Federal

  • August 28, 2024

    Hunter Biden's Addiction Expert Knocked Out Of Tax Trial

    A California federal judge on Tuesday barred Hunter Biden's expected addiction expert from testifying in his upcoming trial on tax charges, saying the expert's opinions hadn't been clearly linked to the specifics of Biden's own struggle.

  • August 28, 2024

    IRS Declines Watchdog's Ask For Attys In Talks With Big Cos.

    The IRS declined a recommendation by its internal watchdog to require the agency's counsel to attend talks held with large multinational corporations by its appellate division, which agents say thwarts their ability to correctly enforce the economic substance doctrine, according to a report.

  • August 28, 2024

    Pa. Atty Admits To Dodging Taxes On Mass Tort Deal Fees

    A Pennsylvania attorney pled guilty Wednesday to failing to pay taxes for approximately $1.2 million in income she received over three years, depriving the government of up to half a million dollars in revenue, according to the U.S. Attorney's Office for the Middle District of Pennsylvania.

  • August 28, 2024

    Feds Looks To Toss Ex-Citizens' Renunciation Fee Challenge

    The federal government asked a D.C. federal judge to throw out a lawsuit brought by former U.S. citizens who want their $2,350 citizenship renunciation fee refunded, arguing during a Wednesday hearing that the United States is immune from the litigation and the plaintiffs can't relitigate claims that they already lost.

  • August 28, 2024

    Mo. Partnership Challenges Nix Of $79M Easement Deduction

    The Internal Revenue Service offered no explanation for its claims that a Missouri partnership's conservation easement donation was overvalued and didn't serve a conservation purpose, the partnership told the U.S. Tax Court in challenging the rejection of a $79 million tax deduction.

  • August 28, 2024

    5th Circ. Upholds Tax Preparer's Sentence, Delays Restitution

    The Fifth Circuit upheld a Texas federal jury's conviction that resulted in a prison sentence for a tax preparation service owner for assisting in filing false tax returns, but it determined that the nearly $72,000 in restitution that she owes should be delayed until after her sentence ends.

  • August 28, 2024

    IRS Must Reconsider Pair's Ability To Pay Tax Liability

    The U.S. Tax Court sent a case involving a levy against a pair of Californians for six years' worth of tax deficiencies back to the IRS' Office of Appeals, saying Wednesday that more work needs to be done to determine the couple's ability to pay.

  • August 28, 2024

    IRS Corrects Proposed Foreign Currency Accounting Regs

    The Internal Revenue Service issued corrections Wednesday to proposed rules that would adjust the timing for when companies could opt to use what is known as the mark-to-market accounting method for gains or losses that arise from foreign currency transactions.

  • August 28, 2024

    NY Firm Calls Gas Co.'s Contract And Fee Claims Duplicative

    Albany, New York-based Whiteman Osterman & Hanna LLP has moved to trim breach of contract and disgorgement of fees claims brought by a former client over allegedly bungled tax advice, telling a New York federal judge the claims are redundant when the ex-client is also pursuing a legal malpractice cause of action. 

  • August 28, 2024

    Atlanta's Ex-CFO Gets 3 Years For 'Triple-Dipping' In Coffers

    Atlanta's former chief financial officer became the latest city hall official to head to prison on corruption charges Tuesday, after getting hit with a three-year prison sentence for what prosecutors called a "triple-dipping" scheme into city coffers to pay for swanky vacations and illegal firearms.

  • August 28, 2024

    Jury Justified In Dismissing $2.2M FBAR Case, Court Rules

    A financial adviser will not face a new trial after an Arizona federal court ruled there was sufficient evidence for a jury to clear him in January of failing to report foreign bank accounts, sparing him at least $2.2 million in penalties.

  • August 28, 2024

    Sysco, IRS Asked To Address Varian's Foreign Dividend Win

    The U.S. Tax Court asked food services giant Sysco and the IRS to address how a tax dispute between them is affected by a recent ruling in a similar case that found medical device company Varian can claim a deduction for foreign dividends.

  • August 28, 2024

    Farm Co. Defends Switch To Amortization In 8th Circ. Tax Fight

    An Arkansas company that leases land eligible for government farm subsidies was entitled to start amortizing the acres for better tax treatment without notifying the IRS, the company told the Eighth Circuit, asking the court to overturn a decision denying its related deductions for 2013 and 2014.

  • August 28, 2024

    Treasury To Require Reports On All-Cash Real Estate Deals

    Anyone who transfers real estate to a legal entity in an all-cash transaction, including attorneys, will be required starting Dec. 1, 2025, to inform the U.S. Treasury Department about that entity's beneficial owners and their identification numbers under a final rule issued Wednesday. 

  • August 28, 2024

    Greenberg Traurig Builds PE Team With Kirkland Hires

    Greenberg Traurig LLP has brought on two fund formation partners from Kirkland & Ellis LLP to continue its growth into the private equity space, according to an announcement this week by the firm.

  • August 28, 2024

    IRS Art Advisory Panel To Discuss Appraisals In Sept.

    The Internal Revenue Service's Art Advisory Panel will meet next month to discuss fair market appraisals of pieces of art for tax purposes, the agency said Wednesday.

  • August 28, 2024

    Virgin Islands Tax Deadlines Delayed After Tropical Storm

    Taxpayers in the U.S. Virgin Islands will be given until Feb. 3 to file individual and business tax returns and make payments after the area was hit by Tropical Storm Ernesto this month, the Internal Revenue Service said Wednesday.

  • August 28, 2024

    Atty Can't Escape Danish Tax Agency's $2.1B Tax Fraud Suit

    An attorney in a $2.1 billion tax fraud case brought by the Danish tax authority cannot argue that a suit filed against him as an individual should be dismissed because it was filed late, a New York federal court ruled.

