Federal
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December 16, 2024
Mich. Judge Troubled By Scope Of Feds' CTA Data Collection
A federal judge in Michigan said new disclosure requirements for small businesses seem burdensome and intrusive during a Monday hearing focused on the privacy implications of the currently blocked anti-money laundering law.
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December 16, 2024
Texan Still Owes 2021 Tax Bill Despite Levy For Other Year
While the U.S. Tax Court is sympathetic to a Texan's complaint that the Internal Revenue Service's levy procedure will result in his facing an endless string of collection actions, he still must pay his $12,500 deficiency from 2021, the Tax Court said Monday.
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December 16, 2024
6th Circ. Affirms $3M Tax Bill For Gold Broker
A gold and silver broker who made fatuous arguments that he wasn't subject to income taxes owes $3 million in liabilities, the Sixth Circuit ruled, upholding a U.S. Tax Court decision.
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December 16, 2024
Tax Court Says Couple Must Recalculate $36M Loss Claims
An Illinois couple must recalculate the more than $36 million in net operating loss carryforward deductions they claimed in 2008 and 2009, the U.S. Tax Court said Monday, siding with the Internal Revenue Service's determination that they had improperly included a number of losses.
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December 16, 2024
Tax Court Wrongly Cut Easement Deduction, 11th Circ. Told
The U.S. Tax Court erred in drastically reducing a partnership's claimed $23 million deduction for donating a conservation easement in Georgia, the partnership told the Eleventh Circuit, saying the court improperly relied on a real estate expert's opinion to establish whether the land had mining value.
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December 16, 2024
Cos. Urge Judge To Maintain Injunction On Transparency Law
A Texas federal judge doesn't need to stay his preliminary injunction on the rollout of new corporate transparency rules while the U.S. government's appeal of his decision is pending at the Fifth Circuit, a business lobbying group and others said Monday.
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December 16, 2024
Wyden Bill Would Nix Tax Perks For Private Placement Plans
U.S. Senate Finance Committee Chairman Ron Wyden unveiled legislation Monday that would remove the tax benefits of a special type of private life insurance plan that he said high-net-worth individuals have been abusing to avoid paying taxes on their investments in the policies.
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December 16, 2024
High Court Passes On Protest Of IRS Social Security Levy
The U.S. Supreme Court said Monday it won't review an Eleventh Circuit decision denying a woman's challenge to the IRS' garnishment of her Social Security payments, letting stand the circuit court's conclusion that her suit was barred because she failed to exhaust administrative remedies.
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December 16, 2024
Applicable Federal Rates Set To Increase Again In Jan.
Applicable federal rates for income tax purposes will increase across the board in January, a second straight month of increases after a string of months that saw declining rates, the Internal Revenue Service said Monday.
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December 16, 2024
Justices Won't Review Man's Demand For Dad's Tax Info
The U.S. Supreme Court on Monday let stand a D.C. Circuit decision tossing a man's suit against the IRS for withholding his dead father's tax records, a ruling the man claimed had deepened a circuit split over the correct process for obtaining personal tax documents.
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December 16, 2024
IRS Issues Corp. Bond Monthly Yield Curve For Dec.
The Internal Revenue Service published the corporate bond monthly yield curve for December for use in calculations for defined benefit plans Monday, as well as corresponding segment rates and other related provisions.
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December 16, 2024
IRS Corrects Regs On Direct Pay Of Partnership Tax Credit
Internal Revenue Service issued a correction Monday to final regulations that make it easier for tax-exempt entities that co-own development projects to qualify for a direct cash payment of clean energy tax credits by electing out of their partnership tax status.
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December 16, 2024
LegalZoom Launches Strategic Alliance With 1-800Accountant
LegalZoom announced Monday that it will launch a multiyear strategic partnership with financial services firm 1-800Accountant by the start of the new year.
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December 14, 2024
IRS Criminal Probes On Worker Retention Cases Still Early
The Internal Revenue Service's criminal arm is still in the early stage of investigating the most extremely fraudulent claims of a tax credit intended to reward businesses for retaining employees during the COVID-19 pandemic, an official said Saturday.
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December 13, 2024
IRS Aims To Ramp Up Partnership Audits, Official Says
The Internal Revenue Service plans to ramp up partnership audits in the next couple of years to boost the current audit rate of 0.05% as the agency props up a new unit that solely focuses on examining large partnerships, an agency attorney said Friday.
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December 13, 2024
IRS To Wrap Up Worker Retention Credits In 2025, Werfel Says
The Internal Revenue Service plans to wrap up processing next year for thousands of claims for tax credits meant to provide incentives for businesses that retained employees during the COVID-19 pandemic, agency Commissioner Daniel Werfel said Friday.
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December 13, 2024
IRS Extends Relief For Partnership Exchange Filing Penalties
The Internal Revenue Service on Friday extended its temporary pause on imposing penalties on taxpayers who failed to provide correct payee statements as part of a partnership interest exchange to those that failed to do so in 2024.
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December 13, 2024
CFC Tax Issues Can't Be Solved Via Treaties, Officials Say
Bilateral treaties between the U.S. and other countries where a controlled foreign corporation may face withholding tax issues aren't able to effectively resolve those disputes, Internal Revenue Service and Treasury officials said Friday.
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December 13, 2024
IRS Mulls Turning Off Foreign Currency Rules For CFCs
The Internal Revenue Service is in the early stages of considering whether foreign currency gain or loss recognition rules could be turned off in certain situations for controlled foreign corporations, an agency official said Friday.
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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.
Expert Analysis
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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.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.
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As Promised, IRS Is Coming For Crypto Tax Evaders
The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.
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5 Reasons Associates Shouldn't Take A Job Just For Money
As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.
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Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules
Regulations recently proposed by the IRS and the U.S. Department of the Treasury concerning two types of tax credits for clean hydrogen production facilities should resolve many of the most pressing questions around qualification for the credits — albeit in a relatively stringent manner, say attorneys at Morgan Lewis.
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Employee Experience Strategy Can Boost Law Firm Success
Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.
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6 Practice Pointers For Pro Bono Immigration Practice
An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.
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Lessons From Country Singer's Personal Service Saga
Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.