Federal
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January 30, 2025
Florida Salesman Evaded $2M In Tax Over 13 Years, Court Told
A Florida salesman evaded nearly $2 million in taxes over more than a dozen years while earning more than $10 million by transferring his home and cash to his domestic partner and creating a nominee business, according to an indictment in Florida federal court.
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January 30, 2025
Crapo, Wyden Pitch Harsher Tax Pro Fines In IRS Revamp Bill
The Internal Revenue Service would be required to simplify foreign bank account report compliance and increase civil and criminal penalties on tax professionals who deliberately harm their clients under draft legislation released Thursday by the Senate Finance Committee's top Democrat and Republican.
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January 30, 2025
New Penalty Rules Flawed, 5th Circ. Told In Microcaptive Row
Treasury's new rules on supervisory approval of penalties are flawed and don't apply to a couple's suit challenging tax penalties and denied deductions related to microcaptive insurance companies they operated for a network of urgent care clinics, an attorney for the couple told the Fifth Circuit.
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January 30, 2025
Pillar 2 Should Live On Despite US Threats, Economists Say
Nations worldwide should continue implementing the international minimum tax agreement known as Pillar Two despite recent threats from the U.S. government to retaliate against what it sees as discriminatory measures imposed on U.S. companies, a group of economists said.
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January 30, 2025
Tax Group Of The Year: Skadden
Skadden Arps Slate Meagher & Flom LLP's tax practice advised on key deals and cases in 2024, including Mars Inc.'s $35.9 million acquisition of Kellanova and BlackRock Inc.'s $12.5 billion acquisition of Global Infrastructure Partners, landing it among the 2024 Law360 Tax Groups of the Year.
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January 30, 2025
SCOTUSblog Publisher Can't Shield Home From Forfeiture
SCOTUSblog publisher Tom Goldstein won't be able to shield his Washington, D.C., residence from forfeiture by substituting various properties in South Carolina as he battles charges that he dodged taxes and used his law firm's money to pay off gambling debts.
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January 30, 2025
IRS Updates NDA Language To Include Anti-Gag Provisions
The Internal Revenue Service has updated its nondisclosure agreement templates to include anti-gag provisions, following a review by the Treasury Inspector General for Tax Administration that found many NDAs lacked required references to whistleblower protections.
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January 30, 2025
Dechert's NY Office Adds Tax Pro From Milbank
Dechert LLP said it has bolstered its global tax group by adding a former special counsel from Milbank LLP to the firm's New York office.
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January 30, 2025
IRS Missing Mark On Processing Paper Returns, GAO Says
The Internal Revenue Service failed to hit its goal of processing paper returns for the 2024 tax filing season in an average of 13 days, instead taking 20, continuing a pattern of delays, the Government Accountability Office said Thursday.
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January 29, 2025
Court Garbled Pharma Owner's Fraud Charges, 6th Circ. Told
An Ohio district court misrepresented healthcare fraud charges against a pharmaceutical salesman to a jury, his attorney argued Wednesday before the Sixth Circuit, calling for the court to overturn his 2023 conviction and subsequent restitution order to pay $7 million to the IRS.
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January 29, 2025
Pension Plans Seek Trader's Testimony In $2B Tax Fraud Suit
Pension plans and individuals who Denmark's government alleges received fraudulent refunds have asked a New York federal court to allow U.K. court testimony into the record from a trader who Danish authorities say masterminded a $2.1 billion tax fraud, saying it shows he deceived other participants.
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January 29, 2025
SCOTUSBlog Publisher Faces Tough Odds In Tax Crimes Case
SCOTUSblog publisher Tom Goldstein, an expert U.S. Supreme Court lawyer accused of paying gambling debts with funds from his law firm and dodging taxes, faces an uphill battle given the considerable amount of evidence the government has already included in an indictment against him, attorneys told Law360.
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January 29, 2025
Calif. Woman Denied Relief From Joint Tax Debt
A California woman is ineligible for relief from the tax liability she and her husband accrued due to incorrectly claimed retirement fund withdrawals, the U.S. Tax Court ruled Wednesday, upholding the Internal Revenue Service's decision to deny the relief.
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January 29, 2025
IRS Appellate Staff Not Afoul Of Constitution, Tax Court Says
The U.S. Tax Court rejected arguments Wednesday by a man challenging the collection of his taxes that employees of the Internal Revenue Service's independent appeals office serve in violation of the U.S. Constitution.
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January 29, 2025
Donated Property Worth $12M Less, Tax Court Affirms
An Alabama couple must pay over $2.5 million in taxes and penalties after the U.S. Tax Court on Wednesday upheld an IRS determination that the value of property they contributed to charity was worth roughly $4 million, not the nearly $16 million they claimed.
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January 29, 2025
White & Case Adds Global Tax Pro From McDermott
White & Case LLP announced Wednesday that it is expanding its global tax practice by bringing in a former McDermott Will & Emery partner to its Washington, D.C., office.