  • August 27, 2024

    Gov't Says Doctor Can't Escape Contempt Fine In FBAR Case

    A doctor challenging his $20,000 civil contempt fine for failing to follow a court order to repatriate money from his foreign bank account to cover $1.1 million in tax liabilities shouldn't be allowed to escape the penalty, the U.S. government argued Tuesday.

  • August 27, 2024

    TIGTA Flags Due Process Issues In IRS' Lien Practices

    The Treasury Inspector General for Tax Administration found that the Internal Revenue Service had numerous issues that affected due process for taxpayers whom it filed lien notices against, according to a report published Tuesday.

  • August 27, 2024

    Treasury Asked To Scrap Stock Buyback Tax's Funding Rule

    Business groups urged the U.S. Treasury Department on Tuesday to remove what's known as the funding rule in forthcoming final regulations on the stock buyback tax, saying the provision would go beyond Congress' intentions for the levy, which aims to deter companies from giving outsize rewards to shareholders.

  • August 27, 2024

    TIGTA Calls For Better Guarding Of Shared Tax Info

    The Treasury Inspector General for Tax Administration identified ways Tuesday it said the Internal Revenue Service should work with state agencies to improve the handling of federal tax information it shares with them, including nudging them to file required security reports.

  • August 27, 2024

    Gov't Urged To Stem Abuse Of Carbon Capture Credits

    The federal government should take measures to stop the abuse of tax credits for carbon capture and storage, more than 100 environmental groups told the U.S. Treasury Department and the Environmental Protection Agency in a letter released Tuesday.

  • August 27, 2024

    Biz Owner Gets 22 Months For Keeping $2.5M In Payroll Tax

    A man who ran construction companies was sentenced to nearly two years in prison and ordered to pay about $2.5 million in restitution to the federal government after admitting he didn't pay employment taxes, the U.S. Attorney's Office for the Northern District of Georgia said Tuesday.

  • August 27, 2024

    Ex-Trooper Asks To Delay Prison In OT Scam Amid Appeal

    A former Massachusetts state trooper asked to stay his five-year prison sentence for stealing overtime pay, lying on his taxes and cheating to get student aid for his son — a request prosecutors said was "yet another attempt to delay justice in this case."

Featured Stories

  • 3 Items Tax Pros Want To See In Student Loan Matching Regs

    David van den Berg

    Practitioners and experts are hoping the IRS will flesh out a recently released notice on student loan matching contributions to retirement plans with details including how to fix errors and whether plans may need to be changed depending on how they provide matches. Here, Law360 explores three issues practitioners and observers want the agency to address.

  • Candidates' Plans To End Tip Taxes Spark Fairness Concerns

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    The Democratic and Republican presidential nominees have both proposed eliminating taxes on tips for restaurant and hospitality workers, but tax experts say such a policy would unfairly pick winners and losers among workers and its benefits would be unevenly spread.

  • IRS Spinoff Guidance Sparks Worries About Short-Term Debt

    Natalie Olivo

    Companies that intend to give creditors equity tied to a spinoff transaction won't get early tax-free approval if the exchange involves recently acquired debt under IRS guidance that practitioners say draws an arbitrary line without accounting for ordinary business operations.

Expert Analysis

  • Litigation Funding Disclosure Key To Open, Impartial Process

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    Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.

  • Whistleblowers Must Note 5 Key Differences Of DOJ Program

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    The U.S. Department of Justice’s recently unveiled whistleblower awards program diverges in key ways from similar programs at other agencies, and individuals must weigh these differences and look first to programs with stronger, proven protections before blowing the whistle, say Stephen Kohn and Geoff Schweller at Kohn Kohn.

  • What NFL Draft Picks Have In Common With Lateral Law Hires

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    Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.

  • Replacing The Stigma Of Menopause With Law Firm Support

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    A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.

  • Planning Law Firm Content Calendars: What, When, Where

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    During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.

  • Brownfield Questions Surround IRS Tax Credit Bonus

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    Though the IRS has published guidance regarding the Inflation Reduction Act's 10% adder for tax credits generated by renewable energy projects constructed on brownfield sites, considerable guesswork remains as potential implications seem contrary to IRS intentions, say Megan Caldwell and Jon Micah Goeller at Husch Blackwell.

  • Law Firms Should Move From Reactive To Proactive Marketing

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    Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.

  • The Big Issues A BigLaw Associates' Union Could Address

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    A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.

  • It's Time For A BigLaw Associates' Union

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    As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.

  • Why DOJ's Whistleblower Program May Have Limited Impact

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    The U.S. Department of Justice’s new whistleblower pilot program aims to incentivize individuals to report corporate misconduct, but the program's effectiveness may be undercut by its differences from other federal agencies’ whistleblower programs and its interplay with other DOJ policies, say attorneys at Milbank.

  • How Justices Upended The Administrative Procedure Act

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    In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.

  • Trump's Best Hush Money Appeal Options Still Likely To Fail

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    The two strongest potential arguments former President Donald Trump could raise in appealing his New York hush money conviction seem promising at first, but precedent strongly suggests they will still ultimately fail — though, of course, Trump's unique position could lead to surprising results, says former New York Supreme Court Justice Ethan Greenberg, now at Anderson Kill.

  • Tips For Tax Equity-Tax Credit Transfers That Pass IRS Muster

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    Although the Internal Revenue Service has increased its scrutiny of complex partnership structures, which must demonstrate their economic substance and business purpose, recent cases and IRS guidance together provide a reliable road map for creating legitimate tax equity structures, say Ian Boccaccio and Michael Messina at Ryan Tax.