Federal
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November 21, 2024
Israel-Hamas War Tax Relief Needed More Notice, TIGTA Says
While the Internal Revenue Service did well to proactively identify taxpayers likely affected by the Israel-Hamas war that it sought to grant tax relief, it failed to directly notify these taxpayers, the Treasury Inspector General for Tax Administration said Thursday.
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November 21, 2024
11th Circ. Asked To Rethink $100M Credit For John Hancock
The Eleventh Circuit should reverse its decision allowing John Hancock Life Insurance Co. to keep $100 million in foreign tax credits that rightfully belong to the company's investors, trustees of a retirement plan said in arguing that the court overlooked a key U.S. Treasury regulation.
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November 20, 2024
Fla. Couple Ask To Revive Suit Over Unclaimed Property
A Florida couple asked the Eleventh Circuit Wednesday to revive their proposed class suit against the state's chief financial officer over a law that allows officials to hold unclaimed money indefinitely, arguing that it is a taking without just compensation because the state never pays interest on the amount held.
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November 20, 2024
DC Circ. Upholds Taxes For Couple Lacking IRS Notice
A Georgia couple whose challenge of a 2019 tax collection was dismissed by the U.S. Tax Court when they failed to present the required IRS notice of deficiency were similarly turned away by the D.C. Circuit on Wednesday.
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November 20, 2024
Fla. Tax Preparer Gets 4 Years For Tax Fraud Scheme
A barred Florida tax preparer was sentenced to four years in prison for falsifying returns to trigger inflated refunds for participants in a three-year tax fraud scheme called the "note program," the U.S. Department of Justice said Wednesday.
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November 20, 2024
Feds Again Seek Early Win In $11.6M Willful FBAR Dispute
The U.S. government intends to renew its request to resolve a narrow matter in a dispute with an international businessman facing an $11.6 million penalty for willful failure to report his foreign bank accounts before the case heads to trial, according to a filing in Hawaii federal court.
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November 20, 2024
11th Circ. Skeptical Couple Can Skip Tax On Stolen Funds
Eleventh Circuit judges seemed unconvinced by a couple's request to overturn a decision that they owed taxes on $1.2 million in savings that their daughter swindled from them, saying during oral arguments Wednesday that their situation, however sympathetic, does not appear to warrant tax relief.
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November 20, 2024
IRS Should Tout Funding Boost Benefits, Advisory Panel Says
The Internal Revenue Service needs to appeal to taxpayers by communicating the benefits of the funding boost the agency received under the 2022 tax and climate law, the IRS Advisory Council said in a report released Wednesday.
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November 19, 2024
Former GOP Tax Chair Urges TCJA Permanence In 2025
Making permanent the provisions of the 2017 tax overhaul that are set to expire at the end of 2025 would provide certainty for businesses and individuals and encourage investment and expansion, former House Ways and Means Committee Chairman Kevin Brady said Tuesday.
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November 19, 2024
12 House Dems Call For Flexible Hydrogen Tax Credit Rules
Twelve Democratic U.S. House members asked the U.S. Department of the Treasury on Tuesday to provide more lax requirements for the clean hydrogen production tax credit than what the agency has proposed.
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November 19, 2024
Group Of Local Gov'ts Asks For Clarity On Energy Credits
A coalition of local government agencies called on the U.S. Treasury Department and the IRS in a letter released Tuesday to clarify that tax-exempt entities undertaking projects that qualify for certain energy credits are able to choose elective payments for certain costs.
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November 19, 2024
'Survivor' Winner Needs To Pay $3.3M Tax Bill, Judge Advises
The winner of the "Survivor" television series who evaded taxes on his $1 million in prize money and served time in prison should pay $3.3 million of his civil liabilities, including fraud penalties, a federal magistrate judge said.
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November 19, 2024
Payments To Ex-Wife Clearly Tax-Deductible, 11th Circ. Told
A Georgia man claiming payments he must make to his ex-wife as part of a marital settlement are alimony and therefore tax-deductible reaffirmed his argument to the Eleventh Circuit, saying the court can clearly answer two questions in his favor.
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November 19, 2024
Liberty Global Tax Break Based On Void Moves, 10th Circ. Told
The economic substance doctrine is broad and can invalidate telecommunications company Liberty Global's transaction that led to a $2.4 billion deduction because steps taken to maximize the tax break lacked business purpose, a government attorney told the Tenth Circuit on Tuesday.
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November 19, 2024
IRS Can Extend Deadline Over Preparer's Fraud, 3rd Circ. Told
The Third Circuit should affirm a U.S. Tax Court ruling allowing the Internal Revenue Service to skirt the normal deadlines and assess taxes going back to 1993 against a couple who were unaware that their tax preparer had falsified their returns to lower their liabilities, the government said.
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November 18, 2024
Tax Court Won't Reverse On Foreign Reporting Penalties
The U.S. Tax Court affirmed Monday its position that the IRS lacks authority to assess certain foreign information reporting penalties, denying the agency's request to reverse a ruling that let a Missouri businessowner off the hook for $120,000.
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November 18, 2024
Nursing Home Owner Pleads Guilty A 2nd Time To Tax Fraud
A nursing home operator pled guilty for the second time in Newark federal court on Monday to a $38.9 million employment tax fraud scheme involving care centers he owned across the country.
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November 18, 2024
IRS Must Speed Up Adoption Of AI Governance, TIGTA Says
The Internal Revenue Service has nearly 70 artificial intelligence tools in use or in development, but the agency needs speed up its development of governance procedures to make sure AI is being used safely and securely, the Treasury Inspector General for Tax Administration said Monday.
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November 18, 2024
IRS Sinks Arizona's Challenge To Federal Tax On Rebates
A federal judge dismissed Arizona's challenge to the Internal Revenue Service's position that rebates the state paid to taxpayers with dependents in 2023 were subject to federal tax, saying the state lacked standing to bring the case.
