Federal
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July 16, 2024
The 2024 Diversity Snapshot: What You Need To Know
Law firms' ongoing initiatives to address diversity challenges have driven another year of progress, with the representation of minority attorneys continuing to improve across the board, albeit at a slower pace than in previous years. Here's our data dive into minority representation at law firms in 2023.
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July 16, 2024
These Firms Have The Most Diverse Equity Partnerships
Law360’s law firm survey shows that firms' efforts to diversify their equity partner ranks are lagging. But some have embraced a broader talent pool at the equity partner level. Here are the ones that stood out.
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July 16, 2024
Applicable Federal Interest Rates To Drop In August
Applicable federal rates for income tax purposes will decrease in August, the Internal Revenue Service said Tuesday, the second month-to-month drop in a row.
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July 16, 2024
3 Tax Reg Groups That May Be Shaky After High Court Rulings
The U.S. Supreme Court issued two rulings that, when combined, open up long-standing federal regulations to challenges without judicial deference to agencies — a pairing that could weaken several categories of tax rules, including guidance issued under the 2017 federal overhaul. Here, Law360 looks at three batches of tax regulations that may be vulnerable in the aftermath of the high court's decisions.
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July 15, 2024
Israeli Firm Seeks To Amend Suit Against GILTI Regs
The owner of an Israeli law firm asked a D.C. federal court to let him amend his challenge to regulations for the U.S. tax on global intangible low-taxed income after the D.C. Circuit determined parts of his arguments went unconsidered.
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July 15, 2024
4th Circ. Rejects Couple's $5.1M Easement Deduction
The Fourth Circuit rejected Monday a married couple's bid to revive a claimed $5.1 million conservation easement deduction, saying it represented a "remarkable" attempt to inflate the value of a 41-acre property that was worth just $652,000 the year before they donated it.
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July 15, 2024
Former Doctor Seeks Jail Release In FBAR Fight
An incarcerated former doctor asked a Michigan federal court Monday to lift its order of civil contempt for his failure to pay about $1 million in foreign account reporting penalties, saying he has done all he can to repatriate offshore securities.
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July 15, 2024
Widow To Pull $1.7M From Swiss Bank To Pay FBAR Penalties
A logger's widow agreed to pull about $1.7 million from her Swiss bank account to pay down penalties that her late husband's estate owes the IRS for his failure to report offshore accounts, according to a filing Monday in a Colorado federal court.
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July 15, 2024
AICPA Suggests Revising Foreign Trust Loan Anti-Abuse Rule
The U.S. Treasury Department should scrap or revise significantly an anti-abuse rule for nonresident aliens who receive loans from foreign trusts, which was included in proposed regulations on how to report foreign trust transactions, the American Institute of Certified Public Accountants said in a letter published Monday.
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July 15, 2024
IBM Taps Jones Day To Take NY Royalty Tax Fight To Justices
IBM asked the U.S. Supreme Court for more time to submit a petition for review of a New York high court decision that upheld tax on royalties received from foreign affiliates, saying it recently retained Jones Day to handle the case.
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July 15, 2024
Akerman Brings On Chamberlain Hrdlicka Tax Pros In Atlanta
Akerman LLP announced Monday that it picked up a pair of new partners for its tax practice group in Atlanta who were previously with Chamberlain Hrdlicka White Williams & Aughtry.
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July 15, 2024
TIGTA Says IRS Can Improve Digital Currency Enforcement
While the IRS has carried out some enforcement actions related to virtual currency noncompliance and has launched a program focused on identifying taxpayers who leave digital assets off their returns, the agency has lots of room for improvement, the Treasury Inspector General for Tax Administration said Monday.
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July 15, 2024
Truck Co. Qualifies For $500M Tax Safe Harbor, 6th Circ. Told
A Tennessee company asked the Sixth Circuit to shield it from more than $500 million in excise tax liabilities, saying a lower court correctly found that its refurbished trucks qualify for the safe harbor from the heavy-truck excise tax.
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July 15, 2024
Rising Star: Davis Polk's Dominic Foulkes
Dominic Foulkes of Davis Polk & Wardwell LLP has advised companies on several multibillion-dollar transactions, including a technology-maker's $4.9 billion initial public offering, the largest in the United States in the last three years, earning him a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 12, 2024
Rising Star: Quinn Emanuel's Emily Au
Emily Au of Quinn Emanuel Urquhart & Sullivan LLP has been the lead attorney on several high-profile cases, including a key case across the U.K. construction industry in terms of HMRC's Value-Added Tax policy, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 12, 2024
Law360 Names 2024's Top Attorneys Under 40
Law360 is pleased to announce the Rising Stars of 2024, our list of 158 attorneys under 40 whose legal accomplishments belie their age.
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July 12, 2024
Chevron's End Doesn't Bear On 3M's Case, IRS Tells 8th Circ.
