Federal

  • 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.

  • December 12, 2024

    IRS Chief Makes Case To Restore $20B Funding Shortfall

    Congress should reverse a $20 billion IRS funding gap in a year-end budget bill to help the agency modernize its technology, improve customer service and collect unpaid taxes from wealthy businesses and individuals, Internal Revenue Commissioner Daniel Werfel said Thursday.

  • December 12, 2024

    2nd Circ. Won't Rethink Dual Citizen's FBAR Penalties

    The Second Circuit will not review its September decision finding that a dual U.S.-French citizen is liable for tax penalties for failing to file reports of foreign bank and financial accounts, the court said Thursday.

  • December 12, 2024

    IRS Expands Business Tax Account Program To Corp. Leaders

    The Internal Revenue Service's business tax account online self-service tool is now available to C corporations, while the agency is opening access to the program to certain officers of both C and S corporations, the agency said Thursday.

  • December 12, 2024

    IRS Hopes To Issue Amount B Pricing Guidance Within Weeks

    Treasury is working to finish its guidance on the simplified transfer pricing approach to baseline marketing and distribution known as Amount B by the end of the year, a U.S. official said Thursday.

  • December 12, 2024

    Ex-FBI Informant Admits To False Accusations In Biden Case

    A former FBI informant accused of making fake criminal accusations against President Joe Biden and his son, Hunter Biden, will plead guilty to tax evasion and falsifying records in a federal investigation, according to a deal filed Thursday in a California federal court.

  • December 12, 2024

    Treasury Seeks To Pause Anti-Laundering Law Injunction

    The U.S. Treasury Department asked a Texas federal judge to pause his nationwide preliminary injunction of the Corporate Transparency Act pending an appeal of his recent decision that found Congress likely overstepped its constitutional authority when it wrote the anti-money laundering law.

  • December 12, 2024

    IRS Electronic Tax Committee To Meet In January

    The Internal Revenue Service's Electronic Tax Administration Advisory Committee will hold its next meeting Jan. 8, the agency said Thursday.

  • December 11, 2024

    Bloomberg Entitled To Use $4B In Receipts For Deductions

    Bloomberg incorrectly allocated gross receipts between software and services related to access to the Bloomberg Terminal, its interactive financial analysis product, but the company ultimately had $4.1 billion in gross receipts that could be used to calculate a deduction for domestic production from 2008 to 2010, the U.S. Tax Court found Wednesday.

  • December 11, 2024

    Temp Agency Owner Gets Prison For $2M Tax Scheme

    A temp agency owner was sentenced to a year and a day in prison after pleading guilty in Massachusetts federal court to paying employees under-the-table wages to avoid $2.1 million in taxes.

  • December 11, 2024

    Tax Preparers Fabricated Expenses, US Says

    Two tax preparers and their company should be barred from owning or operating tax preparation services because they fabricated business income and expenses for clients, the federal government told a Texas federal court.

  • December 11, 2024

    Exxon Tax Ruling Doesn't Help Liberty Global, 10th Circ. Told

    Liberty Global cannot use a recent ruling that allowed Exxon Mobil a tax deduction for interest payments to claim a deduction for dividends that arose from its intragroup shuffling of a Belgian affiliate, the U.S. government told the Tenth Circuit on Wednesday.

  • December 11, 2024

    Beyoncé Fends Off Most Of $3M Tax Bill In Deal With IRS

    Pop star Beyoncé owes only about $700 of what the IRS had claimed was $3 million in outstanding taxes and penalties, according to a U.S. Tax Court ruling Wednesday that approved a settlement between the star and the agency.

  • December 11, 2024

    17M Won't Benefit From Full Child Tax Credit, Report Says

    Roughly 17 million children under 17 — or roughly a quarter of all U.S. children — will live in families that cannot claim the full child tax credit in 2025 because they make too little, the Urban-Brookings Tax Policy Center said in a report.

  • December 11, 2024

    Judge Orders Home Sale To Pay Down $1.7M Tax Debt

    A California federal judge ordered the private sale of a deceased couple's home to pay down a $700,000 tax bill that has been accruing interest for 20 years and now stands at roughly $1.7 million.

