Federal
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November 22, 2024
IRS Extends Domestic Content Relief For Energy Credits
Nonprofits, tribal governments, public utilities and other tax-exempt groups eligible for a direct cash payment of their clean energy tax credits can get relief from meeting the domestic content requirements tied to those incentives for 2025 and 2026 under IRS guidance released Friday.
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November 22, 2024
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.
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November 22, 2024
IRS To Send Out Benefit Plan Opinions This Month
The Internal Revenue Service plans to issue opinion letters this month on preapproved defined benefit plans modified and submitted to the IRS during the second remedial amendment cycle, the agency said Friday.
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November 22, 2024
High Court To Review Legality Of FCC's Subsidy Fees
The U.S. Supreme Court agreed Friday to review whether fees collected to support the Federal Communications Commission's array of telecom subsidy programs for low-income consumers, schools and rural healthcare run afoul of constitutional limits on taxing authority.
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November 22, 2024
Vitamin Co. Must Freeze Owner Payouts Amid $1.4M Tax Fight
A Connecticut federal judge has granted the federal government a temporary restraining order in a $1.4 million tax fight with a vitamin company, barring distributions to the owners unless the company allocates 20% to the court's registry to help cover the potential liability.
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November 22, 2024
IRS Ignores Text In $248M Fight, Liberty Global Tells 10th Circ.
The Internal Revenue Service is incorrectly applying the U.S. tax code in denying Liberty Global's claim for $248 million in foreign tax credits tied to its sale of a Japanese affiliate, the telecommunications company told the Tenth Circuit.
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November 22, 2024
Halliburton Omitted Grounds From $35M Refund Suit, US Says
A Texas federal court must dismiss parts of Halliburton's $35 million tax refund lawsuit because the company failed to raise two grounds of relief in its administrative claim for a refund, the U.S. argued.
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November 22, 2024
Taxation With Representation: Stradley Ronon, Davis Polk
In this week's Taxation With Representation, Amcor PLC buys Berry Global Group Inc., AeroVironment buys BlueHalo, Robinhood Markets Inc. acquires TradePMR, and Comcast Corp. spins off a suite of NBCUniversal cable television networks.
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November 22, 2024
Railroad Worker Tax Rates Won't Change For 2025
Tier 2 tax rates for railroad employees, employers and employee representatives in 2025 will remain unchanged, according to an Internal Revenue Service announcement Friday.
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November 22, 2024
IRS Corrects Advanced Manufacturing Credit Regs
The Internal Revenue Service released a correction notice Friday fixing a dozen errors in the final regulations implementing the advanced manufacturing investment credit rules and special 10-year credit recapture rule.
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November 22, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, featured finalized rules meant to modernize regulations governing the seizure of property by levy.
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November 22, 2024
Ex-Invenergy Atty Joins McDermott's Energy Team In DC
McDermott Will & Emery LLP announced Friday its Washington, D.C., office has brought on an in-house renewable energy and taxation expert with more than a decade of experience to further help the firm's clients utilize energy transition tax credits available in the Inflation Reduction Act.
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November 21, 2024
Tax Firm Must Disclose Case Info In Malpractice Suit
A tax firm being sued for malpractice and unfair trade practices by former clients can't hide behind a state bar association rule to avoid producing discovery documents it claims are privileged, a Wisconsin federal court ruled Thursday.
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November 21, 2024
22M Tax Returns Used Refund-Related Products, TIGTA Says
Nearly 22 million tax returns for 2023, or 16% of all returns, made use of what are known as refund-related products that either provide loans or help pay for tax preparation fees, the Treasury Inspector General for Tax Administration said Thursday.
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November 21, 2024
IRS Updates Dependent Claiming Rules To Speed Up Refunds
Starting in 2025, the Internal Revenue Service will accept e-filed returns that claim dependents that were already claimed on another taxpayer's return so long as the primary taxpayer on the second return includes a valid Identity Protection Personal Identification Number, the agency said Thursday.
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November 21, 2024
Delayed Tax Deadline For Hostages Bill Clears House
Tax deadlines would be delayed and late fees reimbursed for Americans held hostage or wrongfully detained abroad under legislation passed Thursday by the House after it rejected an attempt last week to fast-track the proposal.
