Federal
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October 15, 2024
Alvarez & Marsal Tax Brings On Restructuring Leader
Alvarez & Marsal's tax affiliate added a restructuring professional from investment bank Houlihan Lokey to serve as its head of global restructuring tax services.
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October 15, 2024
V&E Adds Energy Tax Pro From Bracewell In Houston
Vinson & Elkins LLP has bolstered its energy transition and tax practices with a partner in Houston who came aboard from Bracewell LLP and whose background includes substantial in-house experience advising on renewable projects.
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October 15, 2024
Law Firms Diverge As Anti-ESG Pushback Continues
A continuing onslaught of legislation and litigation opposing corporate environmental, social and governance actions has created a fork in the road for law firms, with some choosing to scale back efforts and others pushing ahead with their internal ESG and diversity, equity and inclusion goals.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
Expert Analysis
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How Firms Can Ensure Associate Gender Parity Lasts
Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.
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A Proposal For Fairer, More Efficient Innocent Spouse Relief
Adding a simple election to the current regulatory framework for innocent spouse claims would benefit both taxpayers and the Internal Revenue Service by alleviating the undue burdens placed on those the program was intended to help and improving agency collections in such cases, says Laurie Kazenoff at Kazenoff Tax.
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7 Common Myths About Lateral Partner Moves
As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.
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Proposed Hydrogen Tax Credit Regs May Be Legally Flawed
While the recently proposed regulations for the new clean hydrogen production tax credit have been lauded by some in the environmental community, it is unclear whether they are sufficiently grounded in law, result from valid rulemaking processes, or accord with other administrative law principles, say Hunter Johnston and Steven Dixon at Steptoe.
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Navigating ACA Reporting Nuances As Deadlines Loom
Stephanie Lowe at Liebert Cassidy walks employers through need-to-know elements of Affordable Care Act reporting, including two quickly approaching deadlines, the updated affordability threshold, strategies for choosing an affordability safe harbor, and common coding pitfalls.
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6 Pointers For Attys To Build Trust, Credibility On Social Media
In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.
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Why Biz Groups Disagree On Ending Chevron Deference
Two amicus briefs filed in advance of last month's U.S. Supreme Court oral arguments in Loper Bright Enterprises v. Raimondo highlight contrasting views on whether the doctrine of Chevron deference promotes or undermines the stable regulatory environment that businesses require, say Wyatt Kendall and Sydney Brogden at Morris Manning.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.
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A Look Ahead For The Electric Vehicle Charging Industry
This will likely be an eventful year for the electric vehicle market as government efforts to accelerate their adoption inevitably clash with backlash from supporters of the petroleum industry, say Rue Phillips at SkillFusion and Enid Joffe at Green Paradigm Consulting.
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A Post-Mortem Analysis Of Stroock's Demise
After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.
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SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
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Planning A Defense As IRS Kicks Off Sports Losses Campaign
Sports team owners and partnerships face potential examination under the Internal Revenue Service’s recently announced sports industry losses campaign, and should be preparing to explain what drove their reported losses and assembling documentation to support their tax return positions and accounting methods, say Sheri Dillon and Jennifer Breen at Morgan Lewis.
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What New Calif. Strike Force Means For White Collar Crimes
The recently announced Central District of California strike force targeting complex corporate and securities fraud — following the Northern District of California's model — combines experienced prosecutorial leadership and partnerships with federal agencies like the IRS and FBI, and could result in an uptick in the number of cases and speed of proceedings, say attorneys at MoFo.