  • June 06, 2024

    Fox Rothschild Brings On Tax Pro From Atlanta Boutique

    Fox Rothschild LLP has added an attorney in Atlanta from tax law boutique Wiggam Law to strengthen the firm's taxation and wealth planning department.

  • June 06, 2024

    IRS Needs Strategy For 2.6M Tax Doc Backlog, TIGTA Says

    Not only does the Internal Revenue Service have a document backlog exceeding 2.6 million source documents that need to be associated with a specific form, but it also has been making significant mistakes in reporting closures, the Treasury Inspector General for Tax Administration said in a report released Thursday.

  • June 06, 2024

    Justices Affirm Taxing Of Estate On Insurance Payout

    The U.S. Supreme Court affirmed on Thursday a decision denying a tax refund to the estate of an owner of a building materials company that used a payout from his $3.5 million life insurance policy to purchase his shares in the business.

  • June 05, 2024

    CohnReznick Scores Quick Exit In Tax Scheme Suit

    A New York federal judge agreed to toss a housing partnership's suit accusing accounting firm CohnReznick LLP of professional negligence and fraud, finding that the district court doesn't have jurisdiction over the dispute.

  • June 05, 2024

    IRS Must Better Log AI Use In Tax Gap Estimates, GAO Says

    The Internal Revenue Service needs to complete documentation on its use of artificial intelligence models as part of a plan to improve its tax gap estimates, the Government Accountability Office said Wednesday.

  • June 05, 2024

    Californian Failed To Report Missing Income, Tax Court Says

    A California woman's contention that she should not be accountable for a deficiency in her 2021 tax filing due to what she said was an error by her accountant doesn't stand up under scrutiny, the U.S. Tax Court said Wednesday.

  • June 05, 2024

    Some Payments After Train Derailed Aren't Taxable, IRS Says

    Certain payments from Norfolk Southern Corp. to victims of its freight train derailment and toxic chemical spill in East Palestine, Ohio, are considered disaster relief payments and are therefore not taxable, the Internal Revenue Service said Wednesday.

Expert Analysis

  • Employers, Prep For Shorter Stock Awards Settlement Cycle

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    Companies that provide equity compensation in the form of publicly traded stock will soon have one less day to complete such transactions under U.S. Securities and Exchange Commission and Nasdaq rules — so employers should implement expedited equity compensation stock settlement and payroll tax deposit procedures now, say attorneys at Morgan Lewis.

  • Demystifying IRS' Claims Of $851B Return On Investment

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    The IRS' recently released analysis, estimating a $851 billion return on the government’s $80 billion investment in the agency, represents a huge increase over its 2022 estimate and that of the Congressional Budget Office and may be best viewed as a best-case scenario, says Joyce Beebe at the Baker Institute.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • A Proposal For Fairer, More Efficient Innocent Spouse Relief

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    Adding a simple election to the current regulatory framework for innocent spouse claims would benefit both taxpayers and the Internal Revenue Service by alleviating the undue burdens placed on those the program was intended to help and improving agency collections in such cases, says Laurie Kazenoff at Kazenoff Tax.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • Proposed Hydrogen Tax Credit Regs May Be Legally Flawed

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    While the recently proposed regulations for the new clean hydrogen production tax credit have been lauded by some in the environmental community, it is unclear whether they are sufficiently grounded in law, result from valid rulemaking processes, or accord with other administrative law principles, say Hunter Johnston and Steven Dixon at Steptoe.

  • Navigating ACA Reporting Nuances As Deadlines Loom

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    Stephanie Lowe at Liebert Cassidy walks employers through need-to-know elements of Affordable Care Act reporting, including two quickly approaching deadlines, the updated affordability threshold, strategies for choosing an affordability safe harbor, and common coding pitfalls.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • Why Biz Groups Disagree On Ending Chevron Deference

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    Two amicus briefs filed in advance of last month's U.S. Supreme Court oral arguments in Loper Bright Enterprises v. Raimondo highlight contrasting views on whether the doctrine of Chevron deference promotes or undermines the stable regulatory environment that businesses require, say Wyatt Kendall and Sydney Brogden at Morris Manning.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Look Ahead For The Electric Vehicle Charging Industry

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    This will likely be an eventful year for the electric vehicle market as government efforts to accelerate their adoption inevitably clash with backlash from supporters of the petroleum industry, say Rue Phillips at SkillFusion and Enid Joffe at Green Paradigm Consulting.

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

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