Federal
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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October 10, 2024
Estimated Tax Gap For 2022 Falls To $696B, IRS Says
The projected federal gross tax gap between taxes owed and taxes paid for the 2022 tax year was $696 billion, a $12 billion decrease from 2021, according to a report published Thursday by the Internal Revenue Service.
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October 10, 2024
Partnership Challenges Denial Of $42M Easement Deduction
The Internal Revenue Service failed to justify rejecting a Florida partnership's charitable contribution deduction for donating a $42 million conservation easement to a land conservancy, the partnership told the U.S. Tax Court.
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October 10, 2024
IRS Says It's Stepping Up Worker Credit Claims Processing
The Internal Revenue Service said Thursday it's accelerating processing of claims for pandemic-era worker credits after a moratorium triggered by what the agency has said was widespread fraud.
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October 10, 2024
Dems Weigh Extending 2017 Cuts To Maintain $400K Tax Vow
Despite criticizing the 2017 Republican tax overhaul as a deficit-busting boon to the wealthy, congressional Democrats may feel pressure to support extending some of the law's individual and small-business provisions or risk breaking their pledge not to raise taxes on those earning $400,000 or less.
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October 10, 2024
Pfizer Lone Holdout In Senate Pharma Tax Probe, Wyden Says
Pfizer Inc. is the only company to withhold a country-by-country breakdown of its tax planning in the Senate Finance Committee's probe into how Republicans' 2017 tax package reduced the pharmaceutical industry's U.S. liabilities, according to a letter Chairman Ron Wyden released Thursday.
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October 10, 2024
Calif. Says FDIC Must Wait For $21M Tax Refund
A California tax agency urged a New York federal court to toss a lawsuit by the FDIC seeking a $20.7 million tax refund on behalf of the shuttered Signature Bank, saying it's entitled to wait for a possible IRS audit before delivering the payment.
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October 10, 2024
IRS Keeping Co. In Dark On Carryback Refund, Court Told
The Internal Revenue Service owes a $686,000 tax refund to a contractor for a carryback operating loss, the company told a Texas federal court, adding that the IRS hasn't responded to questions about a letter the agency claims it sent addressing the issue.
Expert Analysis
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This Earth Day, Consider How Your Firm Can Go Greener
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.
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Energy Community Tax Credit Boost Will Benefit Wind Sector
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.
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Weisselberg's Perjury At Trial Spotlights Atty Ethics Issues
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.
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Practicing Law With Parkinson's Disease
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.
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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.
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For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill
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.
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Trump's NY Civil Fraud Trial Spotlights Long-Criticized Law
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.
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Requiring Leave To File Amicus Briefs Is A Bad Idea
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.
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4 Ways To Motivate Junior Attorneys To Bring Their Best
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.
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How IRA Unlocks Green Energy Investments For Tribes
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.
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Former Minn. Chief Justice Instructs On Writing Better Briefs
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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What To Know About IRS' New Jet Use Audit Campaign
The Internal Revenue Service recently announced plans to open several dozen audits scrutinizing executive use of company jets, so companies should be prepared to show the business reasons for travel, and how items like imputed income and deduction disallowance were calculated, say attorneys at Morgan Lewis.
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Stay Interviews Are Key To Retaining Legal Talent
Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.