Federal

  • July 12, 2024

    Mo. Says IRS 'Stonewalling' On Worker Credit Freeze Records

    The Internal Revenue Service violated public records law in failing to release documents related to its decision to stop processing new employee retention credit claims, the state of Missouri said Friday in a complaint that accuses the agency of "stonewalling."

  • July 12, 2024

    11th Circ. Urged To Grant Deductions In Ruined Records Case

    The U.S. Tax Court should have been more generous in granting tax deductions to a Florida couple whose records were destroyed by a hurricane, the couple told the Eleventh Circuit on Friday, saying the lost records were out of their control.

  • July 12, 2024

    European Tax Policy To Watch In The Second Half Of 2024

    Observers of European Union tax policy expect the EU to devote more attention to problems with existing tax legislation in the coming months as the introduction of major policy proposals takes a pause. Specialists also will be watching for progress on EU tax laws that remain stuck, and the bloc is likely to fill roles including tax commissioner. Here, Law360 examines key tax issues to watch for the remaining six months of the year.

  • 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.

Expert Analysis

  • 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.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    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.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    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.

  • Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules

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    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.

  • Employee Experience Strategy Can Boost Law Firm Success

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    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.

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    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.

  • Lessons From Country Singer's Personal Service Saga

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    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.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    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.

  • 5 Litigation Funding Trends To Note In 2024

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    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.

  • Tech CEO Tax Ruling A Warning For Forward Contracts

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    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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