Federal
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May 31, 2024
Fuel Producers Should Apply ASAP For Tax Credit, IRS Says
Fuel producers hoping to start claiming the clean fuel production credit as soon as January should register with the Internal Revenue Service by July 15, the agency said Friday, warning that registration applications made after that date are less likely to go through in time.
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May 31, 2024
IRS Delays Deadlines For Mass. Taxpayers Hit By 2023 Storms
Certain Massachusetts taxpayers impacted by severe storms and flooding that hit the state Sept. 11 now have until July 31 to file various individual and business tax returns and make payments, the Internal Revenue Service said Friday.
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May 31, 2024
Taxation With Representation: Cravath, Cleary, Fried Frank
In this week's Taxation With Representation, T-Mobile buys United States Cellular Corp.'s wireless operations, Energy Transfer plans to buy WTG Midstream, ConocoPhillips acquires Marathon Oil, and Goldman Sachs Alternatives raises over $20 billion for its direct lending strategy.
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May 30, 2024
Chicago Kiosk Salesman Gets 1 Year For Filing False Returns
An electronic-sweepstakes kiosk salesman from Chicago was sentenced to a year in prison for filing false tax returns that included more than $500,000 in inflated business expenses, according to Illinois federal court documents.
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May 30, 2024
IRS Adds 16 Tax Court Sessions To Calendar
The Internal Revenue Service announced 16 U.S. Tax Court sessions in September and October and named calendar administrators for the sessions in a notice released Thursday.
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May 30, 2024
Tax Court Nixes $30M In Conservation Easement Deductions
The U.S. Tax Court upheld on Thursday the IRS' rejection of more than $30 million in charitable contribution deductions for Alabama conservation easements for partnerships acting as test cases for a larger group that took $187 million in deductions.
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May 30, 2024
Tax Court Tosses Whistleblower Award Contest
The U.S. Tax Court ruled Thursday that it cannot review a woman's roughly $1,700 whistleblower award from the Internal Revenue Service because it does not meet a threshold for mandatory awards.
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May 30, 2024
IRS Names New Chief Taxpayer Experience Officer
The Internal Revenue Service has chosen an adviser in its Transformation and Strategy Office to serve as the agency's new chief taxpayer experience officer, according to a statement Thursday.
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May 30, 2024
Later Pillar 1 Due Date Set For June As Tax Talks Wrap Up
Diplomats agreed this week to finalize a treaty for reallocating some of large companies' tax payments and setting standards to simplify some transfer pricing in lower-income countries by June 30 after having missed a March deadline, according to a statement published Thursday by the OECD.
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May 30, 2024
Ex-KPMG Manager Joins Davis+Gilbert As Tax Partner
A former managing director at KPMG has joined New York law firm Davis+Gilbert LLP as a tax partner in its corporate and transactions practice, Davis+Gilbert announced.
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May 30, 2024
Black Business Owners Sue Over Impact Of Transparency Act
The Corporate Transparency Act creates unique burdens on businesses owned by people of color, immigrants and other marginalized groups, the Black Economic Council of Massachusetts and several company owners said in the latest legal challenge to the anti-money laundering law.
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May 30, 2024
Russian Gas Ex-CFO Says $44M FBAR Penalty Is Excessive
The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks told a Florida federal court that the $44 million in foreign account reporting penalties the government is seeking is illegally high.
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May 30, 2024
IRS To Make E-File Program Permanent, Plans Expansions
The Internal Revenue Service will make permanent the free online tax filing system it launched as a limited pilot program this year and plans to expand its scope, Commissioner Daniel Werfel said Thursday.
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May 29, 2024
10th Circ. Tosses Insurance Co. Appeal In Tax Court Dispute
The Tenth Circuit tossed an insurance company's challenge to a U.S. Tax Court ruling rejecting the company's effort to invalidate tax deficiency notices on Wednesday, saying it lacked authority to hear the case because the Tax Court's decision wasn't a final one that would end litigation.
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May 29, 2024
Miami Tax Preparers Should Be Barred For Fraud, DOJ Says
Two Miami-based tax professionals and their businesses should be barred from preparing federal tax returns for others because they repeatedly claimed fraudulent credits without their customers' knowledge, the U.S. Department of Justice told a Florida federal court.
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May 29, 2024
Baker McKenzie Grows Tax Practice With Ex-KPMG Adviser
Baker McKenzie announced the hiring of an experienced Chicago-based tax adviser as a principal who most recently spent sixteen and a half years at Big Four accounting firm KPMG.
