Federal

  • July 23, 2024

    Cannabis Industry Stakeholders Weigh In On Rescheduling

    As the period for public comment on the Biden administration's proposal to reclassify marijuana came to a close Monday, anti-legalization activists, marijuana industry advocates and state cannabis regulators each submitted their thoughts on the potential policy shift.

  • July 23, 2024

    House Delays Vote On FY25 IRS Budget Legislation

    The House delayed an expected vote Tuesday on the Internal Revenue Service's budget for fiscal 2025, casting doubt on whether GOP lawmakers will meet their goal of passing the funding bill before Congress' annual August recess begins next week.

  • July 23, 2024

    Newell Says IRS Misapplied Pricing Law In $124M Dispute

    Newell Brands told the U.S. Tax Court the Internal Revenue Service misapplied transfer pricing law to levy almost $124 million in additional taxes and penalties.

  • July 23, 2024

    White House Taps VA Official To Helm Tax Watchdog

    President Joe Biden has nominated a U.S. Department of Veterans Affairs investigator to serve as Treasury inspector general for tax administration, the Internal Revenue Service's federal watchdog, the White House announced Tuesday.

  • July 23, 2024

    Feds Urge 6th Circ. To Affirm Pharma Owner's Fraud Sentence

    The Sixth Circuit should affirm a district court's fraud convictions, nearly five-year sentence and $7 million restitution order against an Ohio pharmaceutical salesman who underreported his income to reduce his tax liability in a multimillion-dollar scheme involving bogus insurance billings, the federal government said.

  • July 23, 2024

    Farm Owner Must Boost Taxable Income, 8th Circ. Told

    An Arkansas company that leases farmland must raise its reported income by $230,000 because it failed to get permission from the IRS to change its accounting method, the U.S. told the Eighth Circuit on Tuesday in asking it to uphold a U.S. Tax Court ruling.

  • July 23, 2024

    IRS Notice Signals Direction On Corp. AMT Regs, Official Says

    An Internal Revenue Service notice regarding the U.S. corporate alternative minimum tax can be read as a signal about how the agency will more broadly address the measure's potential for counting offshore income twice, an IRS official said Tuesday.

  • July 23, 2024

    Winston & Strawn Adds MoFo Tax Pro As Partner In NY

    Winston & Strawn LLP has added a transactional tax specialist from Morrison Foerster LLP as a partner with the firm's transactions department and tax practice in New York.

  • July 23, 2024

    Former Doctor To Be Released From Jail In FBAR Fight

    A former doctor will be released from U.S. custody after a Michigan federal court lifted Tuesday an order of civil contempt against him for failure to pay about $1 million in foreign account reporting penalties.

  • July 23, 2024

    Orrick Hires Ex-Winston & Strawn Tax Partner In Chicago

    Orrick Herrington & Sutcliffe LLP announced the hiring of a former partner at Winston & Strawn LLP for its renewables tax equity and tax credit team.

  • July 23, 2024

    11th Circ. Should Uphold Tax Court Protection, IRS Says

    The Eleventh Circuit should uphold a U.S. Tax Court ruling that denied a widow tax relief and also rejected her claim that Tax Court judges have unconstitutional job protection, the Internal Revenue Service told the circuit court.

  • July 23, 2024

    5-Hour Energy Partner Owes No Tax On Sale, DC Circ. Says

    The D.C. Circuit found Tuesday that a Canadian citizen's $6.5 million in gains from her sale of a U.S. partnership interest in a company that sold 5-hour Energy drinks was not federally taxable as inventory income, reversing a U.S. Tax Court ruling.

  • July 23, 2024

    IRS Makes Corrections To 2 Proposed Regulations

    The Internal Revenue Service issued a handful of corrections Tuesday to two notices of proposed rulemaking, one regarding certain partnership related-party basis adjustment transactions and the other interest capitalization requirements for improvements to designated property.

  • July 22, 2024

    3 Policies Tax Pros Want Congress To Pass This Year

    As momentum around the House-passed tax break bill has fizzled and election season ramps up, tax experts hope lawmakers use what little time they have left to extend expired research tax breaks, approve the Taiwanese tax agreement and pass disaster relief before the end of the year. Here are three policy changes tax professionals think Congress should make before the end of the year.

  • July 22, 2024

    CPAs Back Bill To Apply Mailbox Rule To Electronic Returns

    The American Institute of Certified Public Accountants said Monday that it endorsed a congressional proposal that would apply what is known as the mailbox rule to electronically submitted tax returns and shift the deadlines for estimated tax payments to intervals that are actually quarterly.

  • July 22, 2024

    US Treasury Working To Extend Pillar 1 DST Compromise

    As OECD-led negotiations continue on a taxing rights overhaul known as Pillar One after a missed June deadline, the U.S. Treasury Department is working to extend the political agreement between it and several countries to nullify their digital services taxes once the rights overhaul is implemented.

