Federal
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December 02, 2024
IRS Floats Pooling, Annual Accounting In Offshore Profit Regs
U.S. multinational companies will be required to create annual shareholder accounts and adhere to new pooling concepts to properly account for previously taxed earnings and profits under proposed rules floated by the U.S. Treasury Department and Internal Revenue Service.
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December 02, 2024
A&O Shearman Tax Pro Jumps To Hogan Lovells In DC
Hogan Lovells said Monday that it has brought on a former Allen Overy Shearman Sterling tax partner who specializes in spinoffs, cross-border deals and other corporate transactions.
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December 02, 2024
DEA Asserts Its Role As Proponent Of Pot Rescheduling Plan
The Drug Enforcement Administration on Monday affirmed it was acting as the proponent of a proposal to loosen federal restrictions on marijuana, and the administrative law judge said supporters of rescheduling would not get an opportunity to cross-examine DEA witnesses.
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December 02, 2024
Calif. Biz Owner Can't Deduct Car Expenses, Tax Court Says
A California business owner failed to prove he is entitled to deductions related to car and truck expenses, the U.S. Tax Court said in a decision released Monday.
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December 02, 2024
IRS Finalizes Partnership Liability Regs After 11 Years
The Internal Revenue Service unveiled final regulations governing the allocation of partnership liabilities 11 years after releasing the proposed rules, saying no subsequent legislative and regulatory changes had taken place to compel the agency to otherwise renew the rulemaking process.
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December 02, 2024
IRS Regs Would Broaden Exception For Unmarked Vehicles
Unmarked vehicles used by firefighters or members of a rescue squad or ambulance crew would be considered a new type of qualified nonpersonal use vehicle that is exempted from substantiation requirements under regulations proposed Monday by the Internal Revenue Service.
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December 02, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's latest weekly bulletin included updates to tax interest and applicable federal rates as well as the corporate bond monthly yield curve.
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November 27, 2024
Georgia Couple Asks Full DC Circ. To Review Tax Case
A Georgia couple whose challenge of a 2019 tax collection was denied by both the U.S. Tax Court and a D.C. Circuit panel is asking for the full appellate court to reconsider its ruling.
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November 27, 2024
US Says Prof's 8th Amendment Argument Fails In FBAR Case
An 86-year-old former professor cannot claim that his $545,000 penalty for failing to report foreign bank accounts violates the Eighth Amendment, the U.S. told a federal court, saying the penalty is neither excessive nor a fine, and that he never raised the argument before.
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November 27, 2024
Up Next At The High Court: Transgender Care, Holocaust Art
The U.S. Supreme Court will return to the bench Monday for its December arguments session, which will include blockbuster questions about the constitutionality of state laws banning gender-affirming care for transgender minors and whether Hungary can be held liable for property stolen during World War II.
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November 27, 2024
US Seeks FBAR Penalties Over $1.7M In Foreign Accounts
A Texas woman should face penalties for willfully failing to disclose foreign bank accounts from 2011 through 2013, which held balances exceeding $1.7 million, the U.S. government told a federal court Wednesday.
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November 27, 2024
Attys, Insurance Broker Seek Appeal In $22M Tax Scheme
Two attorneys and an insurance agent plan to appeal to the Fourth Circuit their convictions in a criminal case that accused them of participating in a $22 million tax avoidance scheme, according to Wednesday filings in North Carolina federal court.
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November 27, 2024
Ex-FBI Informant In Biden Case Wants Tax Charges Separate
A former FBI informant accused of making fake criminal accusations against President Joe Biden and his son, Hunter Biden, told a California federal court that new tax evasion charges against him should remain separate because the two cases are unrelated.
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November 27, 2024
Co. Seeks To Add 3 Chemicals To Taxable Substances List
The Internal Revenue Service is seeking comments on proposals from a chemical exporter to add three chemicals to the Internal Revenue Code's list of taxable substances, the agency said.
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November 27, 2024
Ga. Tax Preparer Admits To Filing False Returns Netting $3M
A Georgia tax preparer pled guilty to filing fraudulent income tax returns on behalf of her clients that cost the federal government more than $3 million, prosecutors announced.
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November 26, 2024
Ukrainian Man Admits To $25M Staffing, Tax Scheme
A Ukrainian man who was recently extradited to the U.S. to face charges that he helped illegally employ immigrants in Florida hotels pled guilty to tax crimes that prosecutors say caused $25 million in tax losses, according to Florida federal court filings.
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November 26, 2024
Jones Walker Welcomes New Commercial, Tax Atty
Jones Walker LLP has added a corporate partner who practices tax law and negotiates, structures and drafts complex merger and acquisition transactions, financings and related contracts and agreements, the firm said.
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November 26, 2024
Tax Court Gives Education Co. 2nd Shot At Nonprofit Status
The U.S. Tax Court dismissed Tuesday a petition from an education company seeking nonprofit status, granting a joint request from the company and the Internal Revenue Service that will give the company time to improve its application.
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November 26, 2024
Jackson Hewitt Workers Get Final OK On $10.8M Settlement
A federal judge granted final approval to a $10.8 million settlement between former Jackson Hewitt Inc. workers and the tax preparation firm over claims the company's franchisees entered into an anti-competitive no-poach agreement despite the provision being removed from the company's franchise agreements.
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November 26, 2024
Ariz. Reps. Urge Exemption Of State Rebates From Federal Tax
Arizona's one-time state tax rebates issued in 2023 should be exempt from federal taxation, three U.S. House members from the state told House leadership, urging a floor vote on legislation to exclude the income following a federal court decision finding the payments taxable.
