Federal
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October 24, 2024
Mining Eligible In Final Regs For Energy Manufacturing Credit
The U.S. Treasury Department's final rules released Thursday on a valuable tax credit for manufacturing key components and materials used in clean energy technologies allow producers to take into account the costs to mine and extract critical minerals.
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October 23, 2024
IRS To Split Pass-Through, Energy Credit Work Into 2 Units
The IRS is planning to split up its Pass-Throughs and Special Industries office into two separate divisions, including one that will focus in part on energy credits enacted under the 2022 landmark climate law, an agency official said Wednesday.
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October 23, 2024
Tax Court Says Trucker Can't Deduct Reimbursed Expenses
The Internal Revenue Service correctly disallowed a Georgia truck driver's unreimbursed business expense deduction claims, because he was in fact reimbursed for the various expenses, the U.S. Tax Court said Wednesday.
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October 23, 2024
Microsemi's Fines Mostly Adhered To Rules, Tax Court Says
The Internal Revenue Service obtained the proper written approval of penalties on most of the tax code violations it brought against semiconductor manufacturer Microsemi but left room for doubt on two penalties, the U.S. Tax Court said.
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October 23, 2024
Foley & Lardner Adds Burr & Forman Corporate Duo In Fla.
Foley & Lardner LLP has ramped up its innovative technology sector and transactions practice group with two former Burr & Forman LLP partners in Jacksonville, Florida, where a Foley & Lardner leader said their arrival aligned with the firm's strategic focus on four key sectors of the economy.
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October 23, 2024
9th Circ. Orders Michael Avenatti To Be Resentenced
The Ninth Circuit on Wednesday ordered the resentencing of Michael Avenatti over his California conviction for tax violations and stealing from clients, saying the lower court made multiple mistakes when it handed down a 14-year prison term to the onetime celebrity attorney.
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October 23, 2024
CPAs Prepare For Uncertainty As TCJA Expiration Looms
Certified public accountants and financial planners are preparing to help their clients navigate the uncertainty around next year's expiration of major parts of the Tax Cuts and Jobs Act as lawmakers gear up to decide who will bear the brunt of any resulting tax changes.
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October 23, 2024
ABA Tax Section Pushes IRS To Narrow Pillar 2 Regulations
Proposed regulations outlining when foreign taxes under the Pillar Two international minimum tax agreement trigger U.S. rules against benefiting twice from the same economic loss should be narrowed to limit their applicability, the American Bar Association Tax Section told the IRS.
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October 23, 2024
IRS Grants Tax-Exempt Entities Relief From Corp. AMT Filing
Tax-exempt entities are not obligated to file the corporate alternative minimum tax form for the 2023 tax year with the Internal Revenue Service, but they should still maintain the document for recordkeeping purposes, the agency announced Wednesday.
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October 23, 2024
Judge Threatens To Toss Gov't's $4.9M Son-Of-Boss Claim
A federal judge warned government attorneys Wednesday that she would dismiss their case against an estate for $4.9 million in taxes if they didn't explain why they weren't actively pursuing their accusations that a Michigan couple schemed to artificially cancel out capital gains
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October 23, 2024
MVP: Sullivan & Cromwell's Eric Wang
Sullivan & Cromwell's S. Eric Wang advised clients on the tax law implications of major deals over the past year, including a transaction that created the largest gas utility company in North America, earning him a spot as one of the 2024 Law360 2024 Tax MVPs.
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October 23, 2024
IRS Schedules Electronic Tax Committee Meeting For Nov.
The Internal Revenue Service's Electronic Tax Administration Advisory Committee will hold its next meeting Nov. 14, the agency said Wednesday.
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October 22, 2024
FTC On Cusp Of H&R Block False Ad Settlement
The Federal Trade Commission has come to an agreement with H&R Block to settle claims of deceptive advertising and has withdrawn its complaint in order for the full commission to vote on the deal.
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October 22, 2024
8th Circ. Judge Presses IRS On 3M Transfer Pricing Tax Ruling
An Eighth Circuit judge cast doubt during oral arguments Tuesday on the government's interpretation of regulations the IRS relied on to reallocate almost $24 million of income to 3M from its Brazilian affiliate that was subject to legal restrictions on royalty payments.
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October 22, 2024
New IRS Unit Starts Work On Pass-Through Compliance
A new Internal Revenue Service unit focused on the compliance of pass-through entities of all sizes and forms, such as partnerships, S corporations and trusts, has officially started work, the agency said Tuesday.
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October 22, 2024
Cannabis Cos. Need Guidance For Rescheduling, CPAs Say
The Internal Revenue Service and U.S. Treasury Department should preemptively issue guidance covering the tax implications of the proposed rescheduling of marijuana in order to make sure affected businesses are prepared for the changes, the American Institute of Certified Public Accountants said.
