Federal
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December 19, 2024
Atty Exits Denmark's $2.1B Tax Fraud Case After Settlement
A New York federal court removed an attorney from a $2.1 billion tax fraud suit after Denmark's tax authority settled with him on his involvement in the matter, according to recent filings.
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December 19, 2024
Denmark Says $500M Recovered In Dividend Tax Fraud Suits
Denmark's tax administration has recovered a total of 3.6 billion Danish kroner ($500 million) in money lost to suspected dividend tax refund fraud after entering settlements of civil cases in several countries in 2024, Denmark's tax minister announced.
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December 19, 2024
Top Federal Tax Policies Of 2024
In 2024, the U.S. Senate rejected a tax bill negotiated between the chairs of the House and Senate tax-writing committees, and on the regulatory front, the U.S. Department of the Treasury and Internal Revenue Service pressed ahead with regulations implementing the Inflation Reduction Act. Here, Law360 looks at the most consequential developments in federal tax policy from the past year.
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December 19, 2024
5th Circ. Urged To Deny Tax Break For Doc's Captive Insurance
A physician who owns a network of urgent care clinics was correctly denied tax deductions along with his wife for over $1 million in premiums they paid to insurance companies they owned, the government told the Fifth Circuit, saying the captive arrangements didn't qualify as insurance for tax purposes.
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December 19, 2024
GAO Finds Direct File Pilot Successful, Suggests Upgrades
The Internal Revenue Service conducted a successful test run this past tax season of Direct File, a new online tax return preparation service for individual taxpayers, but the agency could do more to expand access to the program, the U.S. Government Accountability Office reported Thursday.
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December 18, 2024
Tax Shelter Defendant Charged In Investment Ploy
Federal prosecutors have accused two men, one of whom is already facing charges of promoting tax shelters, with wire fraud and money laundering in connection with their operation of a multimillion-dollar fraudulent investment fund, according to an indictment unsealed Wednesday in Colorado federal court.
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December 18, 2024
Dutch Bank Exec Gave IRS Good Tax Tip, DC Circ. Judge Says
D.C. Circuit judges grappled Wednesday with the denial of a whistleblower award to a late Dutch bank executive who tipped off the IRS to tax reporting schemes, with one judge saying during oral arguments that the executive appeared to have handed the agency "gift-wrapped" evidence of wrongdoing.
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December 18, 2024
Dem Senators Probe IRS Pick's Past With Retention Tax Credit
Senate Finance Committee Chairman Ron Wyden said Wednesday that he was investigating President-elect Donald Trump's Internal Revenue Service commissioner pick over his work promoting the fraud-riddled employee retention tax credit and had sent letters demanding information from two tax advisory firms he worked for.
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December 18, 2024
Man Must Pay $1.3M Tax After Losing Fight Over IRS' Timing
A Nevadan owes the Internal Revenue Service more than $1.3 million for 2006 after a federal court rejected his arguments that the agency failed to timely pursue its tax claim against him.
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December 18, 2024
Short-Term Funding Bill Would Keep $20B For IRS Frozen
The Internal Revenue Service would have $20 billion in Inflation Reduction Act funding remain temporarily frozen under a deal lawmakers struck to keep the government running until March 14.
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December 18, 2024
Upcoming IRS Regs Will Have Optional Amount B Pricing
The Internal Revenue Service announced Wednesday that is planning to propose regulations that will give corporations the option to price certain cross-border transactions using a simplified and streamlined approach under a new international tax framework known as Amount B.
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December 18, 2024
IRS Pushes Some Retirement Plan Min. Distributions To 2026
The Internal Revenue Service updated the effective date to January 2026 — instead of next year — for when some must start to withdraw the required minimum amount of funds from several types of individual retirement accounts that were amended by a December 2022 retirement savings law.
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December 17, 2024
CORRECTED: Ineligible Calif. Securities Atty Accused Of Tax Crimes
A Southern California securities attorney currently ineligible to practice law has gone over five years without filing any personal federal income tax returns, the U.S. Department of Justice alleged in announcing a recently unsealed indictment against the lawyer on Tuesday.
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December 17, 2024
Texas Judge Won't Pause Block Of Corp. Transparency Law
A Texas federal judge on Tuesday denied the government's request to stay his nationwide block of a corporate transparency law while an appeal is pending, saying his view that Congress lacks the constitutional authority to enact the legislation is likely to prevail at the Fifth Circuit.
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December 17, 2024
Biz Group IDs Clean Fuel Production Registration Issues
The process of registering as a clean fuel producer in order to be eligible to claim the associated tax credit under the Inflation Reduction Act has proved to be confusing because of a number of practical issues, a group representing the U.S. biogas industry said in a letter released Tuesday.
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December 17, 2024
IRS Extends Accounting Change Waiver Eligibility To 2024
The Internal Revenue Service again adjusted a previous notice Tuesday to modify certain procedures for obtaining automatic consent of the agency commissioner to change methods of accounting for expenditures paid or incurred in taxable years beginning after 2021, extending them for another year.
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December 17, 2024
Payment To Ex-Wife Not Deductible Alimony, Tax Court Says
A man's $35,000 payment to his ex-wife from stock proceeds is not deductible because it qualifies as a division-of-assets payment and not alimony, the U.S. Tax Court ruled in a bench opinion released Tuesday.
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December 17, 2024
US Seeks Foreclosure To Pay 'Survivor' Winner's $3.3M Taxes
A federal magistrate judge should have recommended allowing the U.S. government to foreclose on two properties it claims are controlled by a winner of the "Survivor" TV series who owes $3.3 million in taxes, the government told a Rhode Island federal court.
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December 17, 2024
NY Urges Justices To Pass On IBM, Disney Royalty Tax Fight
The U.S. Supreme Court should decline to hear appeals by IBM and Disney that claim New York state's tax treatment of royalties received from foreign affiliates resulted in unconstitutional discrimination against interstate commerce, the state told the court Tuesday.
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December 17, 2024
IRS Corrects Proposed Admin Requirements For Direct Pay
The Internal Revenue Service issued a correction Tuesday to proposed regulations laying out administrative requirements for tax-exempt entities to elect out of their partnership status in order to take advantage of new rules enabling direct cash payment of clean energy tax credits.
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December 17, 2024
Ex-Pol Can't Shake Fraud Rap Over Jury's Racial Makeup
A Massachusetts federal judge denied a Vietnamese-American former state senator's bid to undo his conviction for unlawfully accepting unemployment assistance and filing a false tax return, rejecting claims that jury selection was tainted by "racial animus" on the part of prosecutors.
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December 17, 2024
Magic Runs Out For Tax Pro Who Stiffed IRS Out Of $145M
A New York City tax preparer who earned the nickname "the magician" while depriving the IRS of $145 million in revenue copped to tax evasion on Tuesday before a Manhattan federal judge.
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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.
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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.
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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.
Expert Analysis
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A Look Ahead For The Electric Vehicle Charging Industry
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.
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A Post-Mortem Analysis Of Stroock's Demise
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.
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SG's Office Is Case Study To Help Close Legal Gender Gap
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.
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Planning A Defense As IRS Kicks Off Sports Losses Campaign
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.
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What New Calif. Strike Force Means For White Collar Crimes
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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Reimagining Law Firm Culture To Break The Cycle Of Burnout
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.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
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.
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As Promised, IRS Is Coming For Crypto Tax Evaders
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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5 Reasons Associates Shouldn't Take A Job Just For Money
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.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
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.
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Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules
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.
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Employee Experience Strategy Can Boost Law Firm Success
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.
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6 Practice Pointers For Pro Bono Immigration Practice
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.