Federal

  • June 03, 2024

    Couple Can't Justify $3.7M Loss Deduction, Tax Court Says

    A New York couple failed to adequately prove that they should have been able to claim $3.7 million in net operating losses on their personal income taxes that were generated by settlement payments made by a company they owned, the U.S. Tax Court said Monday.

  • June 03, 2024

    Tax Convictions Withstand Poor Counsel Claim, 4th Circ. Says

    A North Carolina man's claim of ineffective counsel is not sufficient reason to vacate his convictions for filing false tax returns and obstructing an official proceeding in a case involving $2.1 million in unreported income sent from Bermuda entities, the Fourth Circuit ruled.

  • June 03, 2024

    Google Must Face Online Tax Filer's Privacy Suit

    An Illinois woman who prepared her taxes online through H&R Block and then sued Google, claiming the search engine's tracking tool effectively eavesdropped on her confidential tax information, can move forward with her proposed class action, a California federal judge ruled Monday.

  • June 03, 2024

    Texas Oil Co. Says IRS Hasn't Paid $36M Promised Refund

    The Internal Revenue Service has promised to pay a Texas oil company more than $36 million in tax refunds and credits for the 2009 tax year but has failed to do so, the company told a federal court.

  • June 03, 2024

    Vanguard Investors Want Class Cert. In Tax Liability Fight

    Investors accusing Vanguard and its top brass of violating its fiduciary duties by triggering a sell-off of assets in target retirement funds in an attempt to lower fees, leaving smaller investors with massive tax bills, asked a Pennsylvania federal court to certify them as a class.

  • June 03, 2024

    Taxes Take Center Stage In Pot Industry Amid Fed. Policy Shift

    The federal government's move to loosen restrictions on cannabis is expected to trigger a wave of mergers and acquisitions structured as asset deals in the industry, especially among struggling retail operations willing to restructure in order to raise profits and lower their tax liabilities.

  • June 03, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin, which included an updated list of procedures for taxpayer-initiated requests for changes in methods of accounting.

  • June 01, 2024

    Blockbuster Summer: 10 Big Issues Justices Still Must Decide

    As the calendar flips over to June, the U.S. Supreme Court still has heaps of cases to decide on issues ranging from trademark registration rules to judicial deference and presidential immunity. Here, Law360 looks at 10 of the most important topics the court has yet to decide.

  • May 31, 2024

    3M Tells 8th Circ. IRS Used Invalid Regs For $24M Allocation

    Multinational conglomerate 3M reiterated Friday its bid for the Eighth Circuit to reverse a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from the company's Brazilian affiliate, arguing the agency's adjustment relied on substantively invalid regulations.

  • May 31, 2024

    IRS Guidance Narrows Spinoffs Available For Preapproval

    Recent IRS guidance limiting the types of spinoff transactions that revenue officials will approve as tax-free ahead of time leaves practitioners and corporations to determine whether to pursue certain intercompany reorganizations without the agency's blessing.

  • May 31, 2024

    Ex-UBS Exec Owes $4.7M In FBAR Penalties, Court Told

    A former CEO of Swiss bank UBS' North American group faces a $4.7 million tax bill that the U.S. claims is due because he did not report his foreign bank accounts or assets, according to a suit filed in Connecticut federal court.

  • May 31, 2024

    IRS Can Seek Tax Beyond Bankruptcy Deal, 11th Circ. Affirms

    A deal between the IRS and an Alabama real estate developer to settle his tax debt for $2 million during Chapter 11 bankruptcy proceedings wasn't final, and the agency can demand additional taxes from him, the Eleventh Circuit affirmed Friday.

  • May 31, 2024

    US, Bulgaria Sign Country-By-Country Reporting Agreement

    The U.S. and Bulgaria signed an agreement Friday on the automatic exchange of country-by-country reports between the nations, Bulgaria's Ministry of Finance said.

  • May 31, 2024

    IRS Memo Backs Tax For Noninsurance Payments To Captives

    When the IRS determines that a company's payments to its foreign captive insurer were not for actual insurance, the agency can assert a 30% tax on the captive for the income it received under the arrangement, the IRS chief counsel's office said in a memo released Friday.

  • May 31, 2024

    Texan's Estate Owes $3.4M For Missed Tax Pays, Court Told

    A Texas man's estate owes over $3.4 million in unpaid taxes, interest and penalties because of missed payments stretching back over a decade, even after multiple extensions were granted to the two executors, the government told a federal district court.

  • May 31, 2024

    5 Tax Bills To Watch This Summer

    House and Senate lawmakers return to Washington, D.C., on Monday, where several tax-related bills await them in both chambers, including a stalled package that would restore business tax breaks and expand the child tax credit. Here, Law360 takes a look at five bills that could move through Congress this summer.