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November 26, 2024
IRS Delays $600 Payment Reporting Requirement A Final Time
The Internal Revenue Service will push back its implementation of a law requiring peer-to-peer payment platforms such as Venmo and PayPal to report aggregate payments of $600 or more for one final time, it said Thursday, and the threshold for 2025 will instead be $2,500.
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November 26, 2024
Gov't, US-Saudi Former Pilot Close $1.2M FBAR Suit
A U.S.-Saudi citizen who's been a pilot and luxury airplane consultant settled his $1.2 million dispute with the U.S. government over bank accounts in Switzerland that the IRS said he failed to report.
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November 26, 2024
IRS Confirms Commerce Payments In Chips Tax Credit
Semiconductor development projects that received funding awards from the U.S. Commerce Department's CHIPS incentives program are considered investments that can also take advantage of the advanced manufacturing tax credit, the Internal Revenue Service confirmed Tuesday in guidance.
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November 26, 2024
IRS Adds Eight Tax Court Sessions To Calendar
The Internal Revenue Service announced eight U.S. Tax Court sessions for February and named the calendar administrators for the sessions in notices released Tuesday.
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November 25, 2024
Ex-DOJ Attorney Joins Moore Tax Law Group In Chicago
The Moore Tax Law Group has brought on a former trial attorney for the U.S. Department of Justice, Tax Division, the firm announced.
Justices On Fence In Tax Clawback Case For Defunct Utah Co.
U.S. Supreme Court justices seemed divided during oral arguments Monday over whether the Tenth Circuit was correct to allow the bankruptcy trustee of a defunct Utah company to use state law to claw back $145,000 in federal taxes after the two-year deadline, a ruling that has created a 3-1 circuit split.
GOP Threats To IRS Funds Risk Halting Agency Progress
Republicans will likely seek to cut IRS funding when they take control of the House, Senate and White House next year, threatening to roll back the gains in staffing, enforcement and technology the agency has made since it received a funding boost in 2022.
Tax-Exempt Benefit Regs Would Give Tribes Overdue Power
Recently proposed regulations on tribal general welfare benefits would grant tribes sole discretion to determine which programs and services are tax-exempt benefits and, if finalized, would fulfill the long-overdue purpose of a 2014 law meant to give them more deference.
Featured Stories
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GOP Threats To IRS Funds Risk Halting Agency Progress
Republicans will likely seek to cut IRS funding when they take control of the House, Senate and White House next year, threatening to roll back the gains in staffing, enforcement and technology the agency has made since it received a funding boost in 2022.
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Tax-Exempt Benefit Regs Would Give Tribes Overdue Power
Recently proposed regulations on tribal general welfare benefits would grant tribes sole discretion to determine which programs and services are tax-exempt benefits and, if finalized, would fulfill the long-overdue purpose of a 2014 law meant to give them more deference.
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The Tax Angle: Tax Prom, 25 Years Of TIGTA
From a look at the Tax Foundation's 87th annual Tax Prom celebration to the Treasury Inspector General for Tax Administration marking 25 years in operation, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
Expert Analysis
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What Higher Education Can Expect From A 2nd Trump Admin
The election of Donald Trump for a second presidential term has far-reaching ramifications for colleges and universities — come January, institutions can expect a crackdown on DEI, increased scrutiny of campus protests, a rollback of the Biden administration's Title IX rules and more, say attorneys at Jenner & Block.
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3 Ways To Train Junior Lawyers In 30 Minutes Or Less
Today’s junior lawyers are experiencing a skills gap due to pandemic-era disruptions, but firms can help bring them up to speed by offering high-impact skill building content in bite-sized, interactive training sessions, say Stacey Schwartz at Katten, Diane Costigan at Winston & Strawn and Lauren Tierney at Freshfields.
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Expect Surging Oil And Gas Industry Under New Trump Admin
Throughout his recent campaign, President-elect Donald Trump promised increased oil and natural gas production and reduced reliance on renewables — and his administration will likely bring more oil and gas dealmaking, faster federal permitting and attempts to roll back incentives for green energy, say attorneys at Sidley.
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The Bar Needs More Clarity On The Discovery Objection Rule
Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.
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Cos. Should Inventory Issues To Prep For New Congress
As the legislative and oversight agendas of the 119th Congress come into sharper focus, corporate counsel should assess and plan for areas of potential oversight risk — from tax policy changes to supply chain integrity — even as much uncertainty remains, say attorneys at WilmerHale.
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Conservation Easement Cases Weave Web Of Uncertainty
Much of the IRS and Justice Department’s recent success in prosecuting syndicated conservation easement cases can be attributed to the government’s focus on the so-called PropCo ratio, which could indicate treacherous waters ahead for participants and their advisers, even under the incoming Trump administration, say attorneys at Polsinelli.
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So You Want To Move Your Law Practice To Canada, Eh?
Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.
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Legislation Most Likely To Pass In Lame Duck Session
As Congress begins its five-week post-election lame duck session, attorneys at Greenberg Traurig break down the legislative priorities and which proposals can be expected to pass.
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What Trump's 2nd Presidency Could Mean For Crypto Sector
Trump's second term will bring a fundamental shift from the Biden administration's approach to crypto-asset regulation and banking supervision, with the most significant changes likely taking effect in the first two quarters of 2025 and broader policy shifts emerging over the next year, say attorneys at Cahill.
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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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Takeaways From The IRS' Crypto Doc Summons Win
A recent First Circuit decision holding that taxpayers do not have a Fourth Amendment reasonable expectation of privacy in cryptocurrency transaction records should prompt both taxpayers and exchanges to take stock of past transactions and future plans, say attorneys at BakerHostetler.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.