Federal

  • December 17, 2024

    IRS Finalizes Expanded 'Coverage Month' For Premium Credit

    The Internal Revenue Service finalized rules Tuesday that will expand the definition of a coverage month for purposes of computing the health insurance premium tax credit.

  • December 17, 2024

    Justices Urged To Let Stand Ex-Wife's Tax Payment Suit

    A woman who said the IRS wrongly applied her tax payment to her ex-husband's bill asked the U.S. Supreme Court to let stand a Third Circuit ruling allowing her to challenge it, saying the decision doesn't conflict with any other rulings and involves an issue that rarely occurs.

  • December 16, 2024

    Mich. Judge Troubled By Scope Of Feds' CTA Data Collection

    A federal judge in Michigan said new disclosure requirements for small businesses seem burdensome and intrusive during a Monday hearing focused on the privacy implications of the currently blocked anti-money laundering law.

  • December 16, 2024

    Texan Still Owes 2021 Tax Bill Despite Levy For Other Year

    While the U.S. Tax Court is sympathetic to a Texan's complaint that the Internal Revenue Service's levy procedure will result in his facing an endless string of collection actions, he still must pay his $12,500 deficiency from 2021, the Tax Court said Monday.

  • December 16, 2024

    6th Circ. Affirms $3M Tax Bill For Gold Broker

    A gold and silver broker who made fatuous arguments that he wasn't subject to income taxes owes $3 million in liabilities, the Sixth Circuit ruled, upholding a U.S. Tax Court decision.

  • December 16, 2024

    Tax Court Says Couple Must Recalculate $36M Loss Claims

    An Illinois couple must recalculate the more than $36 million in net operating loss carryforward deductions they claimed in 2008 and 2009, the U.S. Tax Court said Monday, siding with the Internal Revenue Service's determination that they had improperly included a number of losses.

  • December 16, 2024

    Tax Court Wrongly Cut Easement Deduction, 11th Circ. Told

    The U.S. Tax Court erred in drastically reducing a partnership's claimed $23 million deduction for donating a conservation easement in Georgia, the partnership told the Eleventh Circuit, saying the court improperly relied on a real estate expert's opinion to establish whether the land had mining value.

  • December 16, 2024

    Cos. Urge Judge To Maintain Injunction On Transparency Law

    A Texas federal judge doesn't need to stay his preliminary injunction on the rollout of new corporate transparency rules while the U.S. government's appeal of his decision is pending at the Fifth Circuit, a business lobbying group and others said Monday.

  • December 16, 2024

    Wyden Bill Would Nix Tax Perks For Private Placement Plans

    U.S. Senate Finance Committee Chairman Ron Wyden unveiled legislation Monday that would remove the tax benefits of a special type of private life insurance plan that he said high-net-worth individuals have been abusing to avoid paying taxes on their investments in the policies.

  • December 16, 2024

    High Court Passes On Protest Of IRS Social Security Levy

    The U.S. Supreme Court said Monday it won't review an Eleventh Circuit decision denying a woman's challenge to the IRS' garnishment of her Social Security payments, letting stand the circuit court's conclusion that her suit was barred because she failed to exhaust administrative remedies.

  • December 16, 2024

    Applicable Federal Rates Set To Increase Again In Jan.

    Applicable federal rates for income tax purposes will increase across the board in January, a second straight month of increases after a string of months that saw declining rates, the Internal Revenue Service said Monday.

  • December 16, 2024

    Justices Won't Review Man's Demand For Dad's Tax Info

    The U.S. Supreme Court on Monday let stand a D.C. Circuit decision tossing a man's suit against the IRS for withholding his dead father's tax records, a ruling the man claimed had deepened a circuit split over the correct process for obtaining personal tax documents.

  • December 16, 2024

    IRS Issues Corp. Bond Monthly Yield Curve For Dec.

    The Internal Revenue Service published the corporate bond monthly yield curve for December for use in calculations for defined benefit plans Monday, as well as corresponding segment rates and other related provisions.

