Federal

  • July 17, 2024

    Tax Court Nixes $22.6M Deduction For Historic Renovation

    The U.S. Tax Court denied Wednesday a $22.6 million deduction to a partnership for a conservation easement on its 11-story historic building in downtown Cleveland, saying the easement did not prevent the scale of development on the property that the partnership had claimed.

  • July 17, 2024

    Tax Court Says IRA Deduction Claim Correctly Rejected

    The Internal Revenue Service correctly disallowed a New Hampshire couple's claimed individual retirement account deduction because they never actually made a contribution to such an account, the U.S. Tax Court said Wednesday.

  • July 17, 2024

    Gov't Views On OECD Risk Guidance Vary, Economists Say

    In allocating risk among different components of a business for transfer pricing purposes, analysts need to consider governments' varying interpretations of guidance from the Organization for Economic Cooperation and Development, a panel of economists said Wednesday.

  • July 17, 2024

    Connell Foley Adds Wilson Elser Tax Pro In Group Upgrade

    Connell Foley LLP strengthened its tax and estate team this week with the promotion of several attorneys up to partner and the addition of a mergers and acquisitions and corporate restructuring tax expert previously of counsel at Wilson Elser Moskowitz Edelman & Dicker LLP.

  • July 17, 2024

    The Tax Angle: Child Care, Medical Debt, Small Biz Relief

    As talks take place on Capitol Hill over the impact the expiration of the Tax Cuts and Jobs Act will have on small businesses and child care, here's a peek into a reporter's notebook on a few developing tax stories.

  • July 17, 2024

    IRS Plans August Hearing On Stock Buyback Tax Rules

    The Internal Revenue Service will hold a public hearing Aug. 27 on proposed regulations governing a new excise tax on repurchases of corporate stock, the agency said Wednesday.

  • July 17, 2024

    IRS Issues Fixes For Clean Electricity Credit Regs

    The Internal Revenue Service issued corrections Wednesday that it said fix a number of errors in proposed regulations concerning the clean electricity production and investment tax credits established by the Inflation Reduction Act.

  • July 17, 2024

    Treasury Finalizes Rules To Target 'Killer B' Transactions

    The U.S. Treasury Department published final regulations Wednesday aimed at so-called Killer B transactions, which involve certain corporate reorganizations with at least one foreign affiliate that ultimately allow U.S. companies to avoid domestic taxes.

  • July 17, 2024

    Rising Star: Cravath's Kiran Sheffrin

    Kiran Sheffrin of Cravath Swaine & Moore LLP has advised companies from Anheuser-Busch InBev to Valvoline on multibillion-dollar deals, including a $50 billion combination resulting in the formation of pharmaceutical giant Viatris, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 17, 2024

    Woman Can't Escape Suit Over Partner's $1.1M FBAR Debt

    A woman whose late romantic partner owed $1.1 million in reporting penalties on hidden financial accounts in France and Switzerland can't stop the government from pursuing a suit against her for half the value of her home, a New York federal court ruled.

  • July 17, 2024

    Baker McKenzie Adds EY Partner To Mexico City Office

    Baker McKenzie has appointed a new partner from EY Mexico to its North American tax practice group in Mexico City.

  • July 16, 2024

    Intracompany Prices Should Reflect Acquired IP, Panelists Say

    When one company buys another for its intellectual property, the subsequent pricing of that asset between the now-related entities should reflect the value of what was acquired, transfer pricing specialists said Tuesday at a conference in Washington, D.C.

  • July 16, 2024

    More Geographic Adjustments 'On The Table' For Amount B

    Countries' ability to make further adjustments for geographic differences in the streamlined transfer pricing approach known as Amount B — part of the OECD's plan for reallocating taxing rights among jurisdictions — is "still on the table," an official from the organization said Tuesday.

  • July 16, 2024

    Tycoon's Pilot Says Feds' Stock Tip Claims Don't Add Up

    A private pilot who used to work for convicted insider trader and U.K. billionaire Joe Lewis is arguing federal prosecutors can't use allegations that his own trades were suspicious to ramp up a sentence for a separate tax evasion charge.

  • July 16, 2024

    7th Circ. Says Foreign Retirement Not Shielded In Bankruptcy

    A professor who filed for bankruptcy in Illinois can't protect his Canadian retirement account from creditors because the account is ineligible under a state law shielding accounts that qualify as retirement plans under the Internal Revenue Code, the Seventh Circuit ruled Tuesday.

  • July 16, 2024

    Tax Court Grants Installment Gain Recognition On Stock Sales

    The U.S. Tax Court rejected Tuesday a claim by the IRS that a man and his cousin who had each sold stock in 2002 to an employee stock ownership trust for more than $4 million had to recognize the entirety of their deferred gain the following year.

  • July 16, 2024

    Connecticut Contractor Fined $1.75M For Tax Evasion

    A Connecticut contractor was ordered to pay a $1.75 million fine for evading federal corporate and individual income taxes from 2006 through 2010, the U.S. Department of Justice announced Tuesday.

