Federal

  • 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

    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

    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

    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

    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.

  • July 19, 2024

    Taxation With Representation: A&O Shearman, Gibson Dunn

    In this week's Taxation With Representation, Cleveland-Cliffs Inc. buys Stelco Holdings Inc., KBR acquires LinQuest Corp., Blue Owl Capital Inc. purchases Atalaya Capital Management LP, and Amphenol Corp. buys two mobile networks units from CommScope.

  • July 19, 2024

    Chippewa Lawyer Not Exempt From Taxes, 8th Circ. Says

    The Eighth Circuit said Friday that an attorney who belongs to the Minnesota Chippewa Tribe is not exempt from federal taxes on his self-employment income, saying no treaty or statute specifically allows Native Americans to skirt the tax.

  • July 19, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included the finalized rules that curb the conservation easement tax deduction claimed by certain partnerships.

  • July 18, 2024

    Hunter Biden Wants Charges Tossed After Trump Docs Ruling

    Hunter Biden on Thursday asked federal judges in Delaware and California to throw out his conviction on felony gun charges and to toss other charges of tax evasion, citing a Florida federal judge's order disqualifying the special prosecutor in Donald Trump's classified documents case.

  • July 18, 2024

    Treasury Starting To Address Amount B, Official Says

    The U.S. Department of the Treasury is just starting to decide how to handle a transfer pricing regime under a prong of the OECD-led global tax overhaul, a Treasury official said Thursday.

  • July 18, 2024

    Bank Exec's Tax Tip Case Wrongly Axed, Estate Tells DC Circ.

    The estate of a Dutch bank executive asked the D.C. Circuit to overturn a U.S. Tax Court decision denying him a whistleblower award for reporting on tax avoidance schemes, saying the lower court improperly relied on proposed regulations from the Internal Revenue Service.

  • July 18, 2024

    New IRS Easement Settlements Put Tax Pros In A Pickle

    The IRS' new settlement program for partnerships that participated in conservation easements that haven't yet ended up in court comes with terms far sweeter than past offers, making it difficult for practitioners to advise clients to take the deal or wait for a better one.

  • July 18, 2024

    Tax Pros Say Gov'ts Stretching 'Realistic Alternative' Analysis

    Tax authorities including the Internal Revenue Service are overstepping in their use of "realistic alternative" arguments, substituting their own judgment for that of businesses, transfer pricing specialists said Thursday.

  • July 18, 2024

    Tax Court Affirms IRS Whistleblower Award Computation

    The Internal Revenue Service's Whistleblower Office did not abuse its discretion when it set an award at 22% of collected proceeds even though other awards tied to related claims were set at 30%, the U.S. Tax Court said Thursday.

Featured Stories

  • 3 Policies Tax Pros Want Congress To Pass This Year

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    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.

  • New IRS Easement Settlements Put Tax Pros In A Pickle

    Kat Lucero

    The IRS' new settlement program for partnerships that participated in conservation easements that haven't yet ended up in court comes with terms far sweeter than past offers, making it difficult for practitioners to advise clients to take the deal or wait for a better one.

  • Top International Tax Cases To Watch In The 2nd Half Of 2024

    Natalie Olivo

    Tax attorneys will be tracking several high-stakes cases in the second half of 2024 that could define the bounds of the IRS' ability to craft regulations or lodge direct challenges aimed at what it sees as the tax avoidance maneuvers of multinational corporations. Here, Law360 looks at key international tax cases to follow during the rest of the year.

Expert Analysis

  • Lead Like 'Ted Lasso' By Embracing Cognitive Diversity

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    The Apple TV+ series “Ted Lasso” aptly illustrates how embracing cognitive diversity can be a winning strategy for teams, providing a useful lesson for law firms, which can benefit significantly from fresh, diverse perspectives and collaborative problem-solving, says Paul Manuele at PR Manuele Consulting.

  • Class Actions At The Circuit Courts: July Lessons

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    In this month's review of class action appeals, Mitchell Engel at Shook Hardy considers cases touching on pre- and post-conviction detainment conditions, communications with class representatives, when the American Pipe tolling doctrine stops applying to modified classes, and more.

  • Now More Than Ever, Lawyers Must Exhibit Professionalism

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    As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.

  • Reading Between The Lines Of Justices' Moore Ruling

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    The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.

  • A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates

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    Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.

  • States Should Loosen Law Firm Ownership Restrictions

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    Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.

  • After Chevron: Uniform Tax Law Interpretation Not Guaranteed

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    The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.

  • Texas Ethics Opinion Flags Hazards Of Unauthorized Practice

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    The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • How High Court Approached Time Limit On Reg Challenges

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    The U.S. Supreme Court's decision in Corner Post v. Federal Reserve Board effectively gives new entities their own personal statute of limitations to challenge rules and regulations, and Justice Brett Kavanaugh's concurrence may portend the court's view that those entities do not need to be directly regulated, say attorneys at Snell & Wilmer.

  • How To Clean Up Your Generative AI-Produced Legal Drafts

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    As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.

  • A Tale Of 2 Trump Cases: The Rule Of Law Is A Live Issue

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    The U.S. Supreme Court’s decision this week in Trump v. U.S., holding that former President Donald Trump has broad immunity from prosecution, undercuts the rule of law, while the former president’s New York hush money conviction vindicates it in eight key ways, says David Postel at Henein Hutchison.

  • Industry Self-Regulation Will Shine Post-Chevron

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    The U.S. Supreme Court's Loper decision will shape the contours of industry self-regulation in the years to come, providing opportunities for this often-misunderstood practice, says Eric Reicin at BBB National Programs.

  • 3 Ways Agencies Will Keep Making Law After Chevron

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    The U.S. Supreme Court clearly thinks it has done something big in overturning the Chevron precedent that had given deference to agencies' statutory interpretations, but regulated parties have to consider how agencies retain significant power to shape the law and its meaning, say attorneys at K&L Gates.