Federal
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July 24, 2024
Senate Finance Committee Holding Tax Court Noms Session
The Senate Finance Committee will host an open executive session Thursday to consider three nominations to the U.S. Tax Court, Sen. Ron Wyden, D-Ore., said Wednesday.
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July 24, 2024
Dentons Brings On Former Big 4 Exec As New Global CEO
Global law firm Dentons, which has made a name for itself by aggressive growth through combinations, has tapped a new global chief executive officer with leadership experience at accounting giant EY, the firm's first change at the top in over a decade.
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July 23, 2024
Cannabis Industry Stakeholders Weigh In On Rescheduling
As the period for public comment on the Biden administration's proposal to reclassify marijuana came to a close Monday, anti-legalization activists, marijuana industry advocates and state cannabis regulators each submitted their thoughts on the potential policy shift.
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July 23, 2024
House Delays Vote On FY25 IRS Budget Legislation
The House delayed an expected vote Tuesday on the Internal Revenue Service's budget for fiscal 2025, casting doubt on whether GOP lawmakers will meet their goal of passing the funding bill before Congress' annual August recess begins next week.
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July 23, 2024
Newell Says IRS Misapplied Pricing Law In $124M Dispute
Newell Brands told the U.S. Tax Court the Internal Revenue Service misapplied transfer pricing law to levy almost $124 million in additional taxes and penalties.
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July 23, 2024
White House Taps VA Official To Helm Tax Watchdog
President Joe Biden has nominated a U.S. Department of Veterans Affairs investigator to serve as Treasury inspector general for tax administration, the Internal Revenue Service's federal watchdog, the White House announced Tuesday.
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July 23, 2024
Feds Urge 6th Circ. To Affirm Pharma Owner's Fraud Sentence
The Sixth Circuit should affirm a district court's fraud convictions, nearly five-year sentence and $7 million restitution order against an Ohio pharmaceutical salesman who underreported his income to reduce his tax liability in a multimillion-dollar scheme involving bogus insurance billings, the federal government said.
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July 23, 2024
Farm Owner Must Boost Taxable Income, 8th Circ. Told
An Arkansas company that leases farmland must raise its reported income by $230,000 because it failed to get permission from the IRS to change its accounting method, the U.S. told the Eighth Circuit on Tuesday in asking it to uphold a U.S. Tax Court ruling.
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July 23, 2024
IRS Notice Signals Direction On Corp. AMT Regs, Official Says
An Internal Revenue Service notice regarding the U.S. corporate alternative minimum tax can be read as a signal about how the agency will more broadly address the measure's potential for counting offshore income twice, an IRS official said Tuesday.
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July 23, 2024
Winston & Strawn Adds MoFo Tax Pro As Partner In NY
Winston & Strawn LLP has added a transactional tax specialist from Morrison Foerster LLP as a partner with the firm's transactions department and tax practice in New York.
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July 23, 2024
Former Doctor To Be Released From Jail In FBAR Fight
A former doctor will be released from U.S. custody after a Michigan federal court lifted Tuesday an order of civil contempt against him for failure to pay about $1 million in foreign account reporting penalties.
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July 23, 2024
Orrick Hires Ex-Winston & Strawn Tax Partner In Chicago
Orrick Herrington & Sutcliffe LLP announced the hiring of a former partner at Winston & Strawn LLP for its renewables tax equity and tax credit team.
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July 23, 2024
11th Circ. Should Uphold Tax Court Protection, IRS Says
The Eleventh Circuit should uphold a U.S. Tax Court ruling that denied a widow tax relief and also rejected her claim that Tax Court judges have unconstitutional job protection, the Internal Revenue Service told the circuit court.
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July 23, 2024
5-Hour Energy Partner Owes No Tax On Sale, DC Circ. Says
The D.C. Circuit found Tuesday that a Canadian citizen's $6.5 million in gains from her sale of a U.S. partnership interest in a company that sold 5-hour Energy drinks was not federally taxable as inventory income, reversing a U.S. Tax Court ruling.
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July 23, 2024
IRS Makes Corrections To 2 Proposed Regulations
The Internal Revenue Service issued a handful of corrections Tuesday to two notices of proposed rulemaking, one regarding certain partnership related-party basis adjustment transactions and the other interest capitalization requirements for improvements to designated property.
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July 22, 2024
3 Policies Tax Pros Want Congress To Pass This Year
As momentum around the House-passed tax break bill has fizzled and election season ramps up, tax experts hope lawmakers use what little time they have left to extend expired research tax breaks, approve the Taiwanese tax agreement and pass disaster relief before the end of the year. Here are three policy changes tax professionals think Congress should make before the end of the year.
