Federal
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August 12, 2024
UN Eyes Two Early Changes For Tax Pact In Latest Draft
Diplomats would draft two legally binding protocols under the United Nations framework convention on international tax cooperation while creating the convention itself under the latest draft guidance for negotiators after they select from a shortlist of possible topics, including the digital economy and wealth taxation.
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August 12, 2024
IRS Lacks Broad Plan To Replace Old IT Systems, TIGTA Says
The Internal Revenue Service lacks an agency-wide program to identify and then update, replace or retire legacy information technology systems, the Treasury Inspector General for Tax Administration reported Monday.
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August 12, 2024
Past Tax Ideas Offer Insight Into A Harris-Walz Presidency
An analysis of tax proposals previously put forth by Vice President Kamala Harris and Minnesota Gov. Tim Walz, the Democrats' presumptive nominees for president and vice president, indicates they could pursue a tax agenda geared toward providing tax relief to middle- and lower-income Americans.
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August 12, 2024
FedEx Misreads Chevron Ruling In $85M Tax Dispute, US Says
FedEx wrongly believes the recent U.S. Supreme Court decision overturning the Chevron doctrine precludes the U.S. Treasury Department from promulgating regulations to stop tax cheats and prevent FedEx from claiming $84.6 million in tax credits, the U.S. government told a Tennessee federal court.
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August 12, 2024
Judge OKs IRS To Review Bank Docs Of Exec In Bitcoin Probe
The Internal Revenue Service can review the sequestered bank records of a cryptocurrency executive charged in a 2020 bitcoin fraud investigation, a Texas federal judge ruled, finding the agency had properly notified the executive and his company of summonses it had issued to their banks.
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August 12, 2024
Transparency Act Snowball Fears A 'Mirage,' Treasury Says
The U.S. Department of the Treasury is seeking to quell fears that the Corporate Transparency Act's disclosure requirements could set the stage for more invasive government data collection in a brief asking a Michigan federal judge to uphold the law as constitutional.
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August 12, 2024
IRS Extends Tax Deadlines For Minn. Storm Victims
Minnesota taxpayers affected by severe storms and flooding have until February to file tax returns and make payments, the Internal Revenue Service said Monday.
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August 12, 2024
2 Experts OK'd For Danish Tax Agency In $2.1B Fraud Case
Two experts will be allowed to testify in support of a suit by Denmark's tax agency accusing U.S. pension plans of participating in a $2.1 billion tax refund fraud scheme, a New York federal district court said, overruling the pension plans' objections.
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August 12, 2024
'Survivor' Winner Is True Owner In Property Dispute, US Says
The winner of the first "Survivor" television season is the true owner of disputed property that should be sold to pay down his $3.3 million in tax liabilities, the government told a Rhode Island federal court, rejecting claims that his sister is the owner.
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August 10, 2024
Kyocera Targets Treasury TCJA Reg, Seeking $7M Tax Refund
The Treasury Department acted outside its bounds by issuing a regulation changing the effective date of the 2017 tax overhaul, electronics maker Kyocera argued as it urged a South Carolina federal court to void the regulation and approve the company's claim for $7 million tax refund.
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August 09, 2024
6th Circ. Partially Revives Crypto IRS Reporting Challenge
The Sixth Circuit issued a mixed ruling Friday in a suit brought by a group of cryptocurrency users challenging the IRS' pending mandate to report large crypto transactions, reversing the dismissal of the suit's Fourth and First Amendment violation claims but affirming that some of the case's claims are not ripe.
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August 09, 2024
Partnership Clarity Expected In First Offshore Profits Rules
Tax attorneys anticipate answers to several questions about how partnerships should properly track, report and attribute foreign income previously taxed in the U.S. when the first round of long-awaited proposed rules is published.
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August 09, 2024
3rd Circ. Kicks $1M Case To Tax Court Over IRS Violation
The Third Circuit sent a man's protest of a lien seeking over $1 million in unpaid employee payroll taxes back to the U.S. Tax Court on Friday because the IRS violated an automatic stay on the proceedings triggered by a bankruptcy proceeding.
