Federal

  • July 05, 2024

    Top Federal Tax Cases To Watch In The 2nd Half Of 2024

    In the coming months, the U.S. Treasury and the IRS will defend rules designed to go after what they consider as abusive tax practices, including the economic substance doctrine, the Corporate Transparency Act and the moratorium on employee retention tax credits. Here, Law360 looks at key federal tax cases to watch in the rest of 2024.

  • July 03, 2024

    Ex-Defense Contractor Evaded Taxes On $350 Million, US Says

    A former defense contractor and his wife face a 30-count indictment alleging they were involved in a decadeslong scheme to defraud the U.S. government and avoid taxes on more than $350 million in income, the Department of Justice announced Wednesday.

  • July 03, 2024

    Maryland Fends Off Chamber's Challenge To Digital Ad Tax

    A disputed provision of Maryland's tax on digital advertising doesn't violate the First Amendment, a federal judge in the state found Wednesday, throwing out a challenge to the tax brought by the U.S. Chamber of Commerce and other business groups.

  • July 03, 2024

    Insurers Ask 10th Circ. To Rethink Toss Of $2M Tax Appeal

    Captive insurance companies and their related entities that are challenging more than $2 million in IRS notices of tax deficiencies asked the Tenth Circuit to reconsider its refusal to review a U.S. Tax Court decision finding the notices were not invalid as the entities had claimed.

  • July 03, 2024

    Warren, Other Pols Push Yellen For Corp. Minimum Tax Rules

    Sen. Elizabeth Warren and three other lawmakers urged Treasury Secretary Janet Yellen for the department to quickly release regulations to implement the corporate alternative minimum tax in a letter released Wednesday.

  • July 03, 2024

    'Real Housewives' Figure Pleads Guilty To $2.5M Tax Offense

    A former cast member of a "Real Housewives" TV series and owner of several restaurants and nightclubs in multiple states admitted in a North Carolina federal court to failing to pay over $2.5 million in employment taxes, the U.S. Department of Justice said.

  • July 03, 2024

    IRS Warns Of Scam Tied To Clean Energy Tax Credit Sales

    Individuals should be wary of a scam in which tax return preparers improperly steer them to claim purchased clean energy tax credits to offset income tax from wages, retirement account withdrawals and other sources, the Internal Revenue Service warned Wednesday.

  • July 03, 2024

    Fox Rothschild Hires Pryor Cashman Nonprofit Leads

    Fox Rothschild LLP announced Wednesday the hiring of two Pryor Cashman LLP partners for its corporate department in New York.

  • July 03, 2024

    IRS Reveals Final Regs For Medicare Drug Negotiation Tax

    The Internal Revenue Service finalized regulations Wednesday that govern the quarterly reporting of a new excise tax that pharmaceutical companies, suppliers and importers must pay when they do not negotiate with Medicare over drug prices.

  • July 03, 2024

    Federal Tax Policy To Watch In The 2nd Half Of 2024

    Congressional lawmakers are grappling with the looming 2025 expiration of the 2017 GOP tax overhaul, a situation made more difficult by the coming elections in November that could define what, if any, tax legislation is eventually signed into law this year. Here, Law360 examines federal tax policy to watch in the second half of 2024.

  • July 02, 2024

    Chevron's Fall Places State Tax Rules Under Microscope

    State tax regulations could face increased judicial scrutiny in light of the U.S. Supreme Court's decision to jettison the decades-old Chevron deference doctrine, which instructed courts to defer to federal agencies' interpretations of ambiguous laws.

  • July 02, 2024

    IRS Details Accounting Change For Worthless Debt

    Regulated financial companies or members of regulated financial groups can automatically get the consent of the Internal Revenue Service to change their accounting methods to the allowance charge-off method for debt instruments presumed worthless, the agency said in a revenue procedure Tuesday.

  • July 02, 2024

    NJ Couple Ordered To Pay $2.5M In FBAR Penalties

    A New Jersey couple were ordered to pay $2.5 million in penalties and interest for failing to report their foreign bank accounts in Switzerland, according to court documents.

  • July 02, 2024

    8th Circ. Won't Revive IRS Fraud Docs FOIA Row

    The Eighth Circuit affirmed a ruling that prevents public disclosure of the IRS' methods for verifying callers' identities, rejecting on Tuesday a retired Harvard professor's argument that the documents detailing the methods failed to qualify for an exemption under the Freedom of Information Act.

  • July 02, 2024

    Man Warned Against 'Tax Protester Rhetoric' In Failed Case

    The U.S. Tax Court cautioned a New Jersey man Tuesday against using "tax protester rhetoric" in future disputes while rejecting his challenge to the IRS' determination that he failed to claim income and improperly claimed deductions, dismissing his arguments as frivolous.

  • July 02, 2024

    Eaton Needs To Cough Up Docs In IRS Probe, US Says

    The U.S. government urged an Ohio federal judge to order power management multinational Eaton to produce records on certain European employees in response to an IRS investigation, arguing the company's contention the court lacks jurisdiction is "pure sophistry."

