Federal

  • September 27, 2024

    IRS Hopes To Clarify 'Friendly Doctor' Arrangements

    The Internal Revenue Service hopes to release general guidance on arrangements in which a physician's business can be run by a separate entity, known as friendly doctor arrangements, an agency official said Friday.

  • September 27, 2024

    Corp. AMT Rules Could Wrap In Smaller Partnerships

    Recently proposed rules on the U.S. corporate alternative minimum tax create new concerns for partnerships of various sizes that could be forced to comply with complex reporting requirements unless the government introduces carveouts, tax observers said.

  • September 27, 2024

    IRS Told To Improve Notices Of Disaster-Related Delays

    An estimated 390,000 taxpayers in federal emergency and disaster areas may have paid the balances owed on their taxes before a postponed due date because of Internal Revenue Service notices that did not clearly inform taxpayers of the postponement, the Treasury Inspector General for Tax Administration said Friday.

  • September 27, 2024

    Taxation With Representation: Kirkland, Skadden, Cleary

    In this week's Taxation With Representation, Blackstone and Vista Equity Partners acquire Smartsheet Inc., Macquarie Asset Management takes a stake in D.E. Shaw Renewables Investment Group, and Apogee Enterprises Inc. buys UW Interco LLC from Heartwood Partners.

  • September 27, 2024

    US Trade Group Pushes OECD On Compliance Burden

    The Organization for Economic Cooperation and Development needs to do more work on the safe harbor provisions of its Pillar Two 15% global corporate minimum tax plan — including potentially making it permanent — among other compliance burden concerns, the National Foreign Trade Council said Friday.

  • September 27, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included a U.S. Treasury Department decision to drop a rule that would have set a zero value for the property of an estate that is not declared on the estate's tax return or is discovered after the return is filed.

  • September 26, 2024

    Tax Court Rejects Gasoline Deductions For Stove Store Owner

    The owner of a New York stove and fireplace store had about $1 million in receipts for 2014 and isn't entitled to deduct gasoline and depreciation expenses, the U.S. Tax Court said Thursday, sustaining most of a determination made by the Internal Revenue Service.

  • September 26, 2024

    Montreal Exchange Is A Qualified Exchange, IRS Says

    The Montreal Exchange is a qualified board or exchange for purposes of mark-to-market contracts under Internal Revenue Code Section 1256(g)(7)(C), the Internal Revenue Service said Thursday. 

  • September 26, 2024

    IRS Rolls Out Process to Fix Worker Credit Claims

    The Internal Revenue Service has started a supplemental claim filing process to allow third-party payers who handle tax and payroll reporting for clients to fix incorrect unprocessed claims for the employee retention credit, the agency said Thursday.

  • September 26, 2024

    Collection Agents Need Representation Guidance, TIGTA Says

    The Internal Revenue Service needs to provide guidance for private collection agency employees for cases in which taxpayers request a representative, such as an attorney, while on a call, the Treasury Inspector General for Tax Administration said Thursday.

  • September 26, 2024

    IRS Hiring Up, But Process Often Takes Too Long, TIGTA Says

    While the Internal Revenue Service increased its hiring by 41% between fiscal years 2022 and 2023, it took longer than the agency's 80-day target to hire over 35% of the nearly 53,000 new employees due to numerous problems, the Treasury Inspector General for Tax Administration said Thursday.

  • September 26, 2024

    Tariff Tax Base Too Small To Replace Income Tax, Report Says

    Higher tariffs can't replace income tax revenue, as former President Donald Trump has suggested, since U.S. imports total $3 trillion annually while incomes top $20 trillion, but they would lower incomes by raising prices for U.S. consumers, a think tank reported Thursday.

  • September 26, 2024

    Oil Estate Must Boost Value By $6M, Tax Court Says

    The estate of a woman who inherited an oil company must include in its value over $6 million more to account for her relationship with a limited partnership formed by her great-nephew, the U.S. Tax Court ruled Thursday.

  • September 26, 2024

    Harris' And Trump's Tax Plans Each Add To Deficit, Study Says

    The U.S. federal deficit would grow by at least $2 trillion over the next decade from the tax policy plans of both major parties' candidates, former President Donald Trump and Vice President Kamala Harris, researchers said Thursday.

  • September 26, 2024

    Texas Energy Co. Is Owed $8.1M Research Credit, Court Told

    An energy company that said it developed a method for recycling water produced by fracking is owed $8.1 million in tax credits for research related to developing new oil production methods in the U.S. and Canada, the company told a Texas federal district court.