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August 09, 2024
IRS Wrongly Penalizes For Unreported Inheritance, Court Told
The Internal Revenue Service violated the constitutional rights of a California woman when penalizing her $92,000 for failing to report inheriting $350,000 from a parent who had lived in the U.K., the woman told a federal court.
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August 09, 2024
Israel Resident Says She Was Never Notified Of $9M Tax Debt
The daughter of a dead Brooklyn rabbi was a permanent resident of Israel in the early years of this century and never received IRS notices about $9.2 million in taxes and penalties, she told a New York court Friday in arguing that she doesn't owe the money.
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August 09, 2024
IRS Delays Tax Deadlines In 4 States After Hurricane Debby
Following Hurricane Debby, all South Carolina taxpayers as well as many in Florida, North Carolina and Georgia will now be given until Feb. 3 to file individual and business tax returns and make payments, the Internal Revenue Service said Friday.
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August 09, 2024
Pa. Firm Seeks Over $790K In Employee Retention Credit
The Internal Revenue Service has failed to pay Ostroff Injury Law PC the more than $790,000 it is owed in pandemic-era employee retention credits, the Pennsylvania firm alleges in a federal court complaint, despite satisfying two separate tests the firm says qualify it for the relief.
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August 09, 2024
IRS Direct File To Be Offered In Connecticut Next Year
The Internal Revenue Service's free electronic tax filing program known as Direct File will be available in Connecticut for the 2025 tax filing season, the agency and the U.S. Department of the Treasury announced Friday.
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August 09, 2024
7 Taxpayer Advocacy Panel Committees To Meet In September
Seven Taxpayer Advocacy Panel committees will meet in September to discuss possible improvements to customer services, the Internal Revenue Service said Friday.
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August 09, 2024
IRS Updates Digital Asset Form For Custodial Brokers
The Internal Revenue Service released a revised draft form Friday for brokers to report their digital asset sales, which reflects the treatment of custodial industry participants in final regulations and the transitional relief for filers that fail to report the transactions.
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August 09, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included final regulations that clarify potential situations that could trigger an anti-abuse rule that covers transactions involving foreign corporations.
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August 09, 2024
What Books Tax Pros Recommend For This Summer
As practitioners monitor the tax implications of the U.S. presidential election as well as what might come out of the next European Commission, they may want to take a break with a good book. Here, Law360 takes a look at tax specialists' summer reading recommendations.
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August 09, 2024
Taxation With Representation: Latham, Freshfields, Wachtell
In this week's Taxation With Representation, Quantum Capital Group agrees to a roughly $3 billion deal for Cogentrix Energy, Apax Partners LLP is acquiring Thoughtworks for roughly $1.75 billion, and Mallinckrodt inks a $925 million deal for Therakos.
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August 08, 2024
Cayman Co. Owes Tax On Partners' Income, Tax Court Says
A Cayman Islands partnership is liable for withholding taxes on the share of about $24.8 million in income from its U.S. operations that was allocated to its foreign partners through special purpose vehicles, the U.S. Tax Court said Thursday.
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August 08, 2024
IRS Agents Seek To Join Hunter Biden's Tax Privacy Case
Accusations of wrongdoing against two Internal Revenue Service whistleblowers who said the government downplayed tax fraud allegations against Hunter Biden give the pair standing to intervene in Biden's privacy case against the U.S. government, the men told a federal court.
Expert Analysis
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Understanding The IRC's Excessive Refund Claim Penalty
Taxpayers considering protective refund claims pending resolution of major questions in tax cases like Moore v. U.S., which is pending before the U.S. Supreme Court, should understand how doing so may also leave them vulnerable to an excessive refund claim penalty under Internal Revenue Code Section 6676, say attorneys at McDermott.
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Don't Use The Same Template For Every Client Alert
As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.
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Think Like A Lawyer: Follow The Iron Rule Of Trial Logic
Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.
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The Art Of Asking: Leveraging Your Contacts For Referrals
Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.
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IRS Sings New Tune: Whistleblower Form Update Is Welcome
In a significant reform at the Internal Revenue Service's Whistleblower Office, the recently introduced revisions to the Form 211 whistleblower award application use new technology and a more intuitive approach to streamline the process of reporting allegations of tax fraud committed by wealthy individuals and companies, says Benjamin Calitri at Kohn Kohn.
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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.