Federal
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December 12, 2024
IRS Expands Business Tax Account Program To Corp. Leaders
The Internal Revenue Service's business tax account online self-service tool is now available to C corporations, while the agency is opening access to the program to certain officers of both C and S corporations, the agency said Thursday.
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December 12, 2024
IRS Hopes To Issue Amount B Pricing Guidance Within Weeks
Treasury is working to finish its guidance on the simplified transfer pricing approach to baseline marketing and distribution known as Amount B by the end of the year, a U.S. official said Thursday.
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December 12, 2024
Ex-FBI Informant Admits To False Accusations In Biden Case
A former FBI informant accused of making fake criminal accusations against President Joe Biden and his son, Hunter Biden, will plead guilty to tax evasion and falsifying records in a federal investigation, according to a deal filed Thursday in a California federal court.
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December 12, 2024
Treasury Seeks To Pause Anti-Laundering Law Injunction
The U.S. Treasury Department asked a Texas federal judge to pause his nationwide preliminary injunction of the Corporate Transparency Act pending an appeal of his recent decision that found Congress likely overstepped its constitutional authority when it wrote the anti-money laundering law.
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December 12, 2024
IRS Electronic Tax Committee To Meet In January
The Internal Revenue Service's Electronic Tax Administration Advisory Committee will hold its next meeting Jan. 8, the agency said Thursday.
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December 11, 2024
Bloomberg Entitled To Use $4B In Receipts For Deductions
Bloomberg incorrectly allocated gross receipts between software and services related to access to the Bloomberg Terminal, its interactive financial analysis product, but the company ultimately had $4.1 billion in gross receipts that could be used to calculate a deduction for domestic production from 2008 to 2010, the U.S. Tax Court found Wednesday.
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December 11, 2024
Temp Agency Owner Gets Prison For $2M Tax Scheme
A temp agency owner was sentenced to a year and a day in prison after pleading guilty in Massachusetts federal court to paying employees under-the-table wages to avoid $2.1 million in taxes.
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December 11, 2024
Tax Preparers Fabricated Expenses, US Says
Two tax preparers and their company should be barred from owning or operating tax preparation services because they fabricated business income and expenses for clients, the federal government told a Texas federal court.
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December 11, 2024
Exxon Tax Ruling Doesn't Help Liberty Global, 10th Circ. Told
Liberty Global cannot use a recent ruling that allowed Exxon Mobil a tax deduction for interest payments to claim a deduction for dividends that arose from its intragroup shuffling of a Belgian affiliate, the U.S. government told the Tenth Circuit on Wednesday.
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December 11, 2024
Beyoncé Fends Off Most Of $3M Tax Bill In Deal With IRS
Pop star Beyoncé owes only about $700 of what the IRS had claimed was $3 million in outstanding taxes and penalties, according to a U.S. Tax Court ruling Wednesday that approved a settlement between the star and the agency.
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December 11, 2024
17M Won't Benefit From Full Child Tax Credit, Report Says
Roughly 17 million children under 17 — or roughly a quarter of all U.S. children — will live in families that cannot claim the full child tax credit in 2025 because they make too little, the Urban-Brookings Tax Policy Center said in a report.
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December 11, 2024
Judge Orders Home Sale To Pay Down $1.7M Tax Debt
A California federal judge ordered the private sale of a deceased couple's home to pay down a $700,000 tax bill that has been accruing interest for 20 years and now stands at roughly $1.7 million.
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December 10, 2024
FinCEN Says CTA Still Constitutional In Post-Injunction Alert
The Financial Crimes Enforcement Network has alerted companies that they do not currently need to file so-called beneficial ownership information with the agency after a federal judge's nationwide preliminary injunction blocking the Corporate Transparency Act, though the bureau maintained that the law calling for such information is constitutional.
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December 10, 2024
Morgan Lewis Gets DLA Piper Tax Pro With DOJ Experience
Morgan Lewis & Bockius LLP announced that it has added to its Boston office a tax attorney from DLA Piper who served as an appellate attorney at the U.S. Department of Justice, Tax Division.
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December 10, 2024
Biz Owner In $2.8M Worker Tax Scheme Gets 18 Months
A construction company owner who failed to pay $2.8 million in employment taxes by falsely claiming his workers were subcontractors was sentenced to 18 months in prison Tuesday and ordered to pay full restitution, according to Massachusetts federal court documents.
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December 10, 2024
FBAR Default Against Widow Should Be Vacated, Judge Says
A New York federal magistrate judge recommended vacating a default judgment against a widow, which would give her a second chance to defend her dead husband's estate against U.S. government claims that it owes $275,000 for his failure to report his account at an Indian bank.
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December 10, 2024
Tax Court Nixes Overpayment Refunds In Tolling Row
A Florida man was correctly denied a pair of tax overpayment refunds that totaled roughly $88,000 because the statutes covering his claims are not governed by equitable tolling rules, the U.S. Tax Court said Tuesday.
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December 10, 2024
9th Circ. Nixes Tax Deductions For Disbarred Calif. Attorney
A California attorney who fought with his neighbors in court cannot take business deductions for the cost of challenging his disbarment and a court's declaration that he is a "vexatious litigant," the Ninth Circuit said Tuesday, upholding a ruling from the U.S. Tax Court.
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December 10, 2024
Exxon's Tax Win Sets Path For Liberty Global, 10th Circ. Told
A ruling allowing Exxon Mobil a U.S. tax deduction for interest expenses in its natural gas deal with Qatar confirms that Liberty Global is entitled to a deduction related to its sale of a Belgian affiliate, an attorney for the telecommunications company told the Tenth Circuit.
