Federal
-
December 16, 2024
IRS Corrects Regs On Direct Pay Of Partnership Tax Credit
Internal Revenue Service issued a correction Monday to final regulations that make it easier for tax-exempt entities that co-own development projects to qualify for a direct cash payment of clean energy tax credits by electing out of their partnership tax status.
-
December 16, 2024
LegalZoom Launches Strategic Alliance With 1-800Accountant
LegalZoom announced Monday that it will launch a multiyear strategic partnership with financial services firm 1-800Accountant by the start of the new year.
-
December 14, 2024
IRS Criminal Probes On Worker Retention Cases Still Early
The Internal Revenue Service's criminal arm is still in the early stage of investigating the most extremely fraudulent claims of a tax credit intended to reward businesses for retaining employees during the COVID-19 pandemic, an official said Saturday.
-
December 13, 2024
IRS Aims To Ramp Up Partnership Audits, Official Says
The Internal Revenue Service plans to ramp up partnership audits in the next couple of years to boost the current audit rate of 0.05% as the agency props up a new unit that solely focuses on examining large partnerships, an agency attorney said Friday.
-
December 13, 2024
IRS To Wrap Up Worker Retention Credits In 2025, Werfel Says
The Internal Revenue Service plans to wrap up processing next year for thousands of claims for tax credits meant to provide incentives for businesses that retained employees during the COVID-19 pandemic, agency Commissioner Daniel Werfel said Friday.
-
December 13, 2024
IRS Extends Relief For Partnership Exchange Filing Penalties
The Internal Revenue Service on Friday extended its temporary pause on imposing penalties on taxpayers who failed to provide correct payee statements as part of a partnership interest exchange to those that failed to do so in 2024.
-
December 13, 2024
CFC Tax Issues Can't Be Solved Via Treaties, Officials Say
Bilateral treaties between the U.S. and other countries where a controlled foreign corporation may face withholding tax issues aren't able to effectively resolve those disputes, Internal Revenue Service and Treasury officials said Friday.
-
December 13, 2024
IRS Mulls Turning Off Foreign Currency Rules For CFCs
The Internal Revenue Service is in the early stages of considering whether foreign currency gain or loss recognition rules could be turned off in certain situations for controlled foreign corporations, an agency official said Friday.
-
December 13, 2024
Feds Narrow Drug Case Against Wife Of Convicted Drexel Prof
Prosecutors have told a New Jersey federal judge that they would drop one of three drug distribution charges against the wife of a convicted former Drexel University professor, saying their evidence might not establish intent after the U.S. Supreme Court raised the burden of proof for such cases in 2022.
-
December 13, 2024
Halliburton Consistent On Claims For $35M Refund, Court Told
Halliburton has not changed its reasons for claiming a tax refund on a $35 million payment it made to a foreign government to protect its employees from harassment, the company told a Texas federal court, saying the U.S. wrongly accused it of a flip-flop.
-
December 13, 2024
Taxation With Representation: Kirkland, Davis Polk, Wachtell
In this week's Taxation With Representation, Google and TPG Rise Climate partner with Intersect Power, Gen Digital Inc. acquires MoneyLion Inc., Patient Square Capital acquires Patterson Companies Inc., and the Buffalo Bills and Miami Dolphins sell minority ownership shares to private equity firms.
-
December 13, 2024
Contractor Loses Bail For Texting Alleged Tax Cheat Allies
A District of Columbia federal judge revoked bail for a former defense contractor accused of running a $350 million tax-evasion scheme that prosecutors call one of the largest in U.S. history, after the government said he'd been texting his alleged co-conspirators.
-
December 13, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included final regulations for the advanced manufacturing production credit for manufacturing key components and materials used in clean energy technologies.
-
December 13, 2024
Loper Bright May Influence Tax Less, IRS Chief Counsel Says
The U.S. Supreme Court decision this year overturning a decades-long standard to defer to federal agencies' regulatory interpretations has encouraged the Internal Revenue Service to better explain its rules, its outgoing chief counsel said Friday.