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November 21, 2024
Ga. Attys' Easement Fraud Class Suit Shipped To State Court
A Georgia federal judge kicked back to state court a proposed class action accusing conservation easement fund organizers of racketeering and defrauding investors, saying the organizers failed to prove that the proposed class had at least 100 investors or that the case hinged on federal law.
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November 21, 2024
Israel-Hamas War Tax Relief Needed More Notice, TIGTA Says
While the Internal Revenue Service did well to proactively identify taxpayers likely affected by the Israel-Hamas war that it sought to grant tax relief, it failed to directly notify these taxpayers, the Treasury Inspector General for Tax Administration said Thursday.
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November 21, 2024
11th Circ. Asked To Rethink $100M Credit For John Hancock
The Eleventh Circuit should reverse its decision allowing John Hancock Life Insurance Co. to keep $100 million in foreign tax credits that rightfully belong to the company's investors, trustees of a retirement plan said in arguing that the court overlooked a key U.S. Treasury regulation.
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November 20, 2024
Fla. Couple Ask To Revive Suit Over Unclaimed Property
A Florida couple asked the Eleventh Circuit Wednesday to revive their proposed class suit against the state's chief financial officer over a law that allows officials to hold unclaimed money indefinitely, arguing that it is a taking without just compensation because the state never pays interest on the amount held.
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November 20, 2024
DC Circ. Upholds Taxes For Couple Lacking IRS Notice
A Georgia couple whose challenge of a 2019 tax collection was dismissed by the U.S. Tax Court when they failed to present the required IRS notice of deficiency were similarly turned away by the D.C. Circuit on Wednesday.
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November 20, 2024
Fla. Tax Preparer Gets 4 Years For Tax Fraud Scheme
A barred Florida tax preparer was sentenced to four years in prison for falsifying returns to trigger inflated refunds for participants in a three-year tax fraud scheme called the "note program," the U.S. Department of Justice said Wednesday.
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November 20, 2024
Feds Want 1 Year In Prison For Accountant Who Hid $1.4M
An accountant who hid $1.4 million from the IRS should be sentenced to at least a year in prison despite his stated mental health issues, the government told a Connecticut federal court, saying he seemed driven at least partly by greed and thought he wouldn't get caught.
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November 20, 2024
Feds Again Seek Early Win In $11.6M Willful FBAR Dispute
The U.S. government intends to renew its request to resolve a narrow matter in a dispute with an international businessman facing an $11.6 million penalty for willful failure to report his foreign bank accounts before the case heads to trial, according to a filing in Hawaii federal court.
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November 20, 2024
11th Circ. Skeptical Couple Can Skip Tax On Stolen Funds
Eleventh Circuit judges seemed unconvinced by a couple's request to overturn a decision that they owed taxes on $1.2 million in savings that their daughter swindled from them, saying during oral arguments Wednesday that their situation, however sympathetic, does not appear to warrant tax relief.
Trump Taps Hedge Fund Billionaire Bessent To Head Treasury
President-elect Donald Trump on Friday announced that he's selected Scott Bessent, a billionaire hedge fund manager and the founder of Key Square Group, to serve as secretary of the Treasury in his upcoming administration.
IRS Working To Incorporate Feedback On Donor Fund Regs
The Internal Revenue Service continues to work on final rules for the donor-advised fund excise tax and is taking into account public comments on its proposed rules, such as concerns that the definition of donor-advised funds is too broad, an agency official said Friday.
Hype For Energy Tax Perks Could Shield Regs From Repeal
President-elect Donald Trump and Republican lawmakers could turn to an oversight tool called the Congressional Review Act to undermine clean energy tax credit regulations implementing key parts of Democrats' signature climate law, but the strategy may falter due to GOP support for the incentives.
Featured Stories
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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.
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Hype For Energy Tax Perks Could Shield Regs From Repeal
President-elect Donald Trump and Republican lawmakers could turn to an oversight tool called the Congressional Review Act to undermine clean energy tax credit regulations implementing key parts of Democrats' signature climate law, but the strategy may falter due to GOP support for the incentives.
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Countries Eye Certain Tax Credits To Get Leg Up Under Pillar 2
The international minimum tax agreement known as Pillar Two is changing how countries compete for corporate investment, in part by prompting some governments to retool their tax credit systems in ways that could edge out jurisdictions with fewer resources.
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.