  • July 02, 2024

    Justices Revive Tax Tipster's Case, Citing Chevron Ruling

    The U.S. Supreme Court vacated and remanded on Tuesday a decision denying a whistleblower award to a tipster who reported an improper $60 million tax deduction to the IRS, saying the D.C. Circuit should reconsider its decision following the high court's ruling that overturned the Chevron doctrine.

  • July 02, 2024

    Top Federal Tax Cases Of 2024: Midyear Report

    In the first half of the year, the U.S. Supreme Court torpedoed the Chevron doctrine of judicial deference to federal agencies and affirmed the denial of a tax refund to a business owner's estate related to a life insurance payout, while the U.S. Tax Court reversed itself regarding a rule for conservation easements. Here, Law360 reviews federal court decisions from the past six months that tax attorneys should know.

  • July 01, 2024

    High Court's 1-2 Punch Sets Up Long-Standing Regs For KO

    By ending its term with a stinging combination against federal agencies, the U.S. Supreme Court's conservative bloc left behind a bruised bureaucracy and a regulatory system that's now vulnerable to a barrage of incoming attacks.

  • July 01, 2024

    IRS Faces Rulemaking Pressure Following Chevron's Demise

    The Internal Revenue Service will likely face more pressure to develop tax regulations that are more firmly grounded in the law and tailored to ensure certainty for individuals, businesses and other organizations after the U.S. Supreme Court's landmark decision to overturn the decades-old Chevron doctrine.

  • July 01, 2024

    Feds Push To Keep IRS Agents Out Of Hunter Biden Tax Case

    Two Internal Revenue Service whistleblowers who Hunter Biden said wrongfully disclosed his confidential tax information should not be allowed to intervene in his suit against the U.S. government, the government told a D.C. federal court Monday.

  • July 01, 2024

    Pa. Man Gets 12 Years For $2M COVID-19 Funds Fraud

    A Pennsylvania man was sentenced to approximately 12 years in prison following his convictions for bank fraud, aggravated identity theft and unlawful monetary transactions related to theft of federal COVID-19 pandemic relief funds, according to the U.S. Attorney's Office for the Middle District of Pennsylvania.

  • July 01, 2024

    Womble Bond Adds Int'l Tax Partner In Houston Office

    Womble Bond Dickinson has added a partner to its corporate and securities group in Houston who will focus on tax law and cross-border transactions, the firm announced.

  • July 01, 2024

    Tax Court Again Rules Against Couple On Social Security Pay

    A California couple should have included Social Security disability payments in their income on their federal tax return, the U.S. Tax Court said Monday, upholding an Internal Revenue Service determination against the couple in such a case for a second time.

  • July 01, 2024

    US-Taiwan Biz Groups Push For True Double-Tax Treaty

    Top-ranking Senate members should push for the start of consultations on a bilateral tax treaty to avoid double taxation between the U.S. and Taiwan as opposed to measures already included in a stalled larger bill, two groups focused on business relations between the countries said.

Expert Analysis

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Charting The Course For Digital Assets In 2024

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    Although 2023 was a tough year for the digital asset industry, upcoming court decisions, legislation and regulatory action will bring clarity, allowing the industry to expand and evolve, and the government will decide what innovation it will allow without challenge, says Joshua Smeltzer at Gray Reed.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • Giving The Gov't Drug Patent March-In Authority Is Bad Policy

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    The Biden administration's recent proposal to allow government seizure of certain taxpayer-funded drug patents is a terrible idea that would negate the benefits of government-funded research, to the detriment of patients and the wider economy, says Wayne Winegarden at Pacific Research Institute.

  • How Clients May Use AI To Monitor Attorneys

    Excerpt from Practical Guidance
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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • How 'As Such' Changes LPs' Self-Employment Tax Exposure

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    In light of the U.S. Tax Court’s recent Soroban Capital Partners decision hinging on "as such" to define the statutory limited partners exemption, state law limited partnerships should consider partners' roles and responsibilities before determining whether they are obligated to pay self-employment income tax, say attorneys at Morgan Lewis.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • IRA Monetization Energizes Clean Power Tax Credit Market

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    Recent large sales of clean energy production tax credits reflect an environment in which the Inflation Reduction Act's provisions for monetizing such credits via direct transfer — bypassing slow, costly tax equity transactions — offer opportunities for both developers and investors, says Andrew Eastman at Husch Blackwell.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • Unpacking Long-Awaited Clean Energy Tax Credit Guidance

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    Recently proposed Internal Revenue Service regulations provide welcome confirmatory guidance on the application of investment tax credits as reworked by 2022's Inflation Reduction Act, prevailing wage and apprenticeship rules that are largely consistent with market expectations, and broader eligibility criteria that should please the wind power industry in particular, say attorneys at Morgan Lewis.

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