Federal

  • July 12, 2024

    Taxation With Representation: Ropes & Gray, Cravath, Latham

    In this Week's Taxation with Representation, Paramount Global merges with Skydance Media, Devon Energy acquires Grayson Mill Energy's Williston Basin oil and gas business, Ryan acquires Altus Group Ltd.'s property tax business, and Bain Capital buys Envestnet Inc.

  • July 12, 2024

    Former City Treasurer Gets 30 Months In $1M Embezzlement

    A former city treasurer in Alaska was sentenced to two and a half years in prison after having admitted to tax evasion and fraud in connection with a $1 million embezzlement scheme, according to Alaska federal court documents.

  • July 12, 2024

    7 Taxpayer Advocacy Panel Committees To Meet In August

    Seven of the Taxpayer Advocacy Panel's committees will hold public meetings in August focused on improving customer service at the Internal Revenue Service, the agency announced Friday.

  • July 12, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included the reporting and recording obligations associated with the stock buyback excise tax.

  • July 11, 2024

    3 Defenses The IRS Can Fall Back On After Chevron's Demise

    The U.S. Supreme Court's decision to eliminate federal agencies' ability to rely on the 40-year-old Chevron doctrine to defend their interpretations of ambiguous laws will likely trigger more litigation against the IRS. But that doesn't mean the agency is completely defenseless against such suits. Here, Law360 explores three defense options for the IRS following Chevron's demise.

  • July 11, 2024

    House GOP Urges USTR To Probe Canada Digital Services Tax

    The U.S. trade representative should immediately launch an investigation into Canada's recently enacted digital services tax and determine if trade actions are necessary to protect American interests, U.S. House Ways and Means Republicans said in a letter Thursday.

  • July 11, 2024

    Tax Court Denies Real Estate Loss Deduction To Builder

    The U.S. Tax Court said Thursday that it didn't believe a man who claimed to work an extra 48 hours a week beyond his regular full-time job to build a short-term rental property, denying him a $22,000 rental real estate loss deduction reserved for real estate professionals.

  • July 11, 2024

    ABA Attys Seek To Avoid Reporting Foreign Trust Loans

    The American Bar Association's tax, real estate and trust attorneys are seeking to prevent the U.S. Treasury Department from tightening reporting requirements for the exemption of loans from foreign trusts, which are often used by wealthy families and in succession planning, according to a consultation response.

  • July 11, 2024

    Railroad Benefits Are Taxable, Tax Court Says

    A retired railroad worker and his wife must include benefits from the Railroad Retirement Board in their taxable income, having failed to prove that the benefits are nontaxable due to their disabilities, the U.S. Tax Court ruled Thursday.

  • July 11, 2024

    Ex-Leaders Ask Biden For Int'l Coordination On Billionaire Tax

    President Joe Biden should get behind Brazil's proposal for the Group of 20 nations to coordinate a minimum tax on billionaires, nearly 20 former presidents and prime ministers from countries such as Canada, France and South Korea said in an open letter.

  • July 11, 2024

    IRS Proposes 'Basket Contracts' As Listed Transactions

    The Internal Revenue Service proposed rules Thursday that would flag so-called basket option contracts as potentially abusive listed transactions, imposing additional reporting requirements under the threat of penalty for individuals and businesses involved in such arrangements.

  • July 11, 2024

    Low-Speed EV Maker Sues Treasury Over Blocked Tax Credits

    The U.S. Department of the Treasury violated the Administrative Procedure Act when it passed final regulations excluding low-speed vehicles from qualifying for clean vehicle tax credits, a maker of low-speed electric cars told a D.C. federal court.

  • July 11, 2024

    IRS Crackdown Yields $1B From Millionaires, Treasury Says

    The Internal Revenue Service collected more than $1 billion from millionaires with large tax debts through an enforcement initiative against high-income, high-wealth taxpayers who hadn't paid their tax bills, the U.S. Department of the Treasury said Thursday.

  • July 10, 2024

    Ex-VP Of Fla. Aerospace Co. Sentenced To Prison For Fraud

    The former vice president of a Miami-based aerospace company was sentenced to just over a year in federal prison after he pled guilty to fraud-related charges in connection to a scheme that involved embezzling millions of dollars and splitting the proceeds with a co-conspirator.

