Federal

  • June 14, 2024

    US Urges 5th Circ. To Back $2M Tax Bill For Tire Imports

    The Fifth Circuit should overturn a lower court's ruling that a Houston truck company was not an importer responsible for nearly $2 million in excise taxes on tires it bought from a Chinese manufacturer, the U.S. told the Fifth Circuit on Friday.

  • June 14, 2024

    Eaton Says Court Improperly Required Int'l Employee Evals

    An Ohio federal court should reconsider its decision that multinational power management company Eaton must disclose the personnel records of its foreign employees that were requested by the Internal Revenue Service in a transfer pricing investigation, the company told the court.

  • June 14, 2024

    The Tax Angle: More GOP TCJA Teams, Nonprofit Hospitals

    From a look at efforts by the Republicans on the Senate Finance Committee to prepare for next year's expiration of the 2017 tax overhaul law to a new call for nonprofit hospitals to provide more charity care, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • June 14, 2024

    IRS Says Ariz. Lacks Standing To Fight Taxation Of Rebates

    Arizona did not have standing to lodge its claim that its 2023 income tax rebates should be exempt from federal tax, the Internal Revenue Service told a federal court, arguing the taxes paid by Arizonans did not amount to harm to the state itself.

  • June 14, 2024

    Tax Preparer Blames Customers For Errors In $42.5M Dispute

    A tax preparer who once worked for the IRS said the government wrongly accused him of underestimating clients' tax liabilities, telling a Washington federal court in response to allegations that he caused $42.5 million in tax losses that his customers had made the errors.

  • June 14, 2024

    Taxation With Representation: Kirkland, Arnold & Porter

    In this week's Taxation with Representation, Noble Corp. PLC buys Diamond Offshore Drilling Inc., Cognizant buys Belcan, AlphaSense raises funding to buy Tegus, and Matador Resources Co. acquires a subsidiary of the EnCap Investments portfolio company Ameredev II Parent.

  • June 14, 2024

    House Panel Approves Slashing $2B From IRS Budget

    The House Appropriations Committee approved legislation that would reduce Internal Revenue Service funding for fiscal 2025 by more than $2 billion and prohibit money from going to the agency's free online tax-filing program without congressional approval, sending it to the full House for consideration.

  • June 14, 2024

    ABA Tax Section Calls For Revision To Stock Buyback Regs

    The U.S. Department of the Treasury and the IRS should narrow a rule in proposed regulations on the stock buyback tax regarding U.S. subsidiaries funding repurchases of their foreign parents' stock, the American Bar Association's Tax Section said in a letter released Friday.

  • June 14, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included delays for reporting certain intercompany payments that are exempt from the base erosion and anti-abuse tax.

  • June 14, 2024

    Full DC Circ. Won't Hear Foreign Disclosure Penalty Dispute

    The D.C. Circuit declined to reconsider its ruling overturning a major U.S. Tax Court decision that had crimped the administrative collection arm of the Internal Revenue Service, letting stand a panel's restoration of the agency's power to more freely penalize undisclosed foreign corporations.

  • June 13, 2024

    Senate Finance Panel OKs 3 Tax Court Judges, Treasury IG

    The Senate Finance Committee overwhelmingly approved Thursday the nominations of three judges for the U.S. Tax Court and a new inspector general for the U.S. Department of the Treasury, a post that has lacked a Senate-confirmed nominee for five years.

  • June 13, 2024

    Staffing Hurdles Could Slow Impact Of IRS Audit Boost

    The Internal Revenue Service's intended ramping up of enforcement on wealthy people, large corporations and complex partnerships may not have a meaningful impact in the short term because of challenges in hiring and training people to do the work.

  • June 13, 2024

    Easement Deduction Limit Hurts Conservation, 11th Circ. Told

    A partnership's tax deduction for its donation of a conservation easement should not be limited to its adjusted basis in the property, the partnership told the Eleventh Circuit in urging it to overturn a U.S. Tax Court decision that it claims will hurt conservation efforts.

  • June 13, 2024

    A Chronology Of The Hunter Biden Investigation

    The story behind President Joe Biden's son Hunter Biden's conviction on federal gun charges started with a gun purchase in 2018, was complicated by a laptop repair in 2019, and could bleed into an upcoming trial on federal tax charges in California in September.

  • June 13, 2024

    Mo. City Tax Credit Suit Tossed Over Federal Jurisdiction

    A federal judge dismissed a Kansas City, Missouri, resident's claims that the city unconstitutionally refused to credit his state income taxes paid to Kansas against his city earnings tax liabilities, ruling that a federal law barred the case from being lodged in federal court.

  • June 13, 2024

    IRS Extends Corp. AMT Penalty Relief Into August

    The Internal Revenue Service will continue to provide penalty relief for entities that fail to make estimated quarterly payments of the corporate alternative minimum tax through Aug. 15, the agency said Thursday.

