Federal

  • October 15, 2024

    The 2024 Law360 Pulse Social Impact Leaders

    Check out our Social Impact Leaders ranking, analysis and interactive graphics to see which firms stand out for their engagement with social responsibility and commitment to pro bono service.

  • October 15, 2024

    Gov't Resists DC Circ. Redo In Ayahuasca Church Tax Case

    An Iowa church that used a psychedelic in its rites was correctly denied tax-exempt status on grounds that it was organized for illegal aims, the federal government told the D.C. Circuit in urging it to reject the church's request for a rehearing.

  • October 11, 2024

    Julie Chrisley Appeals Ga. Judge's Resentencing Ruling

    Former real estate mogul and reality television star Julie Chrisley, who was convicted of running a yearslong bank fraud scheme with her husband, Todd, is appealing a federal judge's decision to resentence her to the same seven-year prison term she first received nearly two years ago.

  • October 11, 2024

    Philly Pizzeria Owner Accused Of Dodging Taxes

    A Pennsylvania pizzeria owner evaded taxes for multiple years by paying himself and employees in cash and lied about it to his accountant, the U.S. Department of Justice said in announcing charges against him.

  • October 11, 2024

    Tribal Wildfire Victims Can File Returns Late, IRS Says

    Members of the San Carlos Apache Tribe in Arizona who were affected by a wildfire in July may put off filing certain tax returns until Feb. 5, the Internal Revenue Service said Friday.

  • October 11, 2024

    Tax-Exempt Orgs Get More Time To Make Payment Election

    Certain tax-exempt organizations making an elective payment election have an extra six months to file their business income tax return to declare such an election, the Internal Revenue Service said Friday.

  • October 11, 2024

    IRS Delays Fla. Deadlines, Grants Other Relief After Milton

    Following Hurricane Milton, the Internal Revenue Service has granted all taxpayers in Florida until May 1 to file individual and business tax returns and make payments, the agency said Friday, while also granting dyed diesel penalty relief.

  • October 11, 2024

    Disputes May Loom Over Dividend Deductions For CFCs

    U.S. multinational corporations are concerned that rulemakers' interpretation of a law allowing tax-free repatriation of certain overseas earnings could lead to controversy after the Internal Revenue Service published a memo indicating the break is unavailable for controlled foreign corporations.

  • October 11, 2024

    Bank Info Fair Game In Crypto Exec's Appeal, Gov't Says

    A cryptocurrency executive charged in a 2020 bitcoin fraud investigation can't stop the IRS from using the financial information it gathered through summonses while he appeals the demands in the Fifth Circuit, the U.S. government told a Texas federal court.

  • October 11, 2024

    5 Mos. Jail Enough For Swiss Tax Expert In $60M IRS Scam

    A Manhattan federal judge on Friday allowed a former financial executive from Switzerland to avoid additional time behind bars for his role in building a complex tax fraud scheme that helped wealthy Americans hide $60 million from the IRS.

  • October 11, 2024

    Taxation With Representation: Davis Polk, Latham, Kirkland

    In this week's Taxation With Representation, Rio Tinto agrees to acquire Arcadium Lithium for roughly $6.7 billion, Ares Management Corp. and GCP International reach a $3.7 billion deal, and Butterfly Equity announces plans to buy The Duckhorn Portfolio for $2 billion.

  • October 11, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included proposed rules for the new 15% corporate alternative minimum tax on corporations with reported profits of $1 billion or more.

  • October 10, 2024

    IRS Announces 9 Tax Court Sessions Added To Calendar

    The Internal Revenue Service announced nine U.S. Tax Court sessions in February and March and named calendar administrators for the sessions.

  • October 10, 2024

    Estimated Tax Gap For 2022 Falls To $696B, IRS Says

    The projected federal gross tax gap between taxes owed and taxes paid for the 2022 tax year was $696 billion, a $12 billion decrease from 2021, according to a report published Thursday by the Internal Revenue Service.

  • October 10, 2024

    Partnership Challenges Denial Of $42M Easement Deduction

    The Internal Revenue Service failed to justify rejecting a Florida partnership's charitable contribution deduction for donating a $42 million conservation easement to a land conservancy, the partnership told the U.S. Tax Court.

  • October 10, 2024

    IRS Says It's Stepping Up Worker Credit Claims Processing

    The Internal Revenue Service said Thursday it's accelerating processing of claims for pandemic-era worker credits after a moratorium triggered by what the agency has said was widespread fraud.