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October 22, 2024
Wash. Man Must Pay $43K Tax Bill, Court Affirms
A Washington state resident failed to provide any evidence counter to the Internal Revenue Service's determination that he owed over $43,000 in unpaid taxes and penalties, the U.S. Tax Court said Tuesday, upholding the agency's findings.
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October 22, 2024
Tax Court Says It Can't Rule On FBAR Challenge
The U.S. Tax Court said Tuesday that it lacks the authority to rule on a couple's claim that the Internal Revenue Service wrongly denied them a chance to challenge penalties for failing to report their foreign bank accounts.
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October 22, 2024
Wafer Factories Qualify For CHIPS Tax Credit In Final Regs
Semiconductor wafer production facilities will qualify for the 25% investment tax credit that incentivizes advanced chip manufacturing development projects under final regulations the U.S. Department of the Treasury released Tuesday.
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October 22, 2024
IRS Working On Proposed Spinoff Rules, Agency Official Says
The Internal Revenue Service is planning to propose regulations that may amend positions in an existing revenue procedure that narrowed the range of spinoff transactions the agency will approve as tax-free ahead of time, an IRS official said Tuesday.
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October 22, 2024
Winston & Strawn Boosts Transactions Team With NY Tax Atty
As Winston & Strawn LLP continues to build out its transactions team, the firm has hired a new attorney from Hunton Andrews Kurth LLP with a focus on the tax aspects of real estate financing.
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October 22, 2024
Madigan Ally's Favors Were '100% Legal,' Not Bribes, Jury Told
Counsel for an ex-lobbyist standing trial on public corruption charges alongside former Illinois House Speaker Michael Madigan told an Illinois federal jury Tuesday that the government is treating legal lobbying activity as bribery, and that his client did "100% legal favors" for Madigan to establish trust and maintain access to the powerful politician.
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October 22, 2024
Standard Deduction To Get $400 Bump For 2025 Tax Year
The standard deduction will rise by $400, to $15,000, for individuals and married couples filing separately for the 2025 tax year, the IRS said Tuesday in announcing inflation adjustments to over 60 tax provisions.
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October 22, 2024
9th Circ. Asked To Revive $13M Bad Debt Deduction
The U.S. Tax Court wrongly barred a business owner from taking a $13 million bad debt deduction for loans he made to his companies, he told the Ninth Circuit, saying the lower court treated the debt inconsistently.
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October 22, 2024
The 2024 Prestige Leaders
Check out our Prestige Leaders ranking, analysis and interactive graphics to see which firms stand out for their financial performance, attractiveness to attorneys and law students, ability to secure accolades and positive legal news media representation.
Expert Analysis
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.
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IRS Sings New Tune: Whistleblower Form Update Is Welcome
In a significant reform at the Internal Revenue Service's Whistleblower Office, the recently introduced revisions to the Form 211 whistleblower award application use new technology and a more intuitive approach to streamline the process of reporting allegations of tax fraud committed by wealthy individuals and companies, says Benjamin Calitri at Kohn Kohn.
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This Earth Day, Consider How Your Firm Can Go Greener
As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.
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Energy Community Tax Credit Boost Will Benefit Wind Sector
Recent Internal Revenue Service guidance broadening tax credit eligibility to more parts of offshore wind facilities in so-called energy communities is a win for the industry, which stands to see more projects qualify for a particularly valuable bonus in the investment tax credit context due to the capital-intensive nature of offshore wind projects, say attorneys at Troutman Pepper.
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Weisselberg's Perjury At Trial Spotlights Atty Ethics Issues
Former Trump Organization executive Allen Weisselberg’s recent guilty plea for perjury in the New York attorney general's civil fraud trial should serve as a reminder to attorneys of their ethical duties when they know a client has lied or plans to lie in court, and the potential penalties for not fulfilling those obligations, say Hilary Gerzhoy and Julienne Pasichow at HWG.
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Practicing Law With Parkinson's Disease
This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.
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Why Supreme Court Should Allow Repatriation Tax To Stand
If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.
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For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill
A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.
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Trump's NY Civil Fraud Trial Spotlights Long-Criticized Law
A New York court’s recent decision holding former President Donald Trump liable for fraud brought old criticisms of the state law used against him back into the limelight — including its strikingly broad scope and its major departures from the traditional elements of common law fraud, say Mark Kelley and Lois Ahn at MoloLamken.
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Requiring Leave To File Amicus Briefs Is A Bad Idea
A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.
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4 Ways To Motivate Junior Attorneys To Bring Their Best
As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.
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How IRA Unlocks Green Energy Investments For Tribes
An Inflation Reduction Act provision going into effect May 10 represents a critical juncture for Native American tribes, offering promising economic opportunity in green energy investment, but requiring a proactive and informed approach when taking advantage of newly available tax incentives, say attorneys at Lewis Brisbois.