  • May 31, 2024

    Calif. Man Owes 6 Years Of FBAR Penalties, IRS Tells Court

    A Californian has failed to pay foreign bank account reporting penalties he was assessed that were tied to a business he owed in Mexico for six years, the Internal Revenue Service told a federal court.

  • May 31, 2024

    Fuel Producers Should Apply ASAP For Tax Credit, IRS Says

    Fuel producers hoping to start claiming the clean fuel production credit as soon as January should register with the Internal Revenue Service by July 15, the agency said Friday, warning that registration applications made after that date are less likely to go through in time.

  • May 31, 2024

    IRS Delays Deadlines For Mass. Taxpayers Hit By 2023 Storms

    Certain Massachusetts taxpayers impacted by severe storms and flooding that hit the state Sept. 11 now have until July 31 to file various individual and business tax returns and make payments, the Internal Revenue Service said Friday.

  • May 31, 2024

    Taxation With Representation: Cravath, Cleary, Fried Frank

    In this week's Taxation With Representation, T-Mobile buys United States Cellular Corp.'s wireless operations, Energy Transfer plans to buy WTG Midstream, ConocoPhillips acquires Marathon Oil, and Goldman Sachs Alternatives raises over $20 billion for its direct lending strategy.

  • May 30, 2024

    Chicago Kiosk Salesman Gets 1 Year For Filing False Returns

    An electronic-sweepstakes kiosk salesman from Chicago was sentenced to a year in prison for filing false tax returns that included more than $500,000 in inflated business expenses, according to Illinois federal court documents.

  • May 30, 2024

    IRS Adds 16 Tax Court Sessions To Calendar

    The Internal Revenue Service announced 16 U.S. Tax Court sessions in September and October and named calendar administrators for the sessions in a notice released Thursday.

  • May 30, 2024

    Tax Court Nixes $30M In Conservation Easement Deductions

    The U.S. Tax Court upheld on Thursday the IRS' rejection of more than $30 million in charitable contribution deductions for Alabama conservation easements for partnerships acting as test cases for a larger group that took $187 million in deductions.

  • May 30, 2024

    Tax Court Tosses Whistleblower Award Contest

    The U.S. Tax Court ruled Thursday that it cannot review a woman's roughly $1,700 whistleblower award from the Internal Revenue Service because it does not meet a threshold for mandatory awards.

  • May 30, 2024

    IRS Names New Chief Taxpayer Experience Officer

    The Internal Revenue Service has chosen an adviser in its Transformation and Strategy Office to serve as the agency's new chief taxpayer experience officer, according to a statement Thursday.

Expert Analysis

  • How Clients May Use AI To Monitor Attorneys

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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • How 'As Such' Changes LPs' Self-Employment Tax Exposure

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    In light of the U.S. Tax Court’s recent Soroban Capital Partners decision hinging on "as such" to define the statutory limited partners exemption, state law limited partnerships should consider partners' roles and responsibilities before determining whether they are obligated to pay self-employment income tax, say attorneys at Morgan Lewis.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • IRA Monetization Energizes Clean Power Tax Credit Market

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    Recent large sales of clean energy production tax credits reflect an environment in which the Inflation Reduction Act's provisions for monetizing such credits via direct transfer — bypassing slow, costly tax equity transactions — offer opportunities for both developers and investors, says Andrew Eastman at Husch Blackwell.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • Unpacking Long-Awaited Clean Energy Tax Credit Guidance

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    Recently proposed Internal Revenue Service regulations provide welcome confirmatory guidance on the application of investment tax credits as reworked by 2022's Inflation Reduction Act, prevailing wage and apprenticeship rules that are largely consistent with market expectations, and broader eligibility criteria that should please the wind power industry in particular, say attorneys at Morgan Lewis.

  • Understanding Discovery Obligations In Era Of Generative AI

    Excerpt from Practical Guidance
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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • An Informed Guide To Mastering Retirement Plan Forfeitures

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    When considering how to allocate departing retirement plan participants’ forfeitures, sponsors should consider recently filed lawsuits that allege Employee Retirement Income Security Act violations for using such funds to offset employer contributions, as well as proposed IRS guidance concerning how and when they must be used, says Eric Gregory at Dickinson Wright.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • IRS Proposal May Help Clarify Donor-Advised Fund Excise Tax

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    Recently proposed regulations provide important clarifications of the Internal Revenue Code's excise tax on donor-advised fund distributions by providing detailed definitions of key terms and addressing some of the open issues related to their operation and administration, say attorneys at Morgan Lewis.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

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