Federal

  • June 28, 2024

    Taxation With Representation: Kirkland, Vinson, Skadden

    In this week's Taxation with Representation, Aareal Bank AG and Advent International sell a property management and maintenance software company, Webtoon Entertainment Inc. and Tamboran Resources Corp. price initial public offerings, SM Energy Company acquires oil and gas assets, and Nokia sells Alcatel Submarine Networks to the French state.

  • June 28, 2024

    Estate Owes $4.9M For Son-Of-Boss Scheme, US Says

    An estate owes $4.9 million in tax liabilities for a couple's scheme to artificially cancel out their capital gains, the federal government said in a complaint in Michigan federal court, arguing that the Son-of-Boss scheme constitutes fraud and its proceeds aren't entitled to bankruptcy protection.

  • June 28, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included an extension of the penalty relief for entities that fail to make estimated quarterly payments of the corporate alternative minimum tax.

  • June 28, 2024

    Supreme Court Strikes Down Chevron Deference

    The U.S. Supreme Court on Friday overturned a decades-old precedent that instructed judges about when they could defer to federal agencies' interpretations of law in rulemaking, depriving courts of a commonly used analytic tool and leaving lots of questions about what comes next.

  • June 27, 2024

    Biden, Trump Spar Over Fate Of 2017 Tax Cuts In 1st Debate

    President Joe Biden and former President Donald Trump debated the GOP's 2017 tax policy overhaul Thursday night, with Trump praising its economic benefits and Biden criticizing the tax cuts for favoring the wealthy and increasing federal deficits.

  • June 27, 2024

    IRS To Offer Combined Filing For Energy Investment Credits

    The Internal Revenue Service will let clean energy project owners that are claiming investment tax credits for more than 200 facilities file the claims with a single form, an agency official said Thursday.

  • June 27, 2024

    Corp. Tax Cuts Worsen Racial, Income Inequality, Report Says

    In the first year of a corporate tax break, white U.S. households receive 88% of the benefits while Black and Hispanic households each receive just 1%, according to a study published Thursday by the Institute on Taxation and Economic Policy and an advocacy organization.

  • June 27, 2024

    TurboTax Maker Wipes Out 2 Of 3 Software Patents At PTAB

    The Patent Trial and Appeal Board delivered a mixed bag of decisions in patent challenges brought by Intuit against a small software outfit that claims to have invented the idea of "co-browsing."

  • June 27, 2024

    High Response To IRS Transfer Pricing Letters, Official Says

    Most taxpayers that received letters from the Internal Revenue Service pursuant to a compliance campaign warning them of a transfer pricing issue have responded, an IRS official said Thursday.

  • June 27, 2024

    Congress Shouldn't Rush OECD Tax Package, Group Says

    Congress should avoid "rubber-stamping" the two pillars of the Organization for Economic Cooperation and Development's plan to fight tax base erosion and profit shifting and instead gather more information on its impact on the U.S., a conservative advocacy group said Thursday.

  • June 27, 2024

    IRS Criminal Chief Says COVID Fraud Work To Hold Steady

    IRS Criminal Investigation agents expect to spend as much time this year on coronavirus assistance policy-related fraud as last year, the division chief said at a conference Thursday.

  • June 27, 2024

    IRS Tells 10th Circ. To Deny Liberty Global's $110M Refund Bid

    The U.S. government urged the Tenth Circuit on Thursday to reject telecommunication giant Liberty Global's push for a $110 million tax refund, arguing a lower court correctly deduced that the company's business restructurings were carried out solely to avoid tax.

  • June 27, 2024

    $2.1B Danish Tax Fraud Suspect Won't Testify, Court Says

    A New York federal court denied dueling requests from U.S. pension plan investors accused of participating in a $2.1 billion Danish tax fraud scheme and from Denmark's tax agency to bring in the man that both sides say masterminded the scheme, or to bring in one of his employees.

  • June 27, 2024

    Ex-Skadden Tax Head And M&A Pro Joins Freshfields In NY

    Freshfields Bruckhaus Deringer LLP has added the former head of the tax practice at Skadden Arps Slate Meagher & Flom LLP as a partner this week, who brings to the role experience in deals like 21st Century Fox's $71 billion acquisition by Disney and the merger of T-Mobile and Sprint.