  • September 26, 2024

    Senate Confirms Two More Tax Court Judges

    The U.S. Senate approved two more of President Joe Biden's nominees to serve on the U.S. Tax Court, marking the fourth and fifth judges the chamber has confirmed to the court in the past two months.

  • September 25, 2024

    Remote Sales Tax Compliance Burdens Small Biz, Senate Told

    The 2018 Wayfair decision has burdened small businesses with significant compliance costs to collect and remit taxes in thousands of jurisdictions across the U.S., state tax experts told a U.S. Senate subcommittee Wednesday.

  • September 25, 2024

    Accountant Used Fake Tax Docs For Mortgage, Feds Say

    A managing director at consulting firm Alvarez & Marsal was charged in D.C. federal court with failing to file his personal tax returns for over a decade and falsifying tax documents as part of a mortgage application.

  • September 25, 2024

    Harris Proposes Tax Credits For Domestic Manufacturing

    Vice President Kamala Harris, the Democratic nominee for president, announced a proposal Wednesday that would offer tax credits to boost investment and job creation in manufacturing, energy and agriculture.

  • September 25, 2024

    2 Senate Dems Ask IRS For Faster Worker Credit Payments

    The Internal Revenue Service should speed up payments of employee retention credit claims and prioritize paying low-risk credits to taxpayers that are struggling financially, two Democratic senators told the agency's commissioner.

  • September 25, 2024

    IRS Must Improve Seizure Procedure Compliance, TIGTA Says

    While a review of over 70 cases in which Internal Revenue Service field officers conducted seizures found the employees largely adhered to standard procedures, three cases where they did not highlight areas where the agency could improve its compliance, the Treasury Inspector General for Tax Administration said Wednesday.

  • September 25, 2024

    Julie Chrisley Gets No Slack In Resentencing From Ga. Judge

    Julie Chrisley, the former real estate mogul and reality TV star who was convicted of running a yearslong bank fraud scheme with her husband, Todd, was resentenced Wednesday by a Georgia federal judge to the same seven-year prison term she first received nearly two years ago.

  • September 25, 2024

    Expect More R&D Guidance Before Regs, IRS Atty Says

    The Internal Revenue Service plans to release more guidance governing the tax treatment of research and development expenses before it formally issues proposed regulations that implement the 2017 federal tax law's changes to the incentive, an agency attorney said Wednesday.

  • September 25, 2024

    House Bill Proposes Tax Incentive For Efficient Vehicles

    Buyers of new vehicles with higher-than-average energy performance would be entitled to a tax credit of up to $5,000 under a bill introduced in the U.S. House of Representatives.

  • September 25, 2024

    Direct File Needs Security, Testing Improvements, TIGTA Says

    While the deployment of the Internal Revenue Service's pilot of its free online Direct File program was largely successful, the agency must address some security lapses and testing deficiencies, the Treasury Inspector General for Tax Administration said Wednesday.

Expert Analysis

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Charting The Course For Digital Assets In 2024

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    Although 2023 was a tough year for the digital asset industry, upcoming court decisions, legislation and regulatory action will bring clarity, allowing the industry to expand and evolve, and the government will decide what innovation it will allow without challenge, says Joshua Smeltzer at Gray Reed.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • Giving The Gov't Drug Patent March-In Authority Is Bad Policy

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    The Biden administration's recent proposal to allow government seizure of certain taxpayer-funded drug patents is a terrible idea that would negate the benefits of government-funded research, to the detriment of patients and the wider economy, says Wayne Winegarden at Pacific Research Institute.

  • How Clients May Use AI To Monitor Attorneys

    Excerpt from Practical Guidance
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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • How 'As Such' Changes LPs' Self-Employment Tax Exposure

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    In light of the U.S. Tax Court’s recent Soroban Capital Partners decision hinging on "as such" to define the statutory limited partners exemption, state law limited partnerships should consider partners' roles and responsibilities before determining whether they are obligated to pay self-employment income tax, say attorneys at Morgan Lewis.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • IRA Monetization Energizes Clean Power Tax Credit Market

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    Recent large sales of clean energy production tax credits reflect an environment in which the Inflation Reduction Act's provisions for monetizing such credits via direct transfer — bypassing slow, costly tax equity transactions — offer opportunities for both developers and investors, says Andrew Eastman at Husch Blackwell.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

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