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Tax
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July 18, 2024
GE Can't Claim Credit For £189M In Double Tax, Court Says
A U.K.-registered subsidiary of General Electric does not qualify for at least £189 million ($245 million) in double tax relief under a U.S.-U.K. treaty because it lacks a U.S. presence akin to a domicile, a London appellate court ruled.
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July 17, 2024
Client Bids Didn't Trigger Fla. Long-Arm Law In Breach Suit
A Florida appellate court on Wednesday tossed a breach of contract lawsuit brought by a wealth planner against two out-of-state companies, saying that the parties did not do business in Florida and that a visit to win over potential clients wasn't enough to establish jurisdiction in the Sunshine State.
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July 17, 2024
NC Must Use Smithfield Foods Funds For Schools, Judge Says
North Carolina Attorney General Josh Stein can no longer get his hands on $2 million a year from Smithfield Foods to give out environmental grants to private entities after a judge ruled the state constitution requires the money to be used in public schools.
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July 17, 2024
Minn. Court Says VFW Property Subject To Lower Tax Rate
A group of properties used as a Veterans of Foreign Wars post in Minnesota should be subject to a lower property tax classification because they weren't used for revenue-making purposes, the state's tax court ruled.
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July 17, 2024
KPMG Australia To Shut Commercial Law Shop, Eye Alliances
KPMG Australia announced on Tuesday that it will "no longer [be] operating a separate and distinct commercial law practice," focusing instead on building alliances with firms in the nation.
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July 17, 2024
Rising Star: Cravath's Kiran Sheffrin
Kiran Sheffrin of Cravath Swaine & Moore LLP has advised companies from Anheuser-Busch InBev to Valvoline on multibillion-dollar deals, including a $50 billion combination resulting in the formation of pharmaceutical giant Viatris, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 17, 2024
Baker McKenzie Adds EY Partner To Mexico City Office
Baker McKenzie has appointed a new partner from EY Mexico to its North American tax practice group in Mexico City.
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July 16, 2024
NC Panel Affirms Property Tax Valuation For Ashley Furniture
About 300 acres of property belonging to Ashley Furniture in North Carolina were properly valued at about $60 million for tax years 2018 and 2019, a state appeals court panel ruled Tuesday in favor of the state property tax commission.
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July 16, 2024
7th Circ. Says Foreign Retirement Not Shielded In Bankruptcy
A professor who filed for bankruptcy in Illinois can't protect his Canadian retirement account from creditors because the account is ineligible under a state law shielding accounts that qualify as retirement plans under the Internal Revenue Code, the Seventh Circuit ruled Tuesday.
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July 16, 2024
Connecticut Contractor Fined $1.75M For Tax Evasion
A Connecticut contractor was ordered to pay a $1.75 million fine for evading federal corporate and individual income taxes from 2006 through 2010, the U.S. Department of Justice announced Tuesday.
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July 16, 2024
Tax Transparency Neglected In Latin America, Ex-Officials Say
The international tax transparency system is failing to produce results for Latin American governments, whose scant information requests are too often met with resistance and whose prosecutions generally lack a cross-cutting approach to tax, former officials from the region said Tuesday.
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July 16, 2024
Pa. Court Upholds $23M Value Of Vacant Hospital's Parking
A vacant hospital's parking area in Pennsylvania was properly valued at $23.2 million, the state Commonwealth Court ruled, finding that a trial court had the discretion to apply the sales comparison approach to the valuation.
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July 16, 2024
County Says Pittsburgh Schools Can't Force Reassessment
As one taxing body out of many in Allegheny County, Pennsylvania, the School District of Pittsburgh lacks standing in its lawsuit seeking to force a countywide reassessment of property values, the county said in its preliminary objections to the suit.
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July 16, 2024
Rising Star: Skadden's Melinda Gammello
Melinda Gammello of Skadden Arps Slate Meagher & Flom LLP has advised numerous clients before the U.S. Tax Court and elsewhere on complex tax matters, including transfer pricing issues and the treatment of financial transactions within a company, earning her a spot among the tax law practitioners under 40 honored by Law360 as Rising Stars.
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July 16, 2024
The 2024 Diversity Snapshot: What You Need To Know
Law firms' ongoing initiatives to address diversity challenges have driven another year of progress, with the representation of minority attorneys continuing to improve across the board, albeit at a slower pace than in previous years. Here's our data dive into minority representation at law firms in 2023.
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July 16, 2024
These Firms Have The Most Diverse Equity Partnerships
Law360’s law firm survey shows that firms' efforts to diversify their equity partner ranks are lagging. But some have embraced a broader talent pool at the equity partner level. Here are the ones that stood out.