  • June 27, 2024

    TIGTA Points To Areas Of Improvement For Direct File

    A phase of the Direct File pilot program that allowed eligible IRS employees to get the first crack at the online tax filing service had issues with accuracy of its tax returns and lacked a Spanish translation, the Treasury Inspector General for Tax Administration said Thursday.

  • June 27, 2024

    New FATCA Deal Requires US Banks To Share Info With Swiss

    The United States and Switzerland signed a Foreign Account Tax Compliance Act agreement that will require U.S. banks to share financial account information on a bilateral basis, Switzerland's Federal Department of Finance announced Thursday.

  • June 27, 2024

    IRS Delays Tax Deadlines In Miss. After April Storms

    Certain Mississippi taxpayers affected by storms, tornadoes and flooding that hit the state starting April 8 now have until Nov. 1 to file individual and business tax returns and make payments, the Internal Revenue Service said Thursday.

  • June 26, 2024

    Repatriation Tax Ruling May Sway State Wealth Tax Debates

    The U.S. Supreme Court's upholding of the federal repatriation tax could indirectly affect state tax policy discussions, including by influencing consideration of wealth taxes and encouraging states to keep potential due process issues in mind when enacting tax legislation.

  • June 26, 2024

    Tax Court Says Couple Wrongly Claimed Unsigned Checks

    A Minnesota eye doctor and his wife overstated their income on their joint tax return, as they declared pay that they never actually received from their corporation in the form of unsigned checks, the U.S. Tax Court said in an opinion released Wednesday.

  • June 26, 2024

    IRS To Make Syndicated Easement Settlement Offers

    The Internal Revenue Service will send settlement offers next month to some taxpayers who participated in syndicated conservation easement deals that the agency is auditing, it announced Wednesday.

  • June 26, 2024

    Advice Panel Calls For Regulating Noncredentialed Preparers

    Congress should authorize the Internal Revenue Service to regulate noncredentialed tax preparers to protect taxpayers and the tax system from erroneous returns, the agency's Electronic Tax Administration Advisory Committee said in its annual report to lawmakers Wednesday.

  • June 26, 2024

    9th Circ. Revives $491K Refund Error Recovery Suit

    The Ninth Circuit resurrected Wednesday an IRS suit that seeks to recover more than $491,000 from a taxpayer to whom the agency erroneously mailed a refund, reversing a lower court decision that dismissed the case for falling outside the two-year statute of limitations.

  • June 26, 2024

    5th Circ. Affirms Block On ARPA Tax Rule For Texas, La., Miss.

    A Texas federal judge properly ruled that the federal government could not enforce a provision in the American Rescue Plan Act that prohibits states from using pandemic aid to offset tax cuts, the Fifth Circuit said.

  • June 26, 2024

    Man Denied Tax Breaks For Kids Who Didn't Live With Him

    A Minnesotan does not qualify for tax exemptions or credits related to his three children because they did not live with him for at least half of the relevant tax year, the U.S. Tax Court said in an opinion released Wednesday.

  • June 26, 2024

    Device Maker To Fork Over $3.5M In Tax Dodge Suit

    A man who manufactured a purported health device will pay the IRS nearly $3.5 million under an agreement endorsed by a Florida federal court after the agency claimed he hadn't filed a tax return since 1999.

Expert Analysis

  • A Look Ahead For The Electric Vehicle Charging Industry

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    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.

  • A Post-Mortem Analysis Of Stroock's Demise

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    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.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    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.

  • Planning A Defense As IRS Kicks Off Sports Losses Campaign

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    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.

  • What New Calif. Strike Force Means For White Collar Crimes

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    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.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.

  • Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules

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    Regulations recently proposed by the IRS and the U.S. Department of the Treasury concerning two types of tax credits for clean hydrogen production facilities should resolve many of the most pressing questions around qualification for the credits — albeit in a relatively stringent manner, say attorneys at Morgan Lewis.

  • Employee Experience Strategy Can Boost Law Firm Success

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    Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.

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