Federal
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December 13, 2024
Feds Narrow Drug Case Against Wife Of Convicted Drexel Prof
Prosecutors have told a New Jersey federal judge that they would drop one of three drug distribution charges against the wife of a convicted former Drexel University professor, saying their evidence might not establish intent after the U.S. Supreme Court raised the burden of proof for such cases in 2022.
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December 13, 2024
Halliburton Consistent On Claims For $35M Refund, Court Told
Halliburton has not changed its reasons for claiming a tax refund on a $35 million payment it made to a foreign government to protect its employees from harassment, the company told a Texas federal court, saying the U.S. wrongly accused it of a flip-flop.
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December 13, 2024
Taxation With Representation: Kirkland, Davis Polk, Wachtell
In this week's Taxation With Representation, Google and TPG Rise Climate partner with Intersect Power, Gen Digital Inc. acquires MoneyLion Inc., Patient Square Capital acquires Patterson Companies Inc., and the Buffalo Bills and Miami Dolphins sell minority ownership shares to private equity firms.
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December 13, 2024
Contractor Loses Bail For Texting Alleged Tax Cheat Allies
A District of Columbia federal judge revoked bail for a former defense contractor accused of running a $350 million tax-evasion scheme that prosecutors call one of the largest in U.S. history, after the government said he'd been texting his alleged co-conspirators.
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December 13, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included final regulations for the advanced manufacturing production credit for manufacturing key components and materials used in clean energy technologies.
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December 13, 2024
Loper Bright May Influence Tax Less, IRS Chief Counsel Says
The U.S. Supreme Court decision this year overturning a decades-long standard to defer to federal agencies' regulatory interpretations has encouraged the Internal Revenue Service to better explain its rules, its outgoing chief counsel said Friday.
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December 12, 2024
'Housewives' Figure Touts Social Media Posts In Leniency Bid
Former "Real Housewives of Atlanta" cast member Peter Anthony Thomas asked a North Carolina federal judge on Thursday to give him a prison sentence below federal guidelines for not paying $2.5 million in employment taxes, stating he has used his public platform to encourage his followers to pay their own taxes.
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December 12, 2024
Bitcoin Investor Gets 2 Years For Tax Fraud In Landmark Case
An investor who concealed millions of dollars he earned in bitcoin and became the first person criminally charged for failing to report gains from the sale of cryptocurrency by filing false returns was sentenced to two years in federal prison Thursday.
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December 12, 2024
IRS Wants Choice Retained In Dual Loss Rules, Official Says
The Internal Revenue Service is working to preserve flexibility for taxpayers in rules aimed at preventing companies from using the same economic loss twice after concerns were raised about how the rules could negatively interact with the Pillar Two global minimum tax, an official said Thursday.
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December 12, 2024
IRS Seeks Feedback On Limits In Previous Taxed Profit Rules
The Internal Revenue Service will consider whether rules included in recently proposed guidance on previously taxed earnings and profits to limit instances where U.S. multinationals may use basis to offset gain are too restrictive, an official said Thursday.
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December 12, 2024
IRS Chief Makes Case To Restore $20B Funding Shortfall
Congress should reverse a $20 billion IRS funding gap in a year-end budget bill to help the agency modernize its technology, improve customer service and collect unpaid taxes from wealthy businesses and individuals, Internal Revenue Commissioner Daniel Werfel said Thursday.
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December 12, 2024
2nd Circ. Won't Rethink Dual Citizen's FBAR Penalties
The Second Circuit will not review its September decision finding that a dual U.S.-French citizen is liable for tax penalties for failing to file reports of foreign bank and financial accounts, the court said Thursday.
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December 12, 2024
IRS Expands Business Tax Account Program To Corp. Leaders
The Internal Revenue Service's business tax account online self-service tool is now available to C corporations, while the agency is opening access to the program to certain officers of both C and S corporations, the agency said Thursday.
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December 12, 2024
IRS Hopes To Issue Amount B Pricing Guidance Within Weeks
Treasury is working to finish its guidance on the simplified transfer pricing approach to baseline marketing and distribution known as Amount B by the end of the year, a U.S. official said Thursday.
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December 12, 2024
Ex-FBI Informant Admits To False Accusations In Biden Case
A former FBI informant accused of making fake criminal accusations against President Joe Biden and his son, Hunter Biden, will plead guilty to tax evasion and falsifying records in a federal investigation, according to a deal filed Thursday in a California federal court.
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December 12, 2024
Treasury Seeks To Pause Anti-Laundering Law Injunction
The U.S. Treasury Department asked a Texas federal judge to pause his nationwide preliminary injunction of the Corporate Transparency Act pending an appeal of his recent decision that found Congress likely overstepped its constitutional authority when it wrote the anti-money laundering law.
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December 12, 2024
IRS Electronic Tax Committee To Meet In January
The Internal Revenue Service's Electronic Tax Administration Advisory Committee will hold its next meeting Jan. 8, the agency said Thursday.