  • July 22, 2024

    Pension Plans Slam Biz Docs In $2B Danish Tax Fraud Case

    Denmark's tax agency has produced experts who are relying on unauthenticated documents in litigation accusing U.S. pension plans of participating in a $2.1 billion fraud scheme, the pension plans claimed in urging a New York federal court to exclude the testimony.

  • July 22, 2024

    11th Circ. Denies Rehearing On Social Security Garnishment

    The Eleventh Circuit on Monday turned down a Florida woman's request to reconsider its rejection of her challenge to the Internal Revenue Service's garnishment of her Social Security payments.

  • July 22, 2024

    Werfel Wants IRS to Help Eligible EITC Nonclaimaints

    The Internal Revenue Service needs to do more to help people who are eligible for the earned income tax credit but don't claim it, Daniel Werfel, the agency's commissioner, said Monday.

  • July 22, 2024

    IRS Delays Tax Deadlines For Texans Affected By Hurricane

    Certain Texas taxpayers affected by Hurricane Beryl, which hit the state this month, will have until a delayed deadline of Feb. 3 to file individual and business tax returns and make payments, the Internal Revenue Service said Monday.

  • July 22, 2024

    Kyocera Failed To Back R&D Credits With Records, US Says

    Multinational electronics maker Kyocera AVX Components Corp. failed to back up its claim to research tax credits with the required paperwork, the U.S. government told a South Carolina federal court in asking it to stop part of the company's nearly $9 million refund suit from going to trial.

  • July 19, 2024

    House Panel To Weigh EV Credit Restrictions, IRS' Use Of AI

    The House Rules Committee will consider amendments Monday to a fiscal 2025 funding bill that would give the IRS $10.1 billion, sorting through divergent priorities of lawmakers from integrating artificial intelligence into agency operations to restricting tax credits for electric vehicles and helping seniors file tax returns.

  • July 19, 2024

    Partnership Protests IRS' Reasons For $84M Deduction Denial

    The Internal Revenue Service wrongly denied a partnership's charitable contribution deduction of nearly $84 million for a donated conservation easement for reasons including the partnership failing to demonstrate it made the contribution, the partnership's representative told the U.S. Tax Court.

  • July 19, 2024

    Cox Owner's Estate Claims IRS Miscalculated $46M Tax Bill

    The estate of an owner of the Cox Enterprises media empire challenged a $46 million tax bill from the Internal Revenue Service, telling the U.S. Tax Court that the agency erroneously calculated the tax by inflating the value of the company's stock by about $20 per share.

  • July 19, 2024

    Attorney Denied Separate Trial In $2.1B Danish Tax Fraud

    An attorney facing trial alongside his clients for alleged ties to a $2.1 billion Danish tax fraud has been denied a separate hearing by a New York federal court, which remained unconvinced that his co-workers' advice to the clients could rebound on him prejudicially in a joint trial.

Expert Analysis

  • How Associates Can Build A Professional Image

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    As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.

  • Navigating New Safe Harbor For Domestic Content Tax Credits

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    The U.S. Department of the Treasury’s recent notice simplifying domestic content calculations for certain solar, onshore wind and battery storage projects, which directly acknowledges the difficulty for taxpayers in gathering data to support a domestic content analysis, should make it easier to qualify additional domestic content bonus tax credits, say attorneys at A&O Shearman.

  • Firms Must Rethink How They Train New Lawyers In AI Age

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    As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.

  • 'Energy Communities' Update May Clarify Tax Credit Eligibility

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    A recent IRS notice that includes updated lists of locations where clean energy projects can qualify for additional tax credits — based 2023 unemployment data and placed-in-service dates — should help provide clarity regarding project eligibility that sponsors and developers need, say attorneys at Troutman Pepper.

  • Think Like A Lawyer: Always Be Closing

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    When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.

  • How Cannabis Rescheduling May Alter Paraphernalia Imports

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    The Biden administration's recent proposal to loosen federal restrictions on marijuana use raises questions about how U.S. Customs and Border Protection enforcement policies may shift when it comes to enforcing a separate federal ban on marijuana accessory imports, says R. Kevin Williams at Clark Hill.

  • NCAA Settlement May End The NIL Model As We Know It

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    The recent House v. NCAA settlement in California federal court, in which the NCAA agreed to allow schools to directly pay March Madness television revenue to their athletes, may send outside name, image and likeness collectives in-house, says Mike Ingersoll at Womble Bond.

  • Fishing Makes Me A Better Lawyer

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    Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.

  • A Healthier Legal Industry Starts With Emotional Intelligence

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    The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.

  • To Make Your Legal Writing Clear, Emulate A Master Chef

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    To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.

  • Circuit Judge Writes An Opinion, AI Helps: What Now?

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    Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.

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