Federal
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December 09, 2024
US Investment Cos. Benefit In Updated Norway Tax Treaty
Regulated U.S. investment and holding companies should be able to reap Norwegian tax treaty benefits on dividends, royalties and capital gains without restriction under an updated agreement announced Monday by the Internal Revenue Service.
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December 09, 2024
Woman Appeals Tax Court's Canadian Debt Ruling To 9th Circ.
A woman appealed to the Ninth Circuit a U.S. Tax Court decision that prevented her from challenging a federal tax lien issued by the Internal Revenue Service to secure her $200,000 tax debt to Canada on behalf of the Canadian government.
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December 09, 2024
Chicago Pol's Lies Enough To Keep Conviction, Feds Say
The government urged the U.S. Supreme Court not to disturb a former Chicago alderman's conviction for lying about money he'd borrowed from a since-shuttered bank, arguing his knowing understatements were enough to illegally mislead federal investigators.
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December 09, 2024
Man Owed $264K Under US-Canada Tax Treaty, Court Says
A U.S. man living abroad is allowed under the U.S.-Canada tax treaty to claim a foreign tax credit for nearly $264,000 in payments of the Affordable Care Act's net investment income tax, the Federal Claims Court said.
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December 09, 2024
Feds Seek 2-Year Sentence In Landmark Crypto Tax Case
The first person ever criminally charged for failing to report gains from the sale of cryptocurrency by filing false returns should be sentenced to more than two years in prison after he admitted underreporting $4 million in bitcoin proceeds, prosecutors told a Texas federal court.
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December 06, 2024
DC Circ. Affirms Man's $1.2M 'Seriously Delinquent' Tax Debt
A Florida man owes more than $1.2 million in federal taxes, the D.C. Circuit said Friday, affirming the Internal Revenue Service's certification of his liability under a law that allows those with a "seriously delinquent" tax debt to have their passport revoked.
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December 06, 2024
Trust Distribution Doesn't Violate Holding Law, IRS Says
A distribution from a trust of tenancy-in-common interests that resulted from the trust's involuntary termination will not prevent the interests from being held for certain investment and business purposes, the IRS said in a private letter ruling released Friday.
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December 06, 2024
Gov't Appeals Texas Judge's Block On Anti-Laundering Law
The U.S. government has appealed a Texas federal judge's order that halted the rollout of new reporting requirements aimed at unmasking anonymous shell companies, setting the stage for the Fifth Circuit to weigh in on the nationwide preliminary injunction.
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December 06, 2024
Simpson Thacher Adds Tax Pro From Ropes & Gray
Simpson Thacher & Bartlett LLP announced the firm has added a tax professional from Ropes & Gray LLP as a partner in its Washington, D.C., office.
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December 06, 2024
Biz Owner In $2.8M Worker Tax Scheme Asks To Avoid Prison
A construction company owner who admitted skirting $2.8 million in employment taxes by claiming that his workers were subcontractors, including one who fell to his death on a job, asked a Massachusetts federal court Friday for a sentence of home confinement rather than prison.
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December 06, 2024
Taxation With Representation: Skadden, Gibson Dunn
In this week's Taxation With Representation, BlackRock buys HPS Investment Partners, TreeHouse Foods Inc. buys Harris Tea, Aya Healthcare acquires Cross Country Healthcare, and Bruin Capital launches a soccer representation business.
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December 06, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included regulations aimed at making 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 05, 2024
IRS Pick's Retention Credit History Raises Sens.' Hackles
As senators digested President-elect Donald Trump's nomination of a former U.S. House member to be commissioner of the Internal Revenue Service, some Democrats said the nominee's experience promoting problematic employee retention credits immediately raised questions about his fitness to run the agency.
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December 05, 2024
11th Circ. Won't Rethink $100M Credit For John Hancock
The Eleventh Circuit won't reconsider its decision to let John Hancock Life Insurance Co. keep $100 million in foreign tax credits, leaving in place its October ruling against a Florida law firm retirement plan's trustees.
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December 05, 2024
Tax Court Penalizes Mail Carrier For Frivolous Returns
A retired U.S. Postal Service carrier from Texas owes $10,000 in civil penalties for making frivolous claims that his income wasn't subject to taxes because he wasn't a federal employee, the U.S. Tax Court ruled in a bench opinion released Thursday.
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December 05, 2024
IRS Issues Latest Required Retirement Plan Amendments List
The Internal Revenue Service released Thursday the 2024 edition of an annual list of required amendments for qualifying individually designed retirement plans.
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December 05, 2024
IRS Approved Late Workers' Comp. Payments, TIGTA Says
The Internal Revenue Service approved workers' compensation claims from agency employees that should have been barred because they were filed late, the Treasury Inspector General for Tax Administration said Thursday in a report that called for improvements to the agency's approval process.
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December 05, 2024
Texas Paving Co. Drops Suit Over $686K Carryback Refund
A Texas contracting company voluntarily dropped its case seeking a $686,000 tax refund, plus interest, from the Internal Revenue Service for a carryback operating loss.
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December 05, 2024
IRS Errors Allow Millions In Improper Refunds, TIGTA Says
Tax overpayments aren't being applied to outstanding debt in taxpayer accounts because of procedural and programming errors at the Internal Revenue Service that allow millions of dollars to be improperly refunded to taxpayers, the Treasury Inspector General for Tax Administration said Thursday.
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December 05, 2024
Senate Finance Committee Advances IRS Watchdog Pick
The Senate Finance Committee on Thursday advanced President Joe Biden's nomination of a former assistant inspector general at the U.S. Department of Veterans Affairs to serve as the top IRS watchdog.
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December 05, 2024
Whistleblower Asks DC Circ. To Strike Tax Court Judge Shield
A man whose whistleblower claim was blocked by the IRS for being too late asked the D.C. Circuit to reject a second U.S. Tax Court decision to uphold the denial, saying, among other things, that Tax Court judges have unconstitutional job protection.
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December 04, 2024
GAO Finds Limited Oversight, Data On Crypto In 401(k)s
Though crypto assets make up a small part of the 401(k) market, their limited federal oversight might leave workers responsible for monitoring the volatile investment options, according to a report released Wednesday by the U.S. Government Accountability Office.
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December 04, 2024
Trump Picks Ex-Congressman For IRS Commissioner
President-elect Donald Trump said Wednesday he has tapped a former member of the U.S. House of Representatives to lead the Internal Revenue Service during his coming second term.
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December 04, 2024
Senate Finance Committee Schedules Vote On TIGTA Nominee
The Senate Finance Committee has scheduled a vote Thursday on the nomination of David Samuel Johnson as the inspector general for tax administration, committee Chairman Ron Wyden announced Wednesday.
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December 04, 2024
Ending Trump Tax Cuts Would Have Neutral Effect, CBO Says
Allowing the individual income tax cuts enacted under President Donald Trump's 2017 tax overhaul to expire at the end of next year as planned won't have a significant effect on the economy over 10 years, the Congressional Budget Office said Wednesday.
Expert Analysis
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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.
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7 E-Discovery Predictions For 2024 And Beyond
The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.
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5 Litigation Funding Trends To Note In 2024
Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.
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Tech CEO Tax Ruling A Warning For Forward Contracts
In McKelvey v. Commissioner, the U.S. Tax Court decided that deceased Monster.com founder Andrew McKelvey terminated his underlying obligations when he extended variable prepaid forward contracts, demonstrating why startup founders, early employees and investors should think carefully before amending derivative agreements, say Daren Shaver and Trent Tanzi at Hanson Bridgett.
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4 Legal Ethics Considerations For The New Year
As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.