  • July 16, 2024

    DC Circ. Upholds Dismissal Of Tax Whistleblower Award Case

    The D.C. Circuit upheld Tuesday the U.S. Tax Court's dismissal of a Mississippi man's case seeking review of the denial of his whistleblower claim for 30% of the revenue collected by an Internal Revenue Service offshore voluntary disclosure program.

  • July 16, 2024

    Tax Court Says Deductions Properly Disallowed By IRS

    A New York couple was properly denied tens of thousands of dollars worth of deductions on their federal income taxes by the Internal Revenue Service, since the pair neither qualified nor adequately substantiated their claims, the U.S. Tax Court said Tuesday.

  • July 16, 2024

    Contractor Asks Justices To Review $1.3M R&D Credit Suit

    A construction company's shareholders asked the U.S. Supreme Court to review a decision revoking their tax refund for the company's $1.3 million in claimed research credits, saying the Fifth Circuit wrongly deferred to the Internal Revenue Service in stopping their case from going to trial.

  • July 16, 2024

    Rising Star: Skadden's Melinda Gammello

    Melinda Gammello of Skadden Arps Slate Meagher & Flom LLP has advised numerous clients before the U.S. Tax Court and elsewhere on complex tax matters, including transfer pricing issues and the treatment of financial transactions within a company, earning her a spot among the tax law practitioners under 40 honored by Law360 as Rising Stars.

  • July 16, 2024

    The 2024 Diversity Snapshot: What You Need To Know

    Law firms' ongoing initiatives to address diversity challenges have driven another year of progress, with the representation of minority attorneys continuing to improve across the board, albeit at a slower pace than in previous years. Here's our data dive into minority representation at law firms in 2023.

  • July 16, 2024

    These Firms Have The Most Diverse Equity Partnerships

    Law360’s law firm survey shows that firms' efforts to diversify their equity partner ranks are lagging. But some have embraced a broader talent pool at the equity partner level. Here are the ones that stood out.

  • July 16, 2024

    Applicable Federal Interest Rates To Drop In August

    Applicable federal rates for income tax purposes will decrease in August, the Internal Revenue Service said Tuesday, the second month-to-month drop in a row.

  • July 16, 2024

    3 Tax Reg Groups That May Be Shaky After High Court Rulings

    The U.S. Supreme Court issued two rulings that, when combined, open up long-standing federal regulations to challenges without judicial deference to agencies — a pairing that could weaken several categories of tax rules, including guidance issued under the 2017 federal overhaul. Here, Law360 looks at three batches of tax regulations that may be vulnerable in the aftermath of the high court's decisions.

Expert Analysis

  • 10 Considerations For Litigating A New York Tax Case

    Author Photo

    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Charting The Course For Digital Assets In 2024

    Author Photo

    Although 2023 was a tough year for the digital asset industry, upcoming court decisions, legislation and regulatory action will bring clarity, allowing the industry to expand and evolve, and the government will decide what innovation it will allow without challenge, says Joshua Smeltzer at Gray Reed.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

    Author Photo

    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

    Author Photo

    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

    Author Photo

    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • Giving The Gov't Drug Patent March-In Authority Is Bad Policy

    Author Photo

    The Biden administration's recent proposal to allow government seizure of certain taxpayer-funded drug patents is a terrible idea that would negate the benefits of government-funded research, to the detriment of patients and the wider economy, says Wayne Winegarden at Pacific Research Institute.

  • How Clients May Use AI To Monitor Attorneys

    Excerpt from Practical Guidance
    Author Photo

    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

    Author Photo

    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • How 'As Such' Changes LPs' Self-Employment Tax Exposure

    Author Photo

    In light of the U.S. Tax Court’s recent Soroban Capital Partners decision hinging on "as such" to define the statutory limited partners exemption, state law limited partnerships should consider partners' roles and responsibilities before determining whether they are obligated to pay self-employment income tax, say attorneys at Morgan Lewis.

  • Breaking Down High Court's New Code Of Conduct

    Author Photo

    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • IRA Monetization Energizes Clean Power Tax Credit Market

    Author Photo

    Recent large sales of clean energy production tax credits reflect an environment in which the Inflation Reduction Act's provisions for monetizing such credits via direct transfer — bypassing slow, costly tax equity transactions — offer opportunities for both developers and investors, says Andrew Eastman at Husch Blackwell.

  • Legal Profession Gender Parity Requires Equal Parental Leave

    Author Photo

    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • Unpacking Long-Awaited Clean Energy Tax Credit Guidance

    Author Photo

    Recently proposed Internal Revenue Service regulations provide welcome confirmatory guidance on the application of investment tax credits as reworked by 2022's Inflation Reduction Act, prevailing wage and apprenticeship rules that are largely consistent with market expectations, and broader eligibility criteria that should please the wind power industry in particular, say attorneys at Morgan Lewis.

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