Federal

  • October 16, 2024

    Nev. Businessman, Trump Donor Challenges $12M Tax Bill

    A Nevada businessman and major donor to former President Donald Trump challenged what the IRS claimed are more than $12 million in tax liabilities, telling the U.S. Tax Court that the agency incorrectly adjusted his rental real estate losses and other reported calculations.

  • October 16, 2024

    Construction Co., Gov't Drop $4M Retention Credit Suit

    A former construction business' suit against the Internal Revenue Service seeking nearly $4 million in employee retention credit refunds was dismissed by a Florida federal judge Wednesday after the company and the federal government agreed to drop the case.

  • October 16, 2024

    5th Circ. Upholds Frivolity Penalty In Dell Worker Tax Case

    A Texas man who claimed that nearly $300,000 he earned from working at Dell Technologies Inc. wasn't taxable must pay the taxes in addition to a $25,000 fine for making frivolous arguments, the Fifth Circuit said.

  • October 16, 2024

    Ex-BigLaw Partner Gets 16 Months For Tax Evasion

    A former partner at Husch Blackwell LLP and Dykema Gossett PLLC who pled guilty to refusing to pay taxes on millions of dollars in income was sentenced to 16 months in prison.

  • October 15, 2024

    Applicable Federal Rates Set For Mixed Changes In Nov.

    While the short-term applicable federal rate for income tax purposes will continue a monthslong decline in November, related rates will either hold steady or increase, the Internal Revenue Service said Tuesday.

  • October 15, 2024

    IRS Issues Benefit Overpayments Guidance Under Secure 2.0

    The Internal Revenue Service published guidance Tuesday related to certain inadvertent benefit overpayments as they relate to changes made in the Secure 2.0 Act of 2022, including the treatment of certain overpayments as eligible rollover distributions.

  • October 15, 2024

    Justices Told Split On Shedding Tax Debts Can't Be Ignored

    The U.S. Supreme Court should review a Ninth Circuit decision that found late-filed returns prevented a taxpayer from discharging his federal tax debt in bankruptcy, the taxpayer argued, saying both sides in the case have agreed the circuits are split on the issue.

  • October 15, 2024

    Israel-US Citizen Owes $1.1M In FBAR Penalties, US Says

    A dual Israeli-American citizen who owns a Chicago pub faces more than $1 million in penalties for failing to report bank accounts that he maintained in Israel, the U.S. government told an Illinois federal court.

  • October 15, 2024

    New ABA Tax Chair Wants To Revamp Practice's Dry Image

    The new chair of the American Bar Association Section of Taxation told Law360 she wants to boost the section's recent efforts to revamp the tax practice's image as a boring, numbers-intensive profession with limited opportunities to improve society and inspire more students to enter tax law. Here, she shares her background and goals for the tax section.

  • October 15, 2024

    Alvarez & Marsal Tax Brings On Restructuring Leader

    Alvarez & Marsal's tax affiliate added a restructuring professional from investment bank Houlihan Lokey to serve as its head of global restructuring tax services.

  • October 15, 2024

    V&E Adds Energy Tax Pro From Bracewell In Houston

    Vinson & Elkins LLP has bolstered its energy transition and tax practices with a partner in Houston who came aboard from Bracewell LLP and whose background includes substantial in-house experience advising on renewable projects.

  • October 15, 2024

    Law Firms Diverge As Anti-ESG Pushback Continues

    A continuing onslaught of legislation and litigation opposing corporate environmental, social and governance actions has created a fork in the road for law firms, with some choosing to scale back efforts and others pushing ahead with their internal ESG and diversity, equity and inclusion goals.

  • October 15, 2024

    The 2024 Law360 Pulse Social Impact Leaders

    Check out our Social Impact Leaders ranking, analysis and interactive graphics to see which firms stand out for their engagement with social responsibility and commitment to pro bono service.

  • October 15, 2024

    Gov't Resists DC Circ. Redo In Ayahuasca Church Tax Case

    An Iowa church that used a psychedelic in its rites was correctly denied tax-exempt status on grounds that it was organized for illegal aims, the federal government told the D.C. Circuit in urging it to reject the church's request for a rehearing.

  • October 11, 2024

    Julie Chrisley Appeals Ga. Judge's Resentencing Ruling

    Former real estate mogul and reality television star Julie Chrisley, who was convicted of running a yearslong bank fraud scheme with her husband, Todd, is appealing a federal judge's decision to resentence her to the same seven-year prison term she first received nearly two years ago.

  • October 11, 2024

    Philly Pizzeria Owner Accused Of Dodging Taxes

    A Pennsylvania pizzeria owner evaded taxes for multiple years by paying himself and employees in cash and lied about it to his accountant, the U.S. Department of Justice said in announcing charges against him.