-
December 12, 2024
'Housewives' Figure Touts Social Media Posts In Leniency Bid
Former "Real Housewives of Atlanta" cast member Peter Anthony Thomas asked a North Carolina federal judge on Thursday to give him a prison sentence below federal guidelines for not paying $2.5 million in employment taxes, stating he has used his public platform to encourage his followers to pay their own taxes.
-
December 12, 2024
Bitcoin Investor Gets 2 Years For Tax Fraud In Landmark Case
An investor who concealed millions of dollars he earned in bitcoin and became the first person criminally charged for failing to report gains from the sale of cryptocurrency by filing false returns was sentenced to two years in federal prison Thursday.
-
December 12, 2024
IRS Wants Choice Retained In Dual Loss Rules, Official Says
The Internal Revenue Service is working to preserve flexibility for taxpayers in rules aimed at preventing companies from using the same economic loss twice after concerns were raised about how the rules could negatively interact with the Pillar Two global minimum tax, an official said Thursday.
-
December 12, 2024
IRS Seeks Feedback On Limits In Previous Taxed Profit Rules
The Internal Revenue Service will consider whether rules included in recently proposed guidance on previously taxed earnings and profits to limit instances where U.S. multinationals may use basis to offset gain are too restrictive, an official said Thursday.
-
December 12, 2024
IRS Chief Makes Case To Restore $20B Funding Shortfall
Congress should reverse a $20 billion IRS funding gap in a year-end budget bill to help the agency modernize its technology, improve customer service and collect unpaid taxes from wealthy businesses and individuals, Internal Revenue Commissioner Daniel Werfel said Thursday.
-
December 12, 2024
2nd Circ. Won't Rethink Dual Citizen's FBAR Penalties
The Second Circuit will not review its September decision finding that a dual U.S.-French citizen is liable for tax penalties for failing to file reports of foreign bank and financial accounts, the court said Thursday.
-
December 12, 2024
IRS Expands Business Tax Account Program To Corp. Leaders
The Internal Revenue Service's business tax account online self-service tool is now available to C corporations, while the agency is opening access to the program to certain officers of both C and S corporations, the agency said Thursday.
-
December 12, 2024
IRS Hopes To Issue Amount B Pricing Guidance Within Weeks
Treasury is working to finish its guidance on the simplified transfer pricing approach to baseline marketing and distribution known as Amount B by the end of the year, a U.S. official said Thursday.
-
December 12, 2024
Ex-FBI Informant Admits To False Accusations In Biden Case
A former FBI informant accused of making fake criminal accusations against President Joe Biden and his son, Hunter Biden, will plead guilty to tax evasion and falsifying records in a federal investigation, according to a deal filed Thursday in a California federal court.
-
December 12, 2024
Treasury Seeks To Pause Anti-Laundering Law Injunction
The U.S. Treasury Department asked a Texas federal judge to pause his nationwide preliminary injunction of the Corporate Transparency Act pending an appeal of his recent decision that found Congress likely overstepped its constitutional authority when it wrote the anti-money laundering law.
-
December 12, 2024
IRS Electronic Tax Committee To Meet In January
The Internal Revenue Service's Electronic Tax Administration Advisory Committee will hold its next meeting Jan. 8, the agency said Thursday.
Expert Analysis
-
SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
-
Planning A Defense As IRS Kicks Off Sports Losses Campaign
Sports team owners and partnerships face potential examination under the Internal Revenue Service’s recently announced sports industry losses campaign, and should be preparing to explain what drove their reported losses and assembling documentation to support their tax return positions and accounting methods, say Sheri Dillon and Jennifer Breen at Morgan Lewis.
-
What New Calif. Strike Force Means For White Collar Crimes
The recently announced Central District of California strike force targeting complex corporate and securities fraud — following the Northern District of California's model — combines experienced prosecutorial leadership and partnerships with federal agencies like the IRS and FBI, and could result in an uptick in the number of cases and speed of proceedings, say attorneys at MoFo.
-
Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.
-
The Legal Industry Needs A Cybersecurity Paradigm Shift
As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.
-
As Promised, IRS Is Coming For Crypto Tax Evaders
The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.
-
5 Reasons Associates Shouldn't Take A Job Just For Money
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
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
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
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
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
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
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.