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December 11, 2024
Bloomberg Entitled To Use $4B In Receipts For Deductions
Bloomberg incorrectly allocated gross receipts between software and services related to access to the Bloomberg Terminal, its interactive financial analysis product, but the company ultimately had $4.1 billion in gross receipts that could be used to calculate a deduction for domestic production from 2008 to 2010, the U.S. Tax Court found Wednesday.
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December 11, 2024
Temp Agency Owner Gets Prison For $2M Tax Scheme
A temp agency owner was sentenced to a year and a day in prison after pleading guilty in Massachusetts federal court to paying employees under-the-table wages to avoid $2.1 million in taxes.
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December 11, 2024
Tax Preparers Fabricated Expenses, US Says
Two tax preparers and their company should be barred from owning or operating tax preparation services because they fabricated business income and expenses for clients, the federal government told a Texas federal court.
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December 11, 2024
Exxon Tax Ruling Doesn't Help Liberty Global, 10th Circ. Told
Liberty Global cannot use a recent ruling that allowed Exxon Mobil a tax deduction for interest payments to claim a deduction for dividends that arose from its intragroup shuffling of a Belgian affiliate, the U.S. government told the Tenth Circuit on Wednesday.
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December 11, 2024
Beyoncé Fends Off Most Of $3M Tax Bill In Deal With IRS
Pop star Beyoncé owes only about $700 of what the IRS had claimed was $3 million in outstanding taxes and penalties, according to a U.S. Tax Court ruling Wednesday that approved a settlement between the star and the agency.
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December 11, 2024
17M Won't Benefit From Full Child Tax Credit, Report Says
Roughly 17 million children under 17 — or roughly a quarter of all U.S. children — will live in families that cannot claim the full child tax credit in 2025 because they make too little, the Urban-Brookings Tax Policy Center said in a report.
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December 11, 2024
Judge Orders Home Sale To Pay Down $1.7M Tax Debt
A California federal judge ordered the private sale of a deceased couple's home to pay down a $700,000 tax bill that has been accruing interest for 20 years and now stands at roughly $1.7 million.
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December 10, 2024
FinCEN Says CTA Still Constitutional In Post-Injunction Alert
The Financial Crimes Enforcement Network has alerted companies that they do not currently need to file so-called beneficial ownership information with the agency after a federal judge's nationwide preliminary injunction blocking the Corporate Transparency Act, though the bureau maintained that the law calling for such information is constitutional.
Expert Analysis
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How Firms Can Ensure Associate Gender Parity Lasts
Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.
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A Proposal For Fairer, More Efficient Innocent Spouse Relief
Adding a simple election to the current regulatory framework for innocent spouse claims would benefit both taxpayers and the Internal Revenue Service by alleviating the undue burdens placed on those the program was intended to help and improving agency collections in such cases, says Laurie Kazenoff at Kazenoff Tax.
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7 Common Myths About Lateral Partner Moves
As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.
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Proposed Hydrogen Tax Credit Regs May Be Legally Flawed
While the recently proposed regulations for the new clean hydrogen production tax credit have been lauded by some in the environmental community, it is unclear whether they are sufficiently grounded in law, result from valid rulemaking processes, or accord with other administrative law principles, say Hunter Johnston and Steven Dixon at Steptoe.
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Navigating ACA Reporting Nuances As Deadlines Loom
Stephanie Lowe at Liebert Cassidy walks employers through need-to-know elements of Affordable Care Act reporting, including two quickly approaching deadlines, the updated affordability threshold, strategies for choosing an affordability safe harbor, and common coding pitfalls.
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6 Pointers For Attys To Build Trust, Credibility On Social Media
In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.
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Why Biz Groups Disagree On Ending Chevron Deference
Two amicus briefs filed in advance of last month's U.S. Supreme Court oral arguments in Loper Bright Enterprises v. Raimondo highlight contrasting views on whether the doctrine of Chevron deference promotes or undermines the stable regulatory environment that businesses require, say Wyatt Kendall and Sydney Brogden at Morris Manning.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.
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A Look Ahead For The Electric Vehicle Charging Industry
This will likely be an eventful year for the electric vehicle market as government efforts to accelerate their adoption inevitably clash with backlash from supporters of the petroleum industry, say Rue Phillips at SkillFusion and Enid Joffe at Green Paradigm Consulting.
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A Post-Mortem Analysis Of Stroock's Demise
After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.
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SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
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Planning A Defense As IRS Kicks Off Sports Losses Campaign
Sports team owners and partnerships face potential examination under the Internal Revenue Service’s recently announced sports industry losses campaign, and should be preparing to explain what drove their reported losses and assembling documentation to support their tax return positions and accounting methods, say Sheri Dillon and Jennifer Breen at Morgan Lewis.
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What New Calif. Strike Force Means For White Collar Crimes
The recently announced Central District of California strike force targeting complex corporate and securities fraud — following the Northern District of California's model — combines experienced prosecutorial leadership and partnerships with federal agencies like the IRS and FBI, and could result in an uptick in the number of cases and speed of proceedings, say attorneys at MoFo.