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May 29, 2024
Presidential Candidate Convicted For $15.5M Tax Fraud
A tax-preparation business owner and 2024 presidential candidate was convicted on 33 counts of tax fraud after being accused of inflating deductions in a scheme federal prosecutors said caused more than $15.5 million in tax losses, according to Texas federal court documents.
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May 29, 2024
Treasury Details Which Tech Would Get Clean Energy Credits
Treasury released proposed rules Wednesday outlining which technologies would qualify for new zero-emission energy tax credits, saying wind, solar and geothermal are among those that would make the cut.
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May 28, 2024
Preserving Enhanced LITC Funding Could Aid Tax System
Lawmakers haven't yet enacted funding levels for low-income taxpayer clinics for 2025, but they could grease the wheels of tax administration by preserving enhanced funding for the clinics, which helps more taxpayers comply with the law, reducing the burden on the IRS.
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May 28, 2024
Mich. Doctor Denied Release From Contempt In FBAR Fight
A Michigan doctor will stay jailed for civil contempt after a federal judge found Tuesday that he failed to back up claims that he cannot pay his more than $1 million in foreign bank account reporting penalties due to a bank's bankruptcy and his criminal history.
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May 28, 2024
Biz Groups Back BofA In Merger Interest Tax Fight At 4th Circ.
Business groups told the Fourth Circuit on Tuesday that they supported Bank of America in its fight against a North Carolina federal court ruling that found the bank wasn't entitled to net the interest on the tax liabilities of Merrill Lynch after the two companies merged.
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May 28, 2024
Wisconsin Atty Gets 5½ Years For $2.3M Fraud, Tax Evasion
An attorney licensed in Wisconsin has been sentenced to 5½ years in federal prison and ordered to pay around $2.3 million in restitution for her involvement in multiple fraud schemes, the U.S. Department of Justice announced Tuesday.
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May 28, 2024
Home Care Co. Says It's Owed $1.1M In Pandemic Tax Credits
The IRS has unfairly delayed paying a home healthcare service in Pennsylvania more than $1.1 million in pandemic-era employee retention tax credits while the agency claims to be checking that the business doesn't owe taxes, the company told a federal court.
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May 28, 2024
Global Tax Body Provides Crypto Risk Assessment Red Flags
The Internal Revenue Service and four international tax authorities issued an advisory to financial institutions on the dangers of cryptocurrency in relation to tax evasion, money laundering and other illicit activities, identifying certain risk factors worth their attention.
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May 28, 2024
Tax Lawyer Rejoins Mayer Brown In DC From Latham
Mayer Brown LLP has rehired a tax partner from Latham & Watkins LLP, who joins the firm in Washington, D.C., to continue working with clients to best utilize renewable energy tax credits, the firm announced Tuesday.
Expert Analysis
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Pro Bono Work Is Powerful Self-Help For Attorneys
Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.
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The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'
The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.
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Newman Suspension Shows Need For Judicial Reform
The recent suspension of U.S. Circuit Judge Pauline Newman following her alleged refusal to participate in a disability inquiry reveals the need for judicial misconduct reforms to ensure that judges step down when they can no longer serve effectively, says Aliza Shatzman at The Legal Accountability Project.
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How And Why Your Firm Should Implement Fixed-Fee Billing
Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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How Law Firms Can Use Account-Based Marketing Strategies
Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.
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While Risks Exist, AI Could Transform IRS Enforcement
The Internal Revenue Service's recently announced use of artificial intelligence could revolutionize the agency's enforcement efforts, and transparency about its use and a forum for challenging AI findings could help mitigate fears that the technology will increase bias, say attorneys at Lewis Brisbois.
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Strategic Succession Planning At Law Firms Is Crucial
Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.
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Maximizing Law Firm Profitability In Uncertain Times
As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.
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Enforcement Of International Tax Reporting Is Heating Up
Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.
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How Gov't Agencies Will Fare In The Event Of A Shutdown
With a federal shutdown potentially set to begin at the end of this month, it may be useful to consider the approximate timelines that agencies such as the Federal Trade Commission and IRS have announced for curtailing operations, and potential strategies for mitigating challenges that may arise while agency functions are limited, say attorneys at Cleary.
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IRS Notice Clarifies R&E Amortization, But Questions Remain
The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.
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Preparing Your Legal Department For Pillar 2 Compliance
Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.
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What Large Language Models Mean For Document Review
Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.