  • October 10, 2024

    Dems Weigh Extending 2017 Cuts To Maintain $400K Tax Vow

    Despite criticizing the 2017 Republican tax overhaul as a deficit-busting boon to the wealthy, congressional Democrats may feel pressure to support extending some of the law's individual and small-business provisions or risk breaking their pledge not to raise taxes on those earning $400,000 or less.

  • October 10, 2024

    Pfizer Lone Holdout In Senate Pharma Tax Probe, Wyden Says

    Pfizer Inc. is the only company to withhold a country-by-country breakdown of its tax planning in the Senate Finance Committee's probe into how Republicans' 2017 tax package reduced the pharmaceutical industry's U.S. liabilities, according to a letter Chairman Ron Wyden released Thursday.

  • October 10, 2024

    Calif. Says FDIC Must Wait For $21M Tax Refund

    A California tax agency urged a New York federal court to toss a lawsuit by the FDIC seeking a $20.7 million tax refund on behalf of the shuttered Signature Bank, saying it's entitled to wait for a possible IRS audit before delivering the payment.

  • October 10, 2024

    IRS Keeping Co. In Dark On Carryback Refund, Court Told

    The Internal Revenue Service owes a $686,000 tax refund to a contractor for a carryback operating loss, the company told a Texas federal court, adding that the IRS hasn't responded to questions about a letter the agency claims it sent addressing the issue.

  • October 09, 2024

    Tax Court Rejects Levy On Convicted Atty Over $7B Scheme

    A U.S. Tax Court judge rejected an IRS levy for restitution owed by an ex-attorney serving time for orchestrating a $7 billion tax fraud scheme, saying the agency had made contradictory determinations about the alleged debt and wrongly involved the former attorney's wife, in an opinion released Wednesday.

  • October 09, 2024

    Army Reservist, Wife Lose Appeal Of Tax Debt And Penalty

    The Internal Revenue Service correctly determined a U.S. Army reservist and his wife were deficient on their taxes and liable for an accuracy-related penalty, the U.S. Tax Court said Wednesday, finding they failed to report income and didn't back up claimed deductions.

  • October 09, 2024

    OECD Should Clarify Pillar 2 Safe Harbor Timing, CPAs Say

    The OECD should clarify when exactly multinational corporations need to determine whether they qualify for a transitional safe harbor under an international minimum tax agreement, the American Institute of Certified Public Accountants recommended in a letter.

  • October 09, 2024

    3M Tax Ruling Must Fall Post-Chevron, Chamber Tells 8th Circ.

    The U.S. Supreme Court's ending of the Chevron doctrine calls for overturning a U.S. Tax Court ruling that let the IRS allocate $24 million of income to multinational conglomerate 3M from a Brazilian affiliate, the U.S. Chamber of Commerce told the Eighth Circuit on Wednesday.

  • October 09, 2024

    Election Uncertainty Hampers Companies' Tax Planning

    With the November election approaching, businesses are bracing for the potential impact of two very different sets of tax policies, with the resulting uncertainty making long-term tax planning increasingly difficult.

Expert Analysis

  • Finding Focus: Strategies For Attorneys With ADHD

    Author Photo

    Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.

  • Unlocking Value In Carve-Out M&A Transactions

    Author Photo

    Some of the largest mergers and acquisitions in 2023 were carve-out transactions, and despite their unique intricacies and challenges, these transactions offer both buyers and sellers the opportunity to generate outsized returns in an otherwise vigorously competitive landscape, when carefully planned and diligently executed, say Kevin Crews and Rami Totari at Kirkland.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

    Author Photo

    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

    Author Photo

    After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.

  • Tips For Litigating Against Pro Se Parties In Complex Disputes

    Author Photo

    Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.

  • Anticipating Intensified Partnership Enforcement From IRS

    Author Photo

    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

  • Pro Bono Work Is Powerful Self-Help For Attorneys

    Author Photo

    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

    Author Photo

    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

  • Newman Suspension Shows Need For Judicial Reform

    Author Photo

    The recent suspension of U.S. Circuit Judge Pauline Newman following her alleged refusal to participate in a disability inquiry reveals the need for judicial misconduct reforms to ensure that judges step down when they can no longer serve effectively, says Aliza Shatzman at The Legal Accountability Project.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

    Author Photo

    Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • How Law Firms Can Use Account-Based Marketing Strategies

    Author Photo

    Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.

  • While Risks Exist, AI Could Transform IRS Enforcement

    Author Photo

    The Internal Revenue Service's recently announced use of artificial intelligence could revolutionize the agency's enforcement efforts, and transparency about its use and a forum for challenging AI findings could help mitigate fears that the technology will increase bias, say attorneys at Lewis Brisbois.

  • Strategic Succession Planning At Law Firms Is Crucial

    Author Photo

    Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.