  • June 12, 2024

    Senate Budget Chair Seeks End To Carried Interest Tax Break

    Lawmakers should end the favorable tax treatment of income from carried interest compared with ordinary earned income, Senate Budget Committee Chairman Sheldon Whitehouse said Wednesday.

  • June 12, 2024

    Digital Taxes May Take Hold Regardless Of Treaty Signing

    An internationally agreed-upon freeze on digital levies may continue to thaw even if countries meet their impending deadline to sign a related treaty for new corporate tax rules, in part because the accord faces a hazy path to formal ratification.

  • June 12, 2024

    Feds Strike Deal Ending $7M FBAR Penalty Cases

    The U.S. government agreed to settle a pair of foreign bank account reporting cases in which it had sought a total of $7 million from a former insurance broker and his wife's estate, according to a court order filed Wednesday in California federal court.

  • June 12, 2024

    Groups Push Back On Stock Buyback Tax Test's Scope

    The U.S. Treasury Department's proposed stock buyback tax rules go too far in trying to assess whether the main purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, two groups said in comments released Wednesday.

  • June 12, 2024

    St. Louis Atty Urges Acquittal After Tax Avoidance Conviction

    A Missouri attorney who was found guilty of participating in a $4 million tax avoidance scheme alongside her father and a North Carolina insurance agent is looking to wipe out the verdict, arguing there wasn't enough evidence to convict.

  • June 12, 2024

    IRS Nix Of $45M Easement Deduction Invalid, Donor Says

    A North Carolina partnership asked the U.S. Tax Court to invalidate an Internal Revenue Service adjustment that slashed its $45.6 million deduction for its donation of a conservation easement, saying the agency failed to follow proper administrative procedures.

  • June 12, 2024

    Treasury Issued Over $1B In Clean Vehicle Tax Credits

    The clean vehicle tax credit of up to $7,500 has saved buyers more than $1 billion in total upfront costs since January, the U.S. Treasury Department announced Wednesday, saying the figures represent a major milestone in lowering transportation costs since the incentive was updated in 2022.

  • June 12, 2024

    First 'Survivor' Winner Wants $3M Tax Case Tossed

    The winner of the first season of the TV series "Survivor" asked a Rhode Island federal court to toss the government's case against him seeking nearly $3.3 million in unpaid taxes, saying the liabilities stem from his flawed criminal conviction for tax evasion nearly 20 years ago.

  • June 12, 2024

    4 Taxpayer Advocacy Panel Committees To Meet In July

    Four Taxpayer Advocacy Panel committees will hold public meetings in July focused on improving customer service at the Internal Revenue Service, the agency announced Wednesday.

Expert Analysis

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

  • IRS Sings New Tune: Whistleblower Form Update Is Welcome

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    In a significant reform at the Internal Revenue Service's Whistleblower Office, the recently introduced revisions to the Form 211 whistleblower award application use new technology and a more intuitive approach to streamline the process of reporting allegations of tax fraud committed by wealthy individuals and companies, says Benjamin Calitri at Kohn Kohn.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.

  • Energy Community Tax Credit Boost Will Benefit Wind Sector

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    Recent Internal Revenue Service guidance broadening tax credit eligibility to more parts of offshore wind facilities in so-called energy communities is a win for the industry, which stands to see more projects qualify for a particularly valuable bonus in the investment tax credit context due to the capital-intensive nature of offshore wind projects, say attorneys at Troutman Pepper.

  • Weisselberg's Perjury At Trial Spotlights Atty Ethics Issues

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    Former Trump Organization executive Allen Weisselberg’s recent guilty plea for perjury in the New York attorney general's civil fraud trial should serve as a reminder to attorneys of their ethical duties when they know a client has lied or plans to lie in court, and the potential penalties for not fulfilling those obligations, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • Practicing Law With Parkinson's Disease

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    This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.

  • Why Supreme Court Should Allow Repatriation Tax To Stand

    If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.

  • Trump's NY Civil Fraud Trial Spotlights Long-Criticized Law

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    A New York court’s recent decision holding former President Donald Trump liable for fraud brought old criticisms of the state law used against him back into the limelight — including its strikingly broad scope and its major departures from the traditional elements of common law fraud, say Mark Kelley and Lois Ahn at MoloLamken.

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

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    A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

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    As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.

  • How IRA Unlocks Green Energy Investments For Tribes

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    An Inflation Reduction Act provision going into effect May 10 represents a critical juncture for Native American tribes, offering promising economic opportunity in green energy investment, but requiring a proactive and informed approach when taking advantage of newly available tax incentives, say attorneys at Lewis Brisbois.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

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    Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.

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