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July 15, 2024
NRA's Policies Called 'Dumpster Fire' As 2nd NY Trial Opens
The New York attorney general cast the National Rifle Association as unrepentant and unreformed as a second-phase bench trial began in state court Monday, after a jury had found the group and its ex-officers liable for misspending millions.
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July 15, 2024
4th Circ. Rejects Couple's $5.1M Easement Deduction
The Fourth Circuit rejected Monday a married couple's bid to revive a claimed $5.1 million conservation easement deduction, saying it represented a "remarkable" attempt to inflate the value of a 41-acre property that was worth just $652,000 the year before they donated it.
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July 15, 2024
Widow To Pull $1.7M From Swiss Bank To Pay FBAR Penalties
A logger's widow agreed to pull about $1.7 million from her Swiss bank account to pay down penalties that her late husband's estate owes the IRS for his failure to report offshore accounts, according to a filing Monday in a Colorado federal court.
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July 15, 2024
Pa. Property Owner's Tax Appeal Meritless, Court Says
A Philadelphia property owner properly had its appeal of a tax assessment dismissed by a trial court because its complaints were meritless, the Pennsylvania Commonwealth Court affirmed.
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July 15, 2024
Akerman Brings On Chamberlain Hrdlicka Tax Pros In Atlanta
Akerman LLP announced Monday that it picked up a pair of new partners for its tax practice group in Atlanta who were previously with Chamberlain Hrdlicka White Williams & Aughtry.
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July 15, 2024
Rising Star: Davis Polk's Dominic Foulkes
Dominic Foulkes of Davis Polk & Wardwell LLP has advised companies on several multibillion-dollar transactions, including a technology-maker's $4.9 billion initial public offering, the largest in the United States in the last three years, earning him a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 12, 2024
Rising Star: Quinn Emanuel's Emily Au
Emily Au of Quinn Emanuel Urquhart & Sullivan LLP has been the lead attorney on several high-profile cases, including a key case across the U.K. construction industry in terms of HMRC's Value-Added Tax policy, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 12, 2024
Law360 Names 2024's Top Attorneys Under 40
Law360 is pleased to announce the Rising Stars of 2024, our list of 158 attorneys under 40 whose legal accomplishments belie their age.
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July 12, 2024
Conn. Justices Say Town Can Tax Hospital's Property
Personal property of a Connecticut hospital owned by Hartford HealthCare is taxable, the state Supreme Court said Friday, reversing a trial court opinion and ruling that Hartford's acquisition of the hospital negated a tax exemption for charitable entities.
Expert Analysis
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What To Know About IRS' New Jet Use Audit Campaign
The Internal Revenue Service recently announced plans to open several dozen audits scrutinizing executive use of company jets, so companies should be prepared to show the business reasons for travel, and how items like imputed income and deduction disallowance were calculated, say attorneys at Morgan Lewis.
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Stay Interviews Are Key To Retaining Legal Talent
Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.
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Opinion
Neb. Justices Should Weigh IRC Terms In Dividend Tax Case
Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.
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Series
Spray Painting Makes Me A Better Lawyer
My experiences as an abstract spray paint artist have made me a better litigator, demonstrating — in more ways than one — how fluidity and flexibility are necessary parts of a successful legal practice, says Erick Sandlin at Bracewell.
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A Legal Playbook For Stadium Construction Agreements
As a new wave of construction in the professional sports arena space gets underway, owners must carefully consider the unique considerations and risks associated with these large-scale projects and draft agreements accordingly, say attorneys at Akerman.
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Opinion
Judicial Independence Is Imperative This Election Year
As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.
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Series
Riding My Peloton Bike Makes Me A Better Lawyer
Using the Peloton platform for cycling, running, rowing and more taught me that fostering a mind-body connection will not only benefit you physically and emotionally, but also inspire stamina, focus, discipline and empathy in your legal career, says Christopher Ward at Polsinelli.
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Spartan Arbitration Tactics Against Well-Funded Opponents
Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.
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What Recent Study Shows About AI's Promise For Legal Tasks
Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.
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How FinCEN Proposal Expands RE Transaction Obligations
Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.
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What To Know About Employee Retention Credit Disclosures
Employers that filed potentially erroneous employee retention credit claims should take certain steps to determine whether the IRS’ voluntary disclosure program is a good fit and, if so, prepare a strong application before the window closes on March 22, say attorneys at Dentons.
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Litigation Inspiration: A Source Of Untapped Fulfillment
As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.
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Unpacking FinCEN's Proposed Real Estate Transaction Rule
Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.
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Series
Skiing Makes Me A Better Lawyer
A lifetime of skiing has helped me develop important professional skills, and taught me that embracing challenges with a spirit of adventure can allow lawyers to push boundaries, expand their capabilities and ultimately excel in their careers, says Andrea Przybysz at Tucker Ellis.
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Think Like A Lawyer: Forget Everything You Know About IRAC
The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.