Federal

  • August 06, 2024

    Bressler Grows In NJ With New Litigation, Tax Experts

    Bressler Amery & Ross PC added longtime experts in tax law, trusts and estates, and commercial litigation in a recent round of expansion in New Jersey announced this week.

  • August 06, 2024

    Treasury Floats Rules To Address Losses Under Pillar 2

    The U.S. Treasury Department proposed regulations Tuesday that outline when foreign taxes under the Pillar Two international minimum tax agreement could trigger long-standing U.S. rules that aim to prevent companies from what is known as double-dipping the same economic loss.

  • August 06, 2024

    NC Software Execs Can't Unravel Payroll Tax Fraud Conviction

    Two former software executives found guilty of failing to pay over $600,000 in employment taxes failed to clear a steep hurdle in trying to reverse their convictions, a North Carolina federal judge said in rejecting their bid for acquittal or a new trial.

  • August 06, 2024

    Ex-UBS Exec Calls $4.7M In FBAR Penalties Unconstitutional

    A former executive for Swiss bank UBS' North American group told a Connecticut federal court the $4.7 million in penalties he faces for willful failure to report his foreign bank accounts are unconstitutionally excessive.

  • August 06, 2024

    Partnership Asks Tax Court To Toss $13M Credit Reduction

    An Idaho partnership asked the U.S. Tax Court to throw out an Internal Revenue Service adjustment that reduced the value of an energy investment tax credit by $13 million, saying it never claimed the credit in the first place.

  • August 06, 2024

    Arnold & Porter Adds Abramson Cancer Center Chief Counsel

    Throughout her career and while working in progressive leadership roles for the Abramson Cancer Center at the University of Pennsylvania, Mir Masud-Elias, Arnold & Porter Kaye Scholer LLP's newest counsel, has asked herself the same question: Is this role the best use of her time on Earth?

  • August 06, 2024

    Paul Hastings Gains Tax Pro In Dallas From McDermott

    Paul Hastings announced Tuesday that its meteoric growth in Texas is continuing with the addition of a partner in Dallas who strengthens its global tax practice and came aboard from McDermott Will & Emery LLP.

  • August 05, 2024

    9th Circ. Rejects Calif. Couple's Informal Tax Refund Bid

    A California couple who for years had a practice of overpaying their federal taxes missed a critical deadline to informally claim a nearly $700,000 tax overpayment, a Ninth Circuit panel ruled Monday, rejecting their request for a refund.

  • August 05, 2024

    FedEx Asserts Chevron Ruling Supports $84.6M Refund

    The U.S. Supreme Court's recent rejection of the Chevron doctrine entitles FedEx to an $84.6 million tax refund by taking credits for foreign taxes it paid on offset earnings when repatriating overseas income, the package delivery giant told a Tennessee federal court.

  • August 05, 2024

    Truck Co. Can't Skirt $500M Excise Tax Bill, US Tells 6th Circ.

    A Tennessee truck company failed to demonstrate its eligibility for a safe harbor that allowed it to escape from over $500 million in excise taxes and penalties over refurbished trucks it sold, the U.S. government told the Sixth Circuit, asking it to reverse a lower-court decision.

  • August 05, 2024

    Pension Plan Testimony Barred In $2B Danish Tax Fraud Case

    U.S. pension plans have proposed irrelevant expert testimony in response to allegations of their participation in a $2.1 billion Danish tax fraud scheme, a New York federal judge ruled in excluding the testimony but leaving room to try again.

  • August 05, 2024

    Dems Unearth Another Thomas Trip Paid For By Harlan Crow

    U.S. Supreme Court Justice Clarence Thomas took a previously undisclosed trip between Hawaii and New Zealand on a billionaire Republican donor's private jet in 2010, lawmakers revealed in a letter Monday that offered the donor a "final opportunity" to explain how that trip and others don't constitute a tax fraud scheme.

  • August 05, 2024

    Chamber Asking 4th Circ. To Revive Md. Digital Ad Tax Fight

    The U.S. Chamber of Commerce and other groups are seeking Fourth Circuit review of a federal district court decision throwing out their First Amendment complaint against Maryland's digital advertising tax, the groups told the lower court.

  • August 05, 2024

    3 Changes To IRS Direct File On Stakeholders' Wish Lists

    Organizations that partnered with the IRS or states on the free online tax filing system known as Direct File are seeking improvements in the program's second year, including allowing taxpayers to transfer more data from federal returns to state returns and enhancements for Spanish speakers. Here, Law360 looks at three changes sought by stakeholders.

