Federal

  • January 17, 2025

    US Guidance On Amount B Carries Potential For Disputes

    Recent IRS guidance on a simplified and streamlined transfer pricing method for certain cross-border transactions, known as Amount B, suggests rulemakers want feedback on how it would work if it were made mandatory, but that approach could lead to controversy without global cooperation.

  • January 17, 2025

    Bill Aims To Extend Biogas Investment Credit Through 2025

    A bill in the U.S. House of Representatives would extend the clean energy investment tax credit available for certain biogas facilities' equipment through the end of 2025 instead of at the end of 2024, the bill's sponsors said Friday.

  • January 17, 2025

    11th Circ. Urged To Reject Biz Owners' Tax Penalty Challenge

    The owners of an electronic parts company who asked the Eleventh Circuit to reverse a tax penalty and find that Tax Court judges have unconstitutional job protections failed to link the two and are not entitled to tax relief, the U.S. government said Friday.

  • January 17, 2025

    LA Crypto 'Godfather' Admits To $36M Meta Hacking Fraud

    A Los Angeles-based cryptocurrency founder who called himself "The Godfather" will plead guilty to earning $36 million through the sale of hacked Meta Platforms advertising accounts and evading taxes on the fraudulent profits, according to federal court documents unsealed Friday,

  • January 17, 2025

    IRS Rewrites Residential Green Energy Credit FAQ

    The Internal Revenue Service made substantial changes Friday to its fact sheet for the energy efficient home improvement and residential clean energy property tax credits.

  • January 17, 2025

    Meet The Key Players In Tom Goldstein's Tax-Crimes Case

    The tax-evasion indictment of U.S. Supreme Court expert lawyer and SCOTUSblog publisher Tom Goldstein features an eclectic cast of characters linked to his purported side career as a high-stakes poker player, including law firm partners, professional gamblers, a Texas billionaire, a movie producer and an actor.

  • January 17, 2025

    Taxation With Representation: Simpson Thacher, Covington

    In this week's Taxation With Representation, Eli Lilly and Co. buys a precision breast cancer program, Applied Digital Corp. enters a financing agreement for its high-performance computing business, Clearwater Analytics buys Enfusion, and Lantheus Holdings Inc. buys Life Molecular Imaging Ltd.

  • January 17, 2025

    Ex-Pol's Atty Chided For Early Morning Sentencing Memo

    The lawyer for a former Massachusetts state senator convicted of tax and pandemic aid fraud was scolded by a federal judge on Friday for filing a sentencing memo at 3:30 a.m. on the day of the hearing, then showing up late to court, forcing a postponement.

  • January 17, 2025

    Co. Suggests 4 Chemicals For Taxable Substances List

    The Internal Revenue Service is seeking comments on proposals from Occidental Chemical Corp. to add four chemicals to the Internal Revenue Code's list of taxable substances, the agency said Friday.

  • January 17, 2025

    IRS Commissioner To Step Down As Trump Takes Office

    Internal Revenue Commissioner Daniel Werfel is stepping down from his position in light of President-elect Donald Trump's intent to nominate former Rep. Billy Long to replace him, Werfel said in a message to the agency's employees Friday.

  • January 17, 2025

    Vanguard To Pay SEC, States $106M Over Surprise Tax Bills

    The U.S. Securities and Exchange Commission was joined by dozens of state regulators Friday in announcing a $106.4 million settlement with The Vanguard Group Inc. over claims that the company misled investors about the heightened capital gains taxes they would have to pay on certain retirement savings accounts.

  • January 17, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included revised rules for companies that file consolidated federal income tax returns to modernize previous rules' terminology, including removing gender-specific pronouns. 

  • January 16, 2025

    Trump's Treasury Pick Calls For Permanently Extending TCJA

    Congress must permanently extend the Tax Cuts and Jobs Act provisions set to expire this year to prevent the largest tax increase in history, Scott Bessent, President-elect Donald Trump's pick for Treasury secretary, told the Senate Finance Committee on Thursday.

  • January 16, 2025

    Tax Court Denies Late Pass For Identity Theft

    A California couple cannot challenge an Internal Revenue Service decision to levy their state tax refund because they missed the deadline for filing a petition by four years, the U.S. Tax Court said Thursday, rejecting their request for an extension for dealing with identity theft.

  • January 16, 2025

    DOJ Tax Chief Touts Winning Court Record On Appeals

    The U.S. Department of Justice's Tax Division won an overwhelming majority of appeals in tax cases last year by prioritizing strong legal arguments in disputes that had the potential to significantly affect federal tax administration, the head of the division said Thursday.

