Federal

  • July 18, 2024

    Most Top US Cos. To Report Tax Under Aussie Bill, Study Says

    Australia's Senate is expected to consider adoption next month of the world's most extensive public country-by-country reporting rules, which would require 51% of large U.S. multinational corporations to disclose tax arrangements retroactively from July 1, according to a study published Thursday.

  • July 18, 2024

    Final IRS Rules Require Beneficiaries To Take Distributions

    Beneficiaries of retirement account owners who died after starting to take distributions must continue taking the distributions annually, the Internal Revenue Service said Thursday in final regulations on required minimum distributions that rejected feedback saying the requirement was overly complex.

  • July 18, 2024

    Rising Star: Latham's Eric Kamerman

    Eric Kamerman of Latham & Watkins LLP in recent years handled the tax aspects of several multibillion-dollar acquisitions of powerhouses in British soccer and American fashion, earning him recognition as one of the tax attorneys under age 40 honored by Law360 as Rising Stars.

  • July 18, 2024

    IRS Issues Corp. Bond Monthly Yield Curve For July

    The Internal Revenue Service published Thursday the corporate bond monthly yield curve for July for use in calculations for defined benefit plans, as well as corresponding segment rates and other related provisions.

  • July 18, 2024

    Man Can't Annul Agreement To Pay $2M In Taxes, Court Told

    A federal district court should force a Florida man to pay the over $2 million in taxes, interest and penalties he owes despite his change of heart about an agreement regarding his deficient filings, the government said.

  • July 18, 2024

    Top International Tax Cases To Watch In The 2nd Half Of 2024

    Tax attorneys will be tracking several high-stakes cases in the second half of 2024 that could define the bounds of the IRS' ability to craft regulations or lodge direct challenges aimed at what it sees as the tax avoidance maneuvers of multinational corporations. Here, Law360 looks at key international tax cases to follow during the rest of the year.

  • July 17, 2024

    Much Of Pillar 1 Treaty Agreed On, OECD Official Says

    Agreement has been reached on the bulk of a multilateral pact to implement new taxing rights that are part of a revamp of the international tax system and on expansions to a part of the taxing rights plan, an OECD official said Wednesday.

  • July 17, 2024

    Tax Court OKs Added Penalty Over Nixed $20.7M Deduction

    The U.S. Tax Court found Wednesday that a Georgia partnership should be assessed a negligence penalty alongside a previously assessed accuracy penalty tied to a disallowed $20.7 million charitable contribution deduction, agreeing with an argument by the IRS.

  • July 17, 2024

    Spouse Relief Not Available For Errant Refund, Tax Court Says

    A Maryland woman who along with her husband received an erroneous refund from the Internal Revenue Service isn't entitled to innocent spouse relief because that relief is available only for unpaid taxes or deficiencies, the U.S. Tax Court said Wednesday.

  • July 17, 2024

    Tax Court Nixes $22.6M Deduction For Historic Renovation

    The U.S. Tax Court denied Wednesday a $22.6 million deduction to a partnership for a conservation easement on its 11-story historic building in downtown Cleveland, saying the easement did not prevent the scale of development on the property that the partnership had claimed.

  • July 17, 2024

    Tax Court Says IRA Deduction Claim Correctly Rejected

    The Internal Revenue Service correctly disallowed a New Hampshire couple's claimed individual retirement account deduction because they never actually made a contribution to such an account, the U.S. Tax Court said Wednesday.

  • July 17, 2024

    Gov't Views On OECD Risk Guidance Vary, Economists Say

    In allocating risk among different components of a business for transfer pricing purposes, analysts need to consider governments' varying interpretations of guidance from the Organization for Economic Cooperation and Development, a panel of economists said Wednesday.

  • July 17, 2024

    Connell Foley Adds Wilson Elser Tax Pro In Group Upgrade

    Connell Foley LLP strengthened its tax and estate team this week with the promotion of several attorneys up to partner and the addition of a mergers and acquisitions and corporate restructuring tax expert previously of counsel at Wilson Elser Moskowitz Edelman & Dicker LLP.

  • July 17, 2024

    The Tax Angle: Child Care, Medical Debt, Small Biz Relief

    As talks take place on Capitol Hill over the impact the expiration of the Tax Cuts and Jobs Act will have on small businesses and child care, here's a peek into a reporter's notebook on a few developing tax stories.

  • July 17, 2024

    IRS Plans August Hearing On Stock Buyback Tax Rules

    The Internal Revenue Service will hold a public hearing Aug. 27 on proposed regulations governing a new excise tax on repurchases of corporate stock, the agency said Wednesday.

  • July 17, 2024

    IRS Issues Fixes For Clean Electricity Credit Regs

    The Internal Revenue Service issued corrections Wednesday that it said fix a number of errors in proposed regulations concerning the clean electricity production and investment tax credits established by the Inflation Reduction Act.

  • July 17, 2024

    Treasury Finalizes Rules To Target 'Killer B' Transactions

    The U.S. Treasury Department published final regulations Wednesday aimed at so-called Killer B transactions, which involve certain corporate reorganizations with at least one foreign affiliate that ultimately allow U.S. companies to avoid domestic taxes.

  • July 17, 2024

    Rising Star: Cravath's Kiran Sheffrin

    Kiran Sheffrin of Cravath Swaine & Moore LLP has advised companies from Anheuser-Busch InBev to Valvoline on multibillion-dollar deals, including a $50 billion combination resulting in the formation of pharmaceutical giant Viatris, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 17, 2024

    Woman Can't Escape Suit Over Partner's $1.1M FBAR Debt

    A woman whose late romantic partner owed $1.1 million in reporting penalties on hidden financial accounts in France and Switzerland can't stop the government from pursuing a suit against her for half the value of her home, a New York federal court ruled.

  • July 17, 2024

    Baker McKenzie Adds EY Partner To Mexico City Office

    Baker McKenzie has appointed a new partner from EY Mexico to its North American tax practice group in Mexico City.

  • July 16, 2024

    Intracompany Prices Should Reflect Acquired IP, Panelists Say

    When one company buys another for its intellectual property, the subsequent pricing of that asset between the now-related entities should reflect the value of what was acquired, transfer pricing specialists said Tuesday at a conference in Washington, D.C.

  • July 16, 2024

    More Geographic Adjustments 'On The Table' For Amount B

    Countries' ability to make further adjustments for geographic differences in the streamlined transfer pricing approach known as Amount B — part of the OECD's plan for reallocating taxing rights among jurisdictions — is "still on the table," an official from the organization said Tuesday.

  • July 16, 2024

    Tycoon's Pilot Says Feds' Stock Tip Claims Don't Add Up

    A private pilot who used to work for convicted insider trader and U.K. billionaire Joe Lewis is arguing federal prosecutors can't use allegations that his own trades were suspicious to ramp up a sentence for a separate tax evasion charge.

  • July 16, 2024

    7th Circ. Says Foreign Retirement Not Shielded In Bankruptcy

    A professor who filed for bankruptcy in Illinois can't protect his Canadian retirement account from creditors because the account is ineligible under a state law shielding accounts that qualify as retirement plans under the Internal Revenue Code, the Seventh Circuit ruled Tuesday.

  • July 16, 2024

    Tax Court Grants Installment Gain Recognition On Stock Sales

    The U.S. Tax Court rejected Tuesday a claim by the IRS that a man and his cousin who had each sold stock in 2002 to an employee stock ownership trust for more than $4 million had to recognize the entirety of their deferred gain the following year.

Expert Analysis

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    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

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    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

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    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

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    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

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    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

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    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

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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.

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