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November 18, 2024
Stradley Ronon Adds Tax Pro From Perkins Coie In Chicago
Pennsylvania-based firm Stradley Ronon Stevens & Young LLP has added a tax partner to its Chicago office who spent more than two decades with Perkins Coie LLP, the firm announced Monday.
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November 18, 2024
6th Circ. Pauses IRS Summons For Eaton Worker Docs
The Sixth Circuit said Eaton Corp. doesn't have to comply with an IRS demand to produce performance reviews for its foreign employees until the appellate court decides whether to overturn a decision that the agency's transfer pricing investigation of the multinational power management company outweighed worker privacy concerns.
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November 18, 2024
Tobacco Co. Asks Justices To Review Ore. Out-Of-State Tax
Actions in Oregon by the wholesale customers of an out-of-state tobacco company do not invalidate the protections in federal law against state taxation, the company told the U.S. Supreme Court, seeking review of an Oregon Supreme Court decision.
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November 18, 2024
Loan Provider Owed $34M In Retention Credits, Court Told
A mortgage loan company based in New York asked a federal court to award it more than $34 million in pandemic-era employee retention tax credits, saying the Internal Revenue Service has failed to respond to three separate claims for the credits.
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November 18, 2024
Intuit's GC-Turned-People Chief Sees Comp Reach $15.8M
An executive who helps oversee financial software company Intuit's workforce and formerly served as its general counsel earned roughly $15.8 million in compensation for fiscal year 2024, most of that from stock awards, a public filing says.
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November 18, 2024
Allen Matkins Adds Stradley Ronon Tax Co-Chair In NY
Allen Matkins Leck Gamble Mallory & Natsis LLP has continued growing its New York office with the addition of the co-chair of Stradley Ronon Stevens & Young LLP's tax department, the firm said Monday.
Feds Want 1 Year In Prison For Accountant Who Hid $1.4M
An accountant who hid $1.4 million from the IRS should be sentenced to at least a year in prison despite his stated mental health issues, the government told a Connecticut federal court, saying he seemed driven at least partly by greed and thought he wouldn't get caught.
Treasury Finalizes Partnership Tax Credit 'Direct Pay' Regs
The U.S. Treasury Department finalized regulations Tuesday to 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.
Countries Eye Certain Tax Credits To Get Leg Up Under Pillar 2
The international minimum tax agreement known as Pillar Two is changing how countries compete for corporate investment, in part by prompting some governments to retool their tax credit systems in ways that could edge out jurisdictions with fewer resources.
Featured Stories
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Countries Eye Certain Tax Credits To Get Leg Up Under Pillar 2
The international minimum tax agreement known as Pillar Two is changing how countries compete for corporate investment, in part by prompting some governments to retool their tax credit systems in ways that could edge out jurisdictions with fewer resources.
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The Tax Angle: TCJA Debate, S Corp. Compliance
From a look at congressional lawmakers ramping up their debate over the expiration of the GOP's 2017 tax overhaul law to the IRS' plans to provide more oversight for pass-through businesses and S corporations, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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New Clean Electricity Credits At Risk In 2025 Tax Talks
Clean electricity tax credits in the Democrats' signature climate law could be scaled back amid next year's effort by President-elect Donald Trump and GOP lawmakers to quickly renew expiring provisions of the 2017 Tax Cuts and Jobs Act once they're in office.
Expert Analysis
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3 Ways To Train Junior Lawyers In 30 Minutes Or Less
Today’s junior lawyers are experiencing a skills gap due to pandemic-era disruptions, but firms can help bring them up to speed by offering high-impact skill building content in bite-sized, interactive training sessions, say Stacey Schwartz at Katten, Diane Costigan at Winston & Strawn and Lauren Tierney at Freshfields.
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Expect Surging Oil And Gas Industry Under New Trump Admin
Throughout his recent campaign, President-elect Donald Trump promised increased oil and natural gas production and reduced reliance on renewables — and his administration will likely bring more oil and gas dealmaking, faster federal permitting and attempts to roll back incentives for green energy, say attorneys at Sidley.
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The Bar Needs More Clarity On The Discovery Objection Rule
Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.
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Cos. Should Inventory Issues To Prep For New Congress
As the legislative and oversight agendas of the 119th Congress come into sharper focus, corporate counsel should assess and plan for areas of potential oversight risk — from tax policy changes to supply chain integrity — even as much uncertainty remains, say attorneys at WilmerHale.
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Conservation Easement Cases Weave Web Of Uncertainty
Much of the IRS and Justice Department’s recent success in prosecuting syndicated conservation easement cases can be attributed to the government’s focus on the so-called PropCo ratio, which could indicate treacherous waters ahead for participants and their advisers, even under the incoming Trump administration, say attorneys at Polsinelli.
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So You Want To Move Your Law Practice To Canada, Eh?
Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.
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Legislation Most Likely To Pass In Lame Duck Session
As Congress begins its five-week post-election lame duck session, attorneys at Greenberg Traurig break down the legislative priorities and which proposals can be expected to pass.
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What Trump's 2nd Presidency Could Mean For Crypto Sector
Trump's second term will bring a fundamental shift from the Biden administration's approach to crypto-asset regulation and banking supervision, with the most significant changes likely taking effect in the first two quarters of 2025 and broader policy shifts emerging over the next year, say attorneys at Cahill.
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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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Takeaways From The IRS' Crypto Doc Summons Win
A recent First Circuit decision holding that taxpayers do not have a Fourth Amendment reasonable expectation of privacy in cryptocurrency transaction records should prompt both taxpayers and exchanges to take stock of past transactions and future plans, say attorneys at BakerHostetler.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.