  • August 05, 2024

    IRS Announces 2024 Senior Executive Review Board Members

    The Internal Revenue Service on Monday named the 99 employees who will make up the standing roster of its fiscal year 2024 Senior Executive Service Performance Review Boards.

  • August 02, 2024

    IRS Wrongly Attacking Installment Method Deals, Court Told

    The Internal Revenue Service mischaracterized installment sales as potentially abusive tax shelters in last year's rule proposing additional reporting requirements for such deals, an Idaho capital assets dealer told a federal district court.

  • August 02, 2024

    St. Louis Attys Can't Get Acquittal In $4M Tax Avoidance Case

    Two Missouri-based attorneys, a father and daughter duo found guilty of participating in a $4 million tax avoidance scheme, will not be granted a new trial or an acquittal, despite their assertions that a number of errors tainted their trial, a North Carolina federal judge ruled Friday.

  • August 02, 2024

    Ex-Loeb Tax Atty Latest Addition To Kilpatrick's NY Team

    A former Loeb & Loeb LLP attorney is bringing his experience in U.S. federal tax matters and real estate transactions to Kilpatrick Townsend & Stockton LLP, the firm announced Thursday.

  • August 02, 2024

    Sister-In-Law Ordered To Testify In Hunter Biden Tax Case

    A California federal judge ordered Hunter Biden's sister-in-law, with whom he was romantically involved, and her sister to testify at his upcoming criminal trial in which he is accused of scheming to avoid paying $1.4 million in taxes.

  • August 02, 2024

    Calls To Taxpayer Advocates Go To Voicemail, TIGTA Says

    The Treasury Inspector General for Tax Administration called all 76 local Taxpayer Advocate Service phone lines to test their availability and only had calls answered twice, it said Friday, calling on the service to improve its monitoring of the lines.

  • August 02, 2024

    Treasury Faces Complicated Path For Amount B Pricing Rules

    The U.S. Treasury Department signaled it is considering how to enact the OECD's routine pricing plan known as Amount B, but U.S. tax attorneys expect a complicated compliance exercise if rulemakers establish the new transfer pricing approach.

  • August 02, 2024

    Coca-Cola Poised To Appeal $2.7B Tax Bill With 11th Circ.

    The U.S. Tax Court signed off Friday on Coca-Cola's $2.7 billion tax bill, setting the stage for the beverage giant to appeal the liabilities and related rulings in its long-running dispute over the IRS' reallocation of the company's foreign income.

  • August 02, 2024

    IRS Tells Tax Court AbbVie's $1.6B Break Fee Is A Capital Loss

    The Internal Revenue Service correctly reclassified AbbVie's $1.6 billion break fee to an Irish biotechnology company as a capital loss, the agency told the U.S. Tax Court, arguing that the failed merger is tantamount to disposing of property.

  • August 02, 2024

    Taxation With Representation: Sullivan, Dechert, Kirkland

    In this week's Taxation With Representation, BNP Parabis SA acquires an investment management subsidiary for €5.1 billion, Cleveland accounting firm CBIZ merges with competitor Marcum for $2.3 billion, and Arcosa Inc. inks a deal with a family-owned construction materials business for $1.2 billion.

  • August 02, 2024

    Liberty Global's $110M Tax Refund Kosher, 10th Circ. Told

    The IRS is trying to block Liberty Global's bid for a $110 million tax refund by improperly using a legal doctrine requiring transactions to have economic substance, the telecommunications giant told the Tenth Circuit, arguing it was allowed to make tax-driven choices in the transactions at issue.

Expert Analysis

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.

  • Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules

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    Regulations recently proposed by the IRS and the U.S. Department of the Treasury concerning two types of tax credits for clean hydrogen production facilities should resolve many of the most pressing questions around qualification for the credits — albeit in a relatively stringent manner, say attorneys at Morgan Lewis.

  • Employee Experience Strategy Can Boost Law Firm Success

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    Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.

  • Lessons From Country Singer's Personal Service Saga

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    Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.

  • 5 Litigation Funding Trends To Note In 2024

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    Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.

  • Tech CEO Tax Ruling A Warning For Forward Contracts

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    In McKelvey v. Commissioner, the U.S. Tax Court decided that deceased Monster.com founder Andrew McKelvey terminated his underlying obligations when he extended variable prepaid forward contracts, demonstrating why startup founders, early employees and investors should think carefully before amending derivative agreements, say Daren Shaver and Trent Tanzi at Hanson Bridgett.

  • 4 Legal Ethics Considerations For The New Year

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    As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.

  • What The Law Firm Of The Future Will Look Like

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    As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • 4 PR Pointers When Your Case Is In The News

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    Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

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