Federal
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September 06, 2024
4 Key Complications 3 Years After Pillar 2
Three years ago, countries around the world outlined an agreed-upon minimum corporate tax system in an eight-page document that couldn't have foreseen the full scope of complications that later emerged during implementation, including frictions with existing tax laws. Here, Law360 looks at four key issues that countries and multinational corporations are grappling with as Pillar Two turns three.
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September 06, 2024
IRS Issues 2025 Table For Premium Tax Credit Calculations
The Internal Revenue Service published the table used to determine the 2025 premium tax credit Friday.
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September 06, 2024
Taxation With Representation: Debevoise, Bennett, Orrick
In this week's Taxation With Representation, Verizon reaches a deal to absorb Frontier in a deal worth $20 billion, First Majestic agrees to buy Gatos Silver for $970 million, and Epam Systems inks a $630 million purchase of Neoris.
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September 06, 2024
Man Disguised Businesses To Duck Tax, US Says In $1.9M Suit
A retired business owner who the U.S. government said removed his mailbox to avoid receiving letters from the IRS owes nearly $1.9 million in unpaid tax liabilities, some stemming from pretending to operate his companies as religious ministries, the government said in a suit in Florida federal court.
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September 06, 2024
Vialto Partners Member Joins Baker McKenzie As Partner
Baker McKenzie has hired a tax partner in Washington, D.C., from Vialto Partners, a business consulting firm, the firm announced Thursday.
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September 06, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included updated interest rates for overpayments and underpayments of tax for the fourth quarter of 2024.
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September 05, 2024
Unconstitutionality Of Transparency Act Clear, 11th Circ. Told
A small business group and one of its members have told the Eleventh Circuit that an Alabama federal judge correctly ruled that the Corporate Transparency Act is unconstitutional, so there was no need for them to demonstrate that the law fails to pass constitutional muster.
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September 05, 2024
Liberty Global Urges 10th Circ. To Grant $248M Tax Credit
The U.S. Tax Court improperly applied an Internal Revenue Code provision to some of the $2.8 billion gain from Liberty Global's sale of a Japanese entity, the telecommunications company said in urging the Tenth Circuit to overturn the resulting rejection of a $248 million tax credit.
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September 05, 2024
Holland & Knight Appoints Former Perkins Coie Tax Partner
Holland & Knight LLP appointed a partner to its Portland, Oregon, office who previously served as a partner in energy tax law for Perkins Coie LLP, the firm announced.
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September 05, 2024
$70M Bill Came Too Late, Tax Court Says In Tossing IRS Claim
Partners in a subscription business don't owe around $70 million in taxes as the IRS claimed because the agency notified them too late and couldn't extend the deadline by proving the partners had filed fraudulent returns, the U.S. Tax Court said in rulings Thursday.
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September 05, 2024
Sen. Finance Panel To Hold Hearing On Tax Policy, Avoidance
The Senate Finance Committee will hold a hearing Sept. 12 covering the 2025 tax policy debate and tax avoidance strategies, it announced Thursday.
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September 05, 2024
CPAs Seek Guidance On Business Interest Expense Deduction
The American Institute of Certified Public Accountants requested Thursday that the Internal Revenue Service and U.S. Treasury Department issue guidance clarifying that new limits on business interest expenses included in the 2017 federal tax overhaul apply after an election to capitalize interest expenses.
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September 05, 2024
Two Sentenced To Prison In $111M Tax Fraud Scheme
Two members of a crime ring who admitted to participating in a $111 million tax fraud scheme involving stealing the identities of accountants and taxpayers were sentenced to prison, according to Texas federal court documents.
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September 05, 2024
IRS Seeks Input On Treasury Retirement Match Contributions
The Internal Revenue Service said Thursday it is looking for comments regarding two portions of the Secure 2.0 Act of 2022 related to matching contributions paid by the U.S. Treasury Department to certain retirement savings vehicles for eligible people who make qualified contributions.
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September 04, 2024
Judge Chides IRS, Preparers Over $167M Refund For ID Fees
A D.C. federal judge has declined to approve the IRS' roughly $167 million refund proposal for a putative class of tax-return preparers for charging them excessive fees for special identification numbers, saying the agency failed to address problems the preparers raised with its calculations.
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September 04, 2024
IRS' Economic Substance Authority Has Limits, Tax Court Told
The U.S. Tax Court and other federal courts have the authority to conduct an initial analysis of a transaction in cases where the Internal Revenue Service is challenging the economic substance of the transaction, a manufacturers advocacy group said Wednesday in an amicus brief.
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September 04, 2024
Woman Owes Taxes On Share Of Sold Biz, Tax Court Says
A woman whose ex-husband told a bankruptcy court that he was the sole owner of a business they had started together was actually a 50% shareholder when it was sold and is liable for capital gains, the U.S. Tax Court ruled Wednesday.
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September 04, 2024
Tax Court OKs $465K Gambling Losses Deduction Amount
An Indiana woman adequately proved she had more than $465,000 in substantiated gambling losses over six years, the U.S. Tax Court said Wednesday, though she failed to substantiate her claimed business losses.
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September 04, 2024
Warren Urges IRS To Look At Possible REIT Tax Break Abuse
The Internal Revenue Service should increase its scrutiny of real estate investment trusts to determine whether companies are benefiting from REIT tax benefits while flouting rules, including those that limit the level of a REIT's ownership in a company, Sen. Elizabeth Warren told the agency's commissioner.
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September 04, 2024
Maryland Joining IRS Direct File Next Year
Maryland will join the IRS' free electronic tax filing program known as Direct File in 2025, the U.S. Department of the Treasury and the Internal Revenue Service announced Wednesday.