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January 29, 2025
Tax Group Of The Year: Mayer Brown
Mayer Brown LLP's bench of tax talent is so deep that it can help its clients sell the Chicago Cubs one day and buy $646 million of Brazilian solar farms on another. The firm's ability to offer tax transaction and advisory services across industries, transaction types and specialty areas earned it a place among the 2024 Law360 Tax Groups of the Year.
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January 29, 2025
Chippewa Lawyer Tells High Court His Income Isn't Taxable
An attorney who belongs to the Minnesota Chippewa Tribe asked the U.S. Supreme Court to overturn a decision that said he owes taxes on self-employment income, saying no law expressly allows the federal taxation of income earned by Native Americans living on reservations.
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January 29, 2025
EU Will Keep Minimum Tax Despite US, Commissioner Says
The European Union will maintain a 15% minimum corporate tax rate on large companies despite the U.S. government's opposition to the global tax deal, a European commissioner said Wednesday.
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January 29, 2025
White House Rescinds Trump's Spending Freeze
The White House on Wednesday rescinded a directive freezing federal funding, saying it wants to end litigation and confusion, but said the move will not end a review of spending to ensure compliance with a series of executive orders by the president.
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January 29, 2025
11th Circ. Won't Take Back Up IRS Summons' Constitutionality
The Eleventh Circuit on Tuesday declined to revisit its November decision rejecting a taxpayer's argument that an Internal Revenue Service summons violated his Fifth Amendment rights against self-incrimination.
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January 28, 2025
Lobbying Is Not A Crime, Madigan Co-Defendant Tells Jury
An attorney for an ex-lobbyist standing trial on public corruption charges alongside former Illinois House Speaker Michael Madigan told jurors on Tuesday the government failed to establish that his client conspired to trade the ex-speaker's support for do-nothing jobs, saying all that really happened was "lobbying and politics."
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January 28, 2025
IRS Whistleblower Office Could Survive Trump Purge
As President Donald Trump pushes to slash federal spending and gut government agencies, the Internal Revenue Service Whistleblower Office may remain largely unscathed since its recent efforts to efficiently reward and protect those who report illicit tax activity could align with the administration's goals.
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January 28, 2025
Amid Big Bets, Tom Goldstein Argued 'Poker Is Not Gambling'
A federal indictment's jarring portrayal of pioneering U.S. Supreme Court advocate Tom Goldstein as an "ultrahigh-stakes" gambler who dodged taxes has left the legal community virtually speechless. But Goldstein's status as a serious poker player was not a secret, and in past court cases, he proclaimed the card game "fundamentally dissimilar" from conventional gambling, even while preparing to wager millions on matches.
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January 28, 2025
Trump Pledges Tariffs On Semiconductors, Chips, Drugs
The U.S. will soon place tariffs on foreign-manufactured semiconductors, computer chips and pharmaceuticals in an effort to convince foreign companies to move their manufacturing operations stateside, President Donald Trump told House Republicans at a conference.
Expert Analysis
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Takeaways From Justices' Redemption Insurance Decision
The U.S. Supreme Court’s recent decision in Connelly v. U.S. examines how to determine the fair market value of shares in a closely held company for estate tax purposes, and clarifies how life insurance held by the company to enable redemption of a decedent’s shares affects that calculation, says Evelyn Haralampu at Burns & Levinson.
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6 Tips For Maximizing After-Tax Returns In Private M&A Deals
With potential tax legislation likely to spur a surge in private business sales, sellers can make the most of after-tax proceeds with strategies that include price allocation and qualified investment options, say Isaac Grossman and Daniel Studin at Morrison Cohen.
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After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1
The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.
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Recruitment Trends In Emerging Law Firm Frontiers
BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.
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What DOL Fiduciary Rule Means For Private Fund Managers
Attorneys at Ropes & Gray discuss how the U.S. Department of Labor's recently released final fiduciary rule, which revises the agency's 1975 regulation, could potentially cause private fund managers' current marketing practices and communications to be considered fiduciary advice, and therefore subject them to strict prohibitions.
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Money, Money, Money: Limiting White Collar Wealth Evidence
As courts increasingly recognize that allowing unfettered evidence of wealth could prejudice a jury against a defendant, white collar defense counsel should consider several avenues for excluding visual evidence of a lavish lifestyle at trial, says Jonathan Porter at Husch Blackwell.
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How Associates Can Build A Professional Image
As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.
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Navigating New Safe Harbor For Domestic Content Tax Credits
The U.S. Department of the Treasury’s recent notice simplifying domestic content calculations for certain solar, onshore wind and battery storage projects, which directly acknowledges the difficulty for taxpayers in gathering data to support a domestic content analysis, should make it easier to qualify additional domestic content bonus tax credits, say attorneys at A&O Shearman.
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Firms Must Rethink How They Train New Lawyers In AI Age
As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.
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'Energy Communities' Update May Clarify Tax Credit Eligibility
A recent IRS notice that includes updated lists of locations where clean energy projects can qualify for additional tax credits — based 2023 unemployment data and placed-in-service dates — should help provide clarity regarding project eligibility that sponsors and developers need, say attorneys at Troutman Pepper.
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Think Like A Lawyer: Always Be Closing
When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.
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Lean Into The 'Great Restoration' To Retain Legal Talent
As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.