The U.S. Supreme Court's recent overturning of Chevron deference doesn't warrant a reversal of a U.S. Tax Court ruling in 3M Co.'s transfer pricing case, the Internal Revenue Service told the Eighth Circuit on Friday.
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July 12, 2024
Payments To Ex-Wife Should Be Deductible, 11th Circ. Told
A Georgia man told the Eleventh Circuit on Friday that his payments to his ex-wife as part of a marital settlement should qualify as alimony and therefore be deductible from his federal income taxes, asking the court to reverse a U.S. Tax Court decision.
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July 12, 2024
Mo. Says IRS 'Stonewalling' On Worker Credit Freeze Records
The Internal Revenue Service violated public records law in failing to release documents related to its decision to stop processing new employee retention credit claims, the state of Missouri said Friday in a complaint that accuses the agency of "stonewalling."
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July 12, 2024
11th Circ. Urged To Grant Deductions In Ruined Records Case
The U.S. Tax Court should have been more generous in granting tax deductions to a Florida couple whose records were destroyed by a hurricane, the couple told the Eleventh Circuit on Friday, saying the lost records were out of their control.
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July 12, 2024
European Tax Policy To Watch In The Second Half Of 2024
Observers of European Union tax policy expect the EU to devote more attention to problems with existing tax legislation in the coming months as the introduction of major policy proposals takes a pause. Specialists also will be watching for progress on EU tax laws that remain stuck, and the bloc is likely to fill roles including tax commissioner. Here, Law360 examines key tax issues to watch for the remaining six months of the year.
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July 12, 2024
Taxation With Representation: Ropes & Gray, Cravath, Latham
In this Week's Taxation with Representation, Paramount Global merges with Skydance Media, Devon Energy acquires Grayson Mill Energy's Williston Basin oil and gas business, Ryan acquires Altus Group Ltd.'s property tax business, and Bain Capital buys Envestnet Inc.
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July 12, 2024
Former City Treasurer Gets 30 Months In $1M Embezzlement
A former city treasurer in Alaska was sentenced to two and a half years in prison after having admitted to tax evasion and fraud in connection with a $1 million embezzlement scheme, according to Alaska federal court documents.
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July 12, 2024
7 Taxpayer Advocacy Panel Committees To Meet In August
Seven of the Taxpayer Advocacy Panel's committees will hold public meetings in August focused on improving customer service at the Internal Revenue Service, the agency announced Friday.
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July 12, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the reporting and recording obligations associated with the stock buyback excise tax.
Expert Analysis
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How Attys Can Avoid Pitfalls When Withdrawing From A Case
The Trump campaign's recent scuffle over its bid to replace its counsel in a pregnancy retaliation suit offers a chance to remind attorneys that many troubles inherent in withdrawing from a case can be mitigated or entirely avoided by communicating with clients openly and frequently, says Christopher Konneker at Orsinger Nelson.
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Using A Children's Book Approach In Firm Marketing Content
From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.
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New Crypto Reporting Will Require Rigorous Recordkeeping
The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.
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Geothermal Energy Has Growing Potential In The US
Bipartisan support for the geothermal industry shows that geothermal energy can be an elegant solution toward global decarbonization efforts because of its small footprint, low supply chain risk, and potential to draw on the skills of existing highly specialized oil and gas workers and renewable specialists, say attorneys at Weil.
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Exploring An Alternative Model Of Litigation Finance
A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.
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Trump Hush Money Case Offers Master Class In Trial Strategy
The New York criminal hush money trial of former President Donald Trump typifies some of the greatest challenges that lawyers face in crafting persuasive presentations, providing lessons on how to handle bad facts, craft a simple story that withstands attack, and cross-examine with that story in mind, says Luke Andrews at Poole Huffman.
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A Vision For Economic Clerkships In The Legal System
As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.
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State-Regulated Cannabis Can Thrive Without Section 280E
Marijauna's reclassification as a Schedule III-controlled substance comes at a critical juncture, as removing marijuana from being subjected to Section 280E of the Internal Revenue Code is the only path forward for the state-regulated cannabis industry to survive and thrive, say Andrew Kline at Perkins Coie and Sammy Markland at FTI Consulting.
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Asset Manager Exemption Shifts May Prove Too Burdensome
The U.S. Department of Labor’s recent change to a prohibited transaction exemption used by retirement plan asset managers introduces a host of new costs, burdens and risks to investment firms, from registration requirements to new transition periods, say attorneys at Simpson Thacher.
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A Look At New IRS Rules For Domestically Controlled REITs
The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.
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E-Discovery Quarterly: Recent Rulings On Text Message Data
Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.
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Should NIL Collectives Be Allowed Tax-Favored Status?
Arguments are being made for and against allowing organizations to provide charitable contribution tax deductions for donations used to compensate student-athletes, a practice with impacts on competition for student-athletes and overall tax fairness, but ultimately it is a question for Congress, say Andres Castillo and Barry Gogel at the University of Maryland School of Law.
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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.