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December 10, 2024
Soft Landing For Pilot As Billionaire's Insider Case Wraps
A pilot who admitted to dodging taxes on $500,000 in income after he was accused of taking stock tips from Joe Lewis, his billionaire boss, avoided prison on Tuesday at a sentencing that closed a high-profile insider trading prosecution.
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December 10, 2024
Treasury Finalizes Simplified Foreign Currency Rules
The U.S. Treasury Department finalized regulations Tuesday that aim to simplify aspects of how corporations determine taxable income or loss with respect to certain affiliates that conduct business in a foreign currency.
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December 09, 2024
10th Circ. Affirms Nix Of Atty's Racing Expense Deductions
The Tenth Circuit affirmed Monday the U.S. Tax Court's determination that a Denver personal injury lawyer shouldn't be allowed to deduct about $300,000 for his car racing-related costs as advertising, despite his claims that his races helped him drum up business.
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December 09, 2024
Tax Court Lowers Car Dealership Owner's $4.7M Deficiency
The U.S. Tax Court sided with the owner of a now-shuttered used car dealership Monday in allowing him to deduct certain business expenses, which reduced the IRS' combined $4.7 million assessment of underreported income over a four-year period.
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December 09, 2024
US Investment Cos. Benefit In Updated Norway Tax Treaty
Regulated U.S. investment and holding companies should be able to reap Norwegian tax treaty benefits on dividends, royalties and capital gains without restriction under an updated agreement announced Monday by the Internal Revenue Service.
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December 09, 2024
Woman Appeals Tax Court's Canadian Debt Ruling To 9th Circ.
A woman appealed to the Ninth Circuit a U.S. Tax Court decision that prevented her from challenging a federal tax lien issued by the Internal Revenue Service to secure her $200,000 tax debt to Canada on behalf of the Canadian government.
Expert Analysis
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It's Time For A BigLaw Associates' Union
As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.
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Why DOJ's Whistleblower Program May Have Limited Impact
The U.S. Department of Justice’s new whistleblower pilot program aims to incentivize individuals to report corporate misconduct, but the program's effectiveness may be undercut by its differences from other federal agencies’ whistleblower programs and its interplay with other DOJ policies, say attorneys at Milbank.
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How Justices Upended The Administrative Procedure Act
In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.
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Trump's Best Hush Money Appeal Options Still Likely To Fail
The two strongest potential arguments former President Donald Trump could raise in appealing his New York hush money conviction seem promising at first, but precedent strongly suggests they will still ultimately fail — though, of course, Trump's unique position could lead to surprising results, says former New York Supreme Court Justice Ethan Greenberg, now at Anderson Kill.
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Tips For Tax Equity-Tax Credit Transfers That Pass IRS Muster
Although the Internal Revenue Service has increased its scrutiny of complex partnership structures, which must demonstrate their economic substance and business purpose, recent cases and IRS guidance together provide a reliable road map for creating legitimate tax equity structures, say Ian Boccaccio and Michael Messina at Ryan Tax.
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Mirror, Mirror On The Wall, Is My Counterclaim Bound To Fall?
A Pennsylvania federal court’s recent dismissal of the defendants’ counterclaims in Morgan v. Noss should remind attorneys to avoid the temptation to repackage a claim’s facts and law into a mirror-image counterclaim, as this approach will often result in a waste of time and resources, says Matthew Selmasska at Kaufman Dolowich.
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3 Leadership Practices For A More Supportive Firm Culture
Traditional leadership styles frequently amplify the inherent pressures of legal work, but a few simple, time-neutral strategies can strengthen the skills and confidence of employees and foster a more collaborative culture, while supporting individual growth and contribution to organizational goals, says Benjamin Grimes at BKG Leadership.
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E-Discovery Quarterly: Rulings On Hyperlinked Documents
Recent rulings show that counsel should engage in early discussions with clients regarding the potential of hyperlinked documents in electronically stored information, which will allow for more deliberate negotiation of any agreements regarding the scope of discovery, say attorneys at Sidley.
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Loper Bright Limits Federal Agencies' Ability To Alter Course
The U.S. Supreme Court's recent decision to dismantle Chevron deference also effectively overrules its 2005 decision in National Cable & Telecommunications Association v. Brand X, greatly diminishing agencies' ability to change regulatory course from one administration to the next, says Steven Gordon at Holland & Knight.
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A Guide To Long-Term, Part-Time Employee Determinations
With final regulations under the Secure Act requiring 401(k) retirement benefits for long-term, part-time employees expected soon, Amy Sheridan and David Guadagnoli at Sullivan & Worcester look at how the proposed rules would shift the risk-reward calculus on excluding categories of employees, and what plan sponsors would need to consider when designing retirement plans.
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After Chevron: Delegation Of Authority And Tax Regulators
The U.S. Department of the Treasury and the Internal Revenue Service will face higher standards following Loper Bright’s finding that courts should determine whether agency rules meet the best possible interpretation of the tax code, as well as the scope of the authority delegated by Congress, says Edward Froelich at McDermott.
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Lawyers Can Take Action To Honor The Voting Rights Act
As the Voting Rights Act reaches its 59th anniversary Tuesday, it must urgently be reinforced against recent efforts to dismantle voter protections, and lawyers can pitch in immediately by volunteering and taking on pro bono work to directly help safeguard the right to vote, says Anna Chu at We The Action.
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How To Grow Marketing, Biz Dev Teams In A Tight Market
Faced with fierce competition and rising operating costs, firms are feeling the pressure to build a well-oiled marketing and business development team that supports strategic priorities, but they’ll need to be flexible and creative given a tight talent market, says Ben Curle at Ambition.