  • December 16, 2024

    IRS Corrects Regs On Direct Pay Of Partnership Tax Credit

    Internal Revenue Service issued a correction Monday to final regulations that 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.

  • December 16, 2024

    LegalZoom Launches Strategic Alliance With 1-800Accountant

    LegalZoom announced Monday that it will launch a multiyear strategic partnership with financial services firm 1-800Accountant by the start of the new year.

  • December 14, 2024

    IRS Criminal Probes On Worker Retention Cases Still Early

    The Internal Revenue Service's criminal arm is still in the early stage of investigating the most extremely fraudulent claims of a tax credit intended to reward businesses for retaining employees during the COVID-19 pandemic, an official said Saturday.

  • December 13, 2024

    IRS Aims To Ramp Up Partnership Audits, Official Says

    The Internal Revenue Service plans to ramp up partnership audits in the next couple of years to boost the current audit rate of 0.05% as the agency props up a new unit that solely focuses on examining large partnerships, an agency attorney said Friday.

  • December 13, 2024

    IRS To Wrap Up Worker Retention Credits In 2025, Werfel Says

    The Internal Revenue Service plans to wrap up processing next year for thousands of claims for tax credits meant to provide incentives for businesses that retained employees during the COVID-19 pandemic, agency Commissioner Daniel Werfel said Friday.

  • December 13, 2024

    IRS Extends Relief For Partnership Exchange Filing Penalties

    The Internal Revenue Service on Friday extended its temporary pause on imposing penalties on taxpayers who failed to provide correct payee statements as part of a partnership interest exchange to those that failed to do so in 2024.

  • December 13, 2024

    CFC Tax Issues Can't Be Solved Via Treaties, Officials Say

    Bilateral treaties between the U.S. and other countries where a controlled foreign corporation may face withholding tax issues aren't able to effectively resolve those disputes, Internal Revenue Service and Treasury officials said Friday.

  • December 13, 2024

    IRS Mulls Turning Off Foreign Currency Rules For CFCs

    The Internal Revenue Service is in the early stages of considering whether foreign currency gain or loss recognition rules could be turned off in certain situations for controlled foreign corporations, an agency official said Friday.

  • December 13, 2024

    Feds Narrow Drug Case Against Wife Of Convicted Drexel Prof

    Prosecutors have told a New Jersey federal judge that they would drop one of three drug distribution charges against the wife of a convicted former Drexel University professor, saying their evidence might not establish intent after the U.S. Supreme Court raised the burden of proof for such cases in 2022.

  • December 13, 2024

    Halliburton Consistent On Claims For $35M Refund, Court Told

    Halliburton has not changed its reasons for claiming a tax refund on a $35 million payment it made to a foreign government to protect its employees from harassment, the company told a Texas federal court, saying the U.S. wrongly accused it of a flip-flop.

  • December 13, 2024

    Taxation With Representation: Kirkland, Davis Polk, Wachtell

    In this week's Taxation With Representation, Google and TPG Rise Climate partner with Intersect Power, Gen Digital Inc. acquires MoneyLion Inc., Patient Square Capital acquires Patterson Companies Inc., and the Buffalo Bills and Miami Dolphins sell minority ownership shares to private equity firms.

  • December 13, 2024

    Contractor Loses Bail For Texting Alleged Tax Cheat Allies

    A District of Columbia federal judge revoked bail for a former defense contractor accused of running a $350 million tax-evasion scheme that prosecutors call one of the largest in U.S. history, after the government said he'd been texting his alleged co-conspirators.

Expert Analysis

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • A Proposal For Fairer, More Efficient Innocent Spouse Relief

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    Adding a simple election to the current regulatory framework for innocent spouse claims would benefit both taxpayers and the Internal Revenue Service by alleviating the undue burdens placed on those the program was intended to help and improving agency collections in such cases, says Laurie Kazenoff at Kazenoff Tax.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • 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.

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