  • October 11, 2024

    Tribal Wildfire Victims Can File Returns Late, IRS Says

    Members of the San Carlos Apache Tribe in Arizona who were affected by a wildfire in July may put off filing certain tax returns until Feb. 5, the Internal Revenue Service said Friday.

  • October 11, 2024

    Tax-Exempt Orgs Get More Time To Make Payment Election

    Certain tax-exempt organizations making an elective payment election have an extra six months to file their business income tax return to declare such an election, the Internal Revenue Service said Friday.

  • October 11, 2024

    IRS Delays Fla. Deadlines, Grants Other Relief After Milton

    Following Hurricane Milton, the Internal Revenue Service has granted all taxpayers in Florida until May 1 to file individual and business tax returns and make payments, the agency said Friday, while also granting dyed diesel penalty relief.

  • October 11, 2024

    Disputes May Loom Over Dividend Deductions For CFCs

    U.S. multinational corporations are concerned that rulemakers' interpretation of a law allowing tax-free repatriation of certain overseas earnings could lead to controversy after the Internal Revenue Service published a memo indicating the break is unavailable for controlled foreign corporations.

  • October 11, 2024

    Bank Info Fair Game In Crypto Exec's Appeal, Gov't Says

    A cryptocurrency executive charged in a 2020 bitcoin fraud investigation can't stop the IRS from using the financial information it gathered through summonses while he appeals the demands in the Fifth Circuit, the U.S. government told a Texas federal court.

  • October 11, 2024

    5 Mos. Jail Enough For Swiss Tax Expert In $60M IRS Scam

    A Manhattan federal judge on Friday allowed a former financial executive from Switzerland to avoid additional time behind bars for his role in building a complex tax fraud scheme that helped wealthy Americans hide $60 million from the IRS.

  • October 11, 2024

    Taxation With Representation: Davis Polk, Latham, Kirkland

    In this week's Taxation With Representation, Rio Tinto agrees to acquire Arcadium Lithium for roughly $6.7 billion, Ares Management Corp. and GCP International reach a $3.7 billion deal, and Butterfly Equity announces plans to buy The Duckhorn Portfolio for $2 billion.

  • October 11, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included proposed rules for the new 15% corporate alternative minimum tax on corporations with reported profits of $1 billion or more.

  • October 10, 2024

    IRS Announces 9 Tax Court Sessions Added To Calendar

    The Internal Revenue Service announced nine U.S. Tax Court sessions in February and March and named calendar administrators for the sessions.

Expert Analysis

  • Class Actions At The Circuit Courts: July Lessons

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    In this month's review of class action appeals, Mitchell Engel at Shook Hardy considers cases touching on pre- and post-conviction detainment conditions, communications with class representatives, when the American Pipe tolling doctrine stops applying to modified classes, and more.

  • Now More Than Ever, Lawyers Must Exhibit Professionalism

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    As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.

  • Reading Between The Lines Of Justices' Moore Ruling

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    The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.

  • A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates

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    Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.

  • States Should Loosen Law Firm Ownership Restrictions

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    Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.

  • After Chevron: Uniform Tax Law Interpretation Not Guaranteed

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    The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.

  • Texas Ethics Opinion Flags Hazards Of Unauthorized Practice

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    The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • How High Court Approached Time Limit On Reg Challenges

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    The U.S. Supreme Court's decision in Corner Post v. Federal Reserve Board effectively gives new entities their own personal statute of limitations to challenge rules and regulations, and Justice Brett Kavanaugh's concurrence may portend the court's view that those entities do not need to be directly regulated, say attorneys at Snell & Wilmer.

  • How To Clean Up Your Generative AI-Produced Legal Drafts

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    As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.

  • A Tale Of 2 Trump Cases: The Rule Of Law Is A Live Issue

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    The U.S. Supreme Court’s decision this week in Trump v. U.S., holding that former President Donald Trump has broad immunity from prosecution, undercuts the rule of law, while the former president’s New York hush money conviction vindicates it in eight key ways, says David Postel at Henein Hutchison.

  • Industry Self-Regulation Will Shine Post-Chevron

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    The U.S. Supreme Court's Loper decision will shape the contours of industry self-regulation in the years to come, providing opportunities for this often-misunderstood practice, says Eric Reicin at BBB National Programs.

  • 3 Ways Agencies Will Keep Making Law After Chevron

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    The U.S. Supreme Court clearly thinks it has done something big in overturning the Chevron precedent that had given deference to agencies' statutory interpretations, but regulated parties have to consider how agencies retain significant power to shape the law and its meaning, say attorneys at K&L Gates.

  • Atty Well-Being Efforts Ignore Root Causes Of The Problem

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    The legal industry is engaged in a critical conversation about lawyers' mental health, but current attorney well-being programs primarily focus on helping lawyers cope with the stress of excessive workloads, instead of examining whether this work culture is even fundamentally compatible with lawyer well-being, says Jonathan Baum at Avenir Guild.

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