Federal

  • 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.

  • July 16, 2024

    Connecticut Contractor Fined $1.75M For Tax Evasion

    A Connecticut contractor was ordered to pay a $1.75 million fine for evading federal corporate and individual income taxes from 2006 through 2010, the U.S. Department of Justice announced Tuesday.

Expert Analysis

  • Weisselberg's Perjury At Trial Spotlights Atty Ethics Issues

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    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.

  • Practicing Law With Parkinson's Disease

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    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.

  • 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.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    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.

  • Trump's NY Civil Fraud Trial Spotlights Long-Criticized Law

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    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.

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

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    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.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

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    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.

  • How IRA Unlocks Green Energy Investments For Tribes

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    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.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

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    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.

  • What To Know About IRS' New Jet Use Audit Campaign

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    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.

  • Stay Interviews Are Key To Retaining Legal Talent

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    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.

  • Judicial Independence Is Imperative This Election Year

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    As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.

  • Spartan Arbitration Tactics Against Well-Funded Opponents

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    Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.

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