  • July 10, 2024

    Engineer Who Faced Export Charges Cops To Tax Counts

    A Chinese-born engineer has pled guilty to two counts of filing a false tax return related to allegations that he and his wife omitted gross income from their tax returns between 2015 and 2019, after Texas federal prosecutors initially charged the couple with export violations and fraud. 

  • July 10, 2024

    Tax Court Nominees Vow To Sort Out Post-Chevron Cases

    Three nominees for spots on the U.S. Tax Court assured Senate lawmakers Wednesday that they could resolve cases involving federal regulations and congressional intent after the U.S. Supreme Court overturned the Chevron deference doctrine.

  • July 10, 2024

    OECD Publishes Pillar 2 Technical Reporting Language Draft

    The Organization for Economic Cooperation and Development published a draft of technical details required to digitally input and disseminate information required for Pillar Two global minimum tax returns Wednesday.

  • July 10, 2024

    Americans Overseas Ask for Clarity In Foreign Trust Regs

    An advocacy group representing U.S. citizens living abroad urged the U.S. Treasury Department to clarify proposed rules for reporting transactions with foreign trusts, contending that guidance should explain which common pension arrangements are exempt from disclosure obligations.  

  • July 10, 2024

    IRS Says Related Biz Arms Must Each Apply For Fuel Credit

    Two related business departments that are both clean fuel producers and that have their own employer identification numbers must each apply on their own for the clean fuel production credit, the Internal Revenue Service said in an FAQ released Wednesday.

  • July 10, 2024

    Chevron's End Won't Affect Cubs Sale Tax Suit, 7th Circ. Told

    An anti-abuse rule the IRS is using to push for taxes on gains from Tribune Media Co.'s sale of the Chicago Cubs is not threatened by the U.S. Supreme Court ruling overturning the Chevron deference doctrine, an attorney for the IRS told the Seventh Circuit on Wednesday.

  • July 10, 2024

    IRS Issues Electricity Credit Reference Price For Wind

    The Internal Revenue Service released a 2024 reference price for determining the availability of the renewable electricity production credit for wind energy facilities in a notice issued Wednesday.

  • July 10, 2024

    House Dems Seek IRS Review Of Groups' Church Status

    A group of House Democratic lawmakers asked the Internal Revenue Service to review the tax exemptions of conservative advocacy groups that they contend have improperly received tax-exempt status as churches, according to a letter released Wednesday.

  • July 10, 2024

    5th Circ. Told 'Pay To Litigate' Rule Doesn't Bar Refund Suit

    A couple arguing the IRS failed to apply their tax overpayments to deficiencies claimed by the agency asked the Fifth Circuit to reverse a lower court's dismissal of their suit on the grounds that they hadn't paid their bill, saying the decision effectively asks them to pay twice.

  • July 09, 2024

    IRS Funding At Stake In 2025 Tax Cut Negotiations

    Lawmakers are girding for battle over the soon-to-expire individual tax cuts in the 2017 tax law, and IRS funding will be central to the debate at a time when the agency may be in need of additional resources due to changes in law.

  • July 09, 2024

    House Panel OKs Tax Breaks For More Education Expenses

    The House Ways and Means Committee sent several education-related tax bills to the full House of Representatives on Tuesday, including legislation that would make additional elementary and secondary school expenses eligible for tax-advantaged education savings accounts.

Expert Analysis

  • Proposed Hydrogen Tax Credit Regs May Be Legally Flawed

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    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.

  • Navigating ACA Reporting Nuances As Deadlines Loom

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    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.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    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.

  • Why Biz Groups Disagree On Ending Chevron Deference

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    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.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    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.

  • A Look Ahead For The Electric Vehicle Charging Industry

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    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.

  • A Post-Mortem Analysis Of Stroock's Demise

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    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.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    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.

  • Planning A Defense As IRS Kicks Off Sports Losses Campaign

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    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.

  • What New Calif. Strike Force Means For White Collar Crimes

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    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.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    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.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    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.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    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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