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July 22, 2024
CPAs Back Bill To Apply Mailbox Rule To Electronic Returns
The American Institute of Certified Public Accountants said Monday that it endorsed a congressional proposal that would apply what is known as the mailbox rule to electronically submitted tax returns and shift the deadlines for estimated tax payments to intervals that are actually quarterly.
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July 22, 2024
US Treasury Working To Extend Pillar 1 DST Compromise
As OECD-led negotiations continue on a taxing rights overhaul known as Pillar One after a missed June deadline, the U.S. Treasury Department is working to extend the political agreement between it and several countries to nullify their digital services taxes once the rights overhaul is implemented.
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July 22, 2024
Pension Plans Slam Biz Docs In $2B Danish Tax Fraud Case
Denmark's tax agency has produced experts who are relying on unauthenticated documents in litigation accusing U.S. pension plans of participating in a $2.1 billion fraud scheme, the pension plans claimed in urging a New York federal court to exclude the testimony.
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July 22, 2024
11th Circ. Denies Rehearing On Social Security Garnishment
The Eleventh Circuit on Monday turned down a Florida woman's request to reconsider its rejection of her challenge to the Internal Revenue Service's garnishment of her Social Security payments.
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July 22, 2024
Werfel Wants IRS to Help Eligible EITC Nonclaimaints
The Internal Revenue Service needs to do more to help people who are eligible for the earned income tax credit but don't claim it, Daniel Werfel, the agency's commissioner, said Monday.
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July 22, 2024
IRS Delays Tax Deadlines For Texans Affected By Hurricane
Certain Texas taxpayers affected by Hurricane Beryl, which hit the state this month, will have until a delayed deadline of Feb. 3 to file individual and business tax returns and make payments, the Internal Revenue Service said Monday.
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July 22, 2024
Kyocera Failed To Back R&D Credits With Records, US Says
Multinational electronics maker Kyocera AVX Components Corp. failed to back up its claim to research tax credits with the required paperwork, the U.S. government told a South Carolina federal court in asking it to stop part of the company's nearly $9 million refund suit from going to trial.
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July 19, 2024
House Panel To Weigh EV Credit Restrictions, IRS' Use Of AI
The House Rules Committee will consider amendments Monday to a fiscal 2025 funding bill that would give the IRS $10.1 billion, sorting through divergent priorities of lawmakers from integrating artificial intelligence into agency operations to restricting tax credits for electric vehicles and helping seniors file tax returns.
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July 19, 2024
Partnership Protests IRS' Reasons For $84M Deduction Denial
The Internal Revenue Service wrongly denied a partnership's charitable contribution deduction of nearly $84 million for a donated conservation easement for reasons including the partnership failing to demonstrate it made the contribution, the partnership's representative told the U.S. Tax Court.
Expert Analysis
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Anticipating Intensified Partnership Enforcement From IRS
The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.
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Pro Bono Work Is Powerful Self-Help For Attorneys
Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.
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The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'
The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.
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Newman Suspension Shows Need For Judicial Reform
The recent suspension of U.S. Circuit Judge Pauline Newman following her alleged refusal to participate in a disability inquiry reveals the need for judicial misconduct reforms to ensure that judges step down when they can no longer serve effectively, says Aliza Shatzman at The Legal Accountability Project.
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How And Why Your Firm Should Implement Fixed-Fee Billing
Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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How Law Firms Can Use Account-Based Marketing Strategies
Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.
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While Risks Exist, AI Could Transform IRS Enforcement
The Internal Revenue Service's recently announced use of artificial intelligence could revolutionize the agency's enforcement efforts, and transparency about its use and a forum for challenging AI findings could help mitigate fears that the technology will increase bias, say attorneys at Lewis Brisbois.
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Strategic Succession Planning At Law Firms Is Crucial
Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.
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Maximizing Law Firm Profitability In Uncertain Times
As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.
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Enforcement Of International Tax Reporting Is Heating Up
Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.
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How Gov't Agencies Will Fare In The Event Of A Shutdown
With a federal shutdown potentially set to begin at the end of this month, it may be useful to consider the approximate timelines that agencies such as the Federal Trade Commission and IRS have announced for curtailing operations, and potential strategies for mitigating challenges that may arise while agency functions are limited, say attorneys at Cleary.
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IRS Notice Clarifies R&E Amortization, But Questions Remain
The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.
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Preparing Your Legal Department For Pillar 2 Compliance
Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.