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September 04, 2024
Ex-Mass. Pol 'A Little Sloppy' But Not Criminal, Jurors Told
Former Massachusetts state Sen. Dean A. Tran denied charges Wednesday that he stole pandemic unemployment assistance and cheated on his taxes, with his attorney telling a jury that Tran simply made a series of paperwork "mistakes."
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September 04, 2024
Chippewa Lawyer Asks 8th Circ. To Reconsider Tax Exemption
An attorney who contends that Congress never expressly allowed the federal government to tax Native Americans asked the Eighth Circuit to reconsider denying him a tax exemption on his self-employment income, saying the ruling conflicts with recent U.S. Supreme Court decisions.
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September 04, 2024
IRS Reopens Comment Period For Tax Payment Regs
The Internal Revenue Service announced Wednesday that it had reopened the comment period for proposed regulations that would allow taxpayers to make payments using credit and debit cards directly with the agency instead of through a third party.
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September 04, 2024
IRS Announces 4 Tax Court Sessions Added To Calendar
The Internal Revenue Service announced four U.S. Tax Court sessions in December and named calendar administrators for the sessions in a notice released Wednesday.
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September 03, 2024
5th Circ. Rejects 4 Arguments Against $6K Tax Bill
The U.S. Tax Court correctly determined a man owed over $5,000 in tax deficiencies as well as more than $1,000 in penalties plus interest, the Fifth Circuit ruled Tuesday, finding none of the taxpayer's four arguments persuasive.
![Hunter Biden leaves federal court with his wife Melissa Cohen Biden after pleading guilty in his felony federal tax case, Thursday, Sept. 5, 2024, in Los Angeles. (AP Photo/Jae C. Hong)](https://assets.law360news.com/1876000/1876804/c86a0f929dc5bb54e0bf7678b6da43476ccb9563-hunter_biden_04176.jpg)
Hunter Biden Pleads Guilty To Tax Charges In Surprise Move
Hunter Biden entered a surprise guilty plea to nine criminal tax charges in California federal court on Thursday, bringing a dramatic conclusion to the case following a dizzying series of events on what was set to be the first day of his trial.
![Democratic presidential nominee Vice President Kamala Harris speaks during a campaign stop at the Throwback Brewery, in North Hampton, N.H., Wednesday, Sept. 4, 2024. (AP Photo/Steven Senne)](https://assets.law360news.com/1876000/1876309/c73f505650583df85484bd29a2f958c93b578b23-election_2024_harris_26798.jpg)
Harris Floats Capital Gains Tax Hike To 28% For High Earners
The tax on long-term capital gains would increase to 28% from 20% for taxpayers who earn $1 million or more under a proposal unveiled Wednesday by Vice President and Democratic presidential nominee Kamala Harris ahead of a campaign rally in New Hampshire.
![The U.S. Courthouse for the United States Court of Appeals for the Eleventh Circuit, is seen, Saturday, July 21, 2012, in Atlanta. (AP Photo/Mike Stewart)](https://assets.law360news.com/1875000/1875893/1f0a50231d3737d7e96f96f870f80539eee1e7d3-georgia-daily-life.jpeg)
11th Circ. Trims $12.6M FBAR Fine In 8th Amendment Split
Some of the $12.6 million in penalties the IRS on imposed a man for willfully failing to report foreign bank accounts were in violation of the Eighth Amendment's bar on excessive fines, the Eleventh Circuit ruled, creating an apparent circuit split.
Featured Stories
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4 Key Complications 3 Years After Pillar 2
Three years ago, countries around the world outlined an agreed-upon minimum corporate tax system in an eight-page document that couldn't have foreseen the full scope of complications that later emerged during implementation, including frictions with existing tax laws. Here, Law360 looks at four key issues that countries and multinational corporations are grappling with as Pillar Two turns three.
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3 Ways Justices' SEC Fraud Ruling Could Affect Tax Disputes
The U.S. Supreme Court's groundbreaking decision to curb the U.S. Securities and Exchange Commission's in-house fraud enforcement could hamper the IRS' ability to assert certain penalties, including in contested conservation easement cases, and challenge the U.S. Tax Court's authority to review them. Here, Law360 examines three arenas in which the Supreme Court decision could shake up tax administration and litigation.
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3 Items Tax Pros Want To See In Student Loan Matching Regs
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.
Expert Analysis
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Why Attorneys Should Consider Community Leadership Roles
Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.
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Firms Must Offer A Trifecta Of Services In Post-Chevron World
After the U.S. Supreme Court’s Loper Bright Enterprises v. Raimondo decision overturning Chevron deference, law firms will need to integrate litigation, lobbying and communications functions to keep up with the ramifications of the ruling and provide adequate counsel quickly, says Neil Hare at Dentons.
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5 Tips To Succeed In A Master Of Laws Program And Beyond
As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.
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Pros, Cons Of Disclosing Improper Employee Retention Credit
Employers considering the Internal Revenue Service’s second voluntary disclosure program, which allows companies to avoid penalties for erroneously claiming employee retention credits for the 2021 tax year by repaying the credits and naming the tax advisers who encouraged these abusive practices, should carefully weigh the program’s benefits against its potential drawbacks, say attorneys at Winston & Strawn.
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How Law Firms Can Avoid 'Collaboration Drag'
Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.
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Litigation Funding Disclosure Key To Open, Impartial Process
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.
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Whistleblowers Must Note 5 Key Differences Of DOJ Program
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.
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What NFL Draft Picks Have In Common With Lateral Law Hires
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.
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Replacing The Stigma Of Menopause With Law Firm Support
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.
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Planning Law Firm Content Calendars: What, When, Where
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.
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Brownfield Questions Surround IRS Tax Credit Bonus
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.
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Law Firms Should Move From Reactive To Proactive Marketing
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.
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The Big Issues A BigLaw Associates' Union Could Address
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.