  • January 16, 2025

    Tax Court Rejects Explanation For Unreported Wages

    A woman owes taxes on nearly $19,000 of unreported income she said she reported on a gift tax return, the U.S. Tax Court ruled Thursday, rejecting her argument that wages reported as gifts would not incur taxes.

  • January 16, 2025

    Tax Court Tosses Some Of Ind. Couple's Deduction Claims

    The U.S. Tax Court had mixed responses Thursday related to an Indiana couple's claimed business deductions tied to a rental property as well as itemized deductions related to the husband's work as an electrician, allowing some while saying others weren't properly substantiated.

  • January 16, 2025

    IRS Explains Changing Elective Payment Accounting Periods

    The IRS provided procedures Thursday for certain entities — including Native American tribes and state governments — that aren't required to file federal income tax returns but have chosen to make elective payments and want to change their taxable years to match their accounting periods.

  • January 16, 2025

    AmEx Inks $230M Deal Over DOJ, Fed Small Biz Sales Claims

    American Express has signed a nonprosecution agreement and said Thursday it will pay about $230 million to end investigations by the Department of Justice and the Federal Reserve into the financial services company's previous sales practices for some small business customers in the U.S.

  • January 16, 2025

    Tax Court's 90-Day Deadline Is Not Fixed, 6th Circ. Told

    A woman who missed the 90-day deadline for challenging her liabilities in the U.S. Tax Court told the Sixth Circuit on Thursday that the Internal Revenue Service has wrongly argued that case law proves the deadline is set in stone.

  • January 16, 2025

    SCOTUSblog Publisher Tom Goldstein Indicted In Tax Case

    Tom Goldstein, a publisher of SCOTUSblog and one of the most experienced U.S. Supreme Court lawyers in the country, was indicted Thursday in Maryland federal court on charges he schemed to evade paying taxes for years and used funds from his boutique law firm to cover gambling debts. 

  • January 16, 2025

    OECD To Release List Of Abusive Transactions Under Pillar 2

    The Organization for Economic Cooperation and Development is putting together a list of intercompany transactions that may raise red flags as attempts to undermine an international minimum tax agreement known as Pillar Two, an OECD official said Thursday.  

  • January 16, 2025

    Morrison Foerster Adds Tax Group Co-Chair From Jones Day

    Morrison Foerster LLP announced it has added a partner from Jones Day to serve as co-chair of the firm's global tax group in its New York office.

  • January 16, 2025

    Atty Gets 5-Year NJ Suspension After Tax Fraud Conviction

    A Philadelphia-based personal injury attorney convicted for not paying income tax on more than $8 million in revenue he earned and for failing to pay almost $60,000 in payroll taxes received a five-year suspension from New Jersey's Supreme Court but will keep his law license in the state.

  • January 16, 2025

    IRS Corrects Simplified Foreign Currency Rules

    The Internal Revenue Service issued corrections Thursday to finalized regulations 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.

Expert Analysis

  • A Proposal For Fairer, More Efficient Innocent Spouse Relief

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    Adding a simple election to the current regulatory framework for innocent spouse claims would benefit both taxpayers and the Internal Revenue Service by alleviating the undue burdens placed on those the program was intended to help and improving agency collections in such cases, says Laurie Kazenoff at Kazenoff Tax.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • Proposed Hydrogen Tax Credit Regs May Be Legally Flawed

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    While the recently proposed regulations for the new clean hydrogen production tax credit have been lauded by some in the environmental community, it is unclear whether they are sufficiently grounded in law, result from valid rulemaking processes, or accord with other administrative law principles, say Hunter Johnston and Steven Dixon at Steptoe.

  • Navigating ACA Reporting Nuances As Deadlines Loom

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    Stephanie Lowe at Liebert Cassidy walks employers through need-to-know elements of Affordable Care Act reporting, including two quickly approaching deadlines, the updated affordability threshold, strategies for choosing an affordability safe harbor, and common coding pitfalls.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • Why Biz Groups Disagree On Ending Chevron Deference

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    Two amicus briefs filed in advance of last month's U.S. Supreme Court oral arguments in Loper Bright Enterprises v. Raimondo highlight contrasting views on whether the doctrine of Chevron deference promotes or undermines the stable regulatory environment that businesses require, say Wyatt Kendall and Sydney Brogden at Morris Manning.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • 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.

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