  • December 10, 2024

    FinCEN Says CTA Still Constitutional In Post-Injunction Alert

    The Financial Crimes Enforcement Network has alerted companies that they do not currently need to file so-called beneficial ownership information with the agency after a federal judge's nationwide preliminary injunction blocking the Corporate Transparency Act, though the bureau maintained that the law calling for such information is constitutional.

  • December 10, 2024

    Morgan Lewis Gets DLA Piper Tax Pro With DOJ Experience

    Morgan Lewis & Bockius LLP announced that it has added to its Boston office a tax attorney from DLA Piper who served as an appellate attorney at the U.S. Department of Justice, Tax Division.

  • December 10, 2024

    Biz Owner In $2.8M Worker Tax Scheme Gets 18 Months

    A construction company owner who failed to pay $2.8 million in employment taxes by falsely claiming his workers were subcontractors was sentenced to 18 months in prison Tuesday and ordered to pay full restitution, according to Massachusetts federal court documents.

  • December 10, 2024

    FBAR Default Against Widow Should Be Vacated, Judge Says

    A New York federal magistrate judge recommended vacating a default judgment against a widow, which would give her a second chance to defend her dead husband's estate against U.S. government claims that it owes $275,000 for his failure to report his account at an Indian bank.

  • December 10, 2024

    Tax Court Nixes Overpayment Refunds In Tolling Row

    A Florida man was correctly denied a pair of tax overpayment refunds that totaled roughly $88,000 because the statutes covering his claims are not governed by equitable tolling rules, the U.S. Tax Court said Tuesday.

  • December 10, 2024

    9th Circ. Nixes Tax Deductions For Disbarred Calif. Attorney

    A California attorney who fought with his neighbors in court cannot take business deductions for the cost of challenging his disbarment and a court's declaration that he is a "vexatious litigant," the Ninth Circuit said Tuesday, upholding a ruling from the U.S. Tax Court.

  • December 10, 2024

    Exxon's Tax Win Sets Path For Liberty Global, 10th Circ. Told

    A ruling allowing Exxon Mobil a U.S. tax deduction for interest expenses in its natural gas deal with Qatar confirms that Liberty Global is entitled to a deduction related to its sale of a Belgian affiliate, an attorney for the telecommunications company told the Tenth Circuit.

  • December 10, 2024

    Soft Landing For Pilot As Billionaire's Insider Case Wraps

    A pilot who admitted to dodging taxes on $500,000 in income after he was accused of taking stock tips from Joe Lewis, his billionaire boss, avoided prison on Tuesday at a sentencing that closed a high-profile insider trading prosecution.

  • December 10, 2024

    Treasury Finalizes Simplified Foreign Currency Rules

    The U.S. Treasury Department finalized regulations Tuesday that aim to simplify aspects of how corporations determine taxable income or loss with respect to certain affiliates that conduct business in a foreign currency.

  • December 09, 2024

    10th Circ. Affirms Nix Of Atty's Racing Expense Deductions

    The Tenth Circuit affirmed Monday the U.S. Tax Court's determination that a Denver personal injury lawyer shouldn't be allowed to deduct about $300,000 for his car racing-related costs as advertising, despite his claims that his races helped him drum up business.

Expert Analysis

  • 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.

  • Planning A Defense As IRS Kicks Off Sports Losses Campaign

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    Sports team owners and partnerships face potential examination under the Internal Revenue Service’s recently announced sports industry losses campaign, and should be preparing to explain what drove their reported losses and assembling documentation to support their tax return positions and accounting methods, say Sheri Dillon and Jennifer Breen at Morgan Lewis.

  • What New Calif. Strike Force Means For White Collar Crimes

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    The recently announced Central District of California strike force targeting complex corporate and securities fraud — following the Northern District of California's model — combines experienced prosecutorial leadership and partnerships with federal agencies like the IRS and FBI, and could result in an uptick in the number of cases and speed of proceedings, say attorneys at MoFo.

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