Federal

  • July 17, 2024

    IRS Plans August Hearing On Stock Buyback Tax Rules

    The Internal Revenue Service will hold a public hearing Aug. 27 on proposed regulations governing a new excise tax on repurchases of corporate stock, the agency said Wednesday.

  • July 17, 2024

    IRS Issues Fixes For Clean Electricity Credit Regs

    The Internal Revenue Service issued corrections Wednesday that it said fix a number of errors in proposed regulations concerning the clean electricity production and investment tax credits established by the Inflation Reduction Act.

  • July 17, 2024

    Treasury Finalizes Rules To Target 'Killer B' Transactions

    The U.S. Treasury Department published final regulations Wednesday aimed at so-called Killer B transactions, which involve certain corporate reorganizations with at least one foreign affiliate that ultimately allow U.S. companies to avoid domestic taxes.

  • July 17, 2024

    Rising Star: Cravath's Kiran Sheffrin

    Kiran Sheffrin of Cravath Swaine & Moore LLP has advised companies from Anheuser-Busch InBev to Valvoline on multibillion-dollar deals, including a $50 billion combination resulting in the formation of pharmaceutical giant Viatris, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 17, 2024

    Woman Can't Escape Suit Over Partner's $1.1M FBAR Debt

    A woman whose late romantic partner owed $1.1 million in reporting penalties on hidden financial accounts in France and Switzerland can't stop the government from pursuing a suit against her for half the value of her home, a New York federal court ruled.

  • July 17, 2024

    Baker McKenzie Adds EY Partner To Mexico City Office

    Baker McKenzie has appointed a new partner from EY Mexico to its North American tax practice group in Mexico City.

  • July 16, 2024

    Intracompany Prices Should Reflect Acquired IP, Panelists Say

    When one company buys another for its intellectual property, the subsequent pricing of that asset between the now-related entities should reflect the value of what was acquired, transfer pricing specialists said Tuesday at a conference in Washington, D.C.

  • July 16, 2024

    More Geographic Adjustments 'On The Table' For Amount B

    Countries' ability to make further adjustments for geographic differences in the streamlined transfer pricing approach known as Amount B — part of the OECD's plan for reallocating taxing rights among jurisdictions — is "still on the table," an official from the organization said Tuesday.

  • July 16, 2024

    Tycoon's Pilot Says Feds' Stock Tip Claims Don't Add Up

    A private pilot who used to work for convicted insider trader and U.K. billionaire Joe Lewis is arguing federal prosecutors can't use allegations that his own trades were suspicious to ramp up a sentence for a separate tax evasion charge.

  • July 16, 2024

    7th Circ. Says Foreign Retirement Not Shielded In Bankruptcy

    A professor who filed for bankruptcy in Illinois can't protect his Canadian retirement account from creditors because the account is ineligible under a state law shielding accounts that qualify as retirement plans under the Internal Revenue Code, the Seventh Circuit ruled Tuesday.

  • July 16, 2024

    Tax Court Grants Installment Gain Recognition On Stock Sales

    The U.S. Tax Court rejected Tuesday a claim by the IRS that a man and his cousin who had each sold stock in 2002 to an employee stock ownership trust for more than $4 million had to recognize the entirety of their deferred gain the following year.

  • July 16, 2024

    Connecticut Contractor Fined $1.75M For Tax Evasion

    A Connecticut contractor was ordered to pay a $1.75 million fine for evading federal corporate and individual income taxes from 2006 through 2010, the U.S. Department of Justice announced Tuesday.

  • July 16, 2024

    DC Circ. Upholds Dismissal Of Tax Whistleblower Award Case

    The D.C. Circuit upheld Tuesday the U.S. Tax Court's dismissal of a Mississippi man's case seeking review of the denial of his whistleblower claim for 30% of the revenue collected by an Internal Revenue Service offshore voluntary disclosure program.

  • July 16, 2024

    Tax Court Says Deductions Properly Disallowed By IRS

    A New York couple was properly denied tens of thousands of dollars worth of deductions on their federal income taxes by the Internal Revenue Service, since the pair neither qualified nor adequately substantiated their claims, the U.S. Tax Court said Tuesday.

  • July 16, 2024

    Contractor Asks Justices To Review $1.3M R&D Credit Suit

    A construction company's shareholders asked the U.S. Supreme Court to review a decision revoking their tax refund for the company's $1.3 million in claimed research credits, saying the Fifth Circuit wrongly deferred to the Internal Revenue Service in stopping their case from going to trial.

  • July 16, 2024

    Rising Star: Skadden's Melinda Gammello

    Melinda Gammello of Skadden Arps Slate Meagher & Flom LLP has advised numerous clients before the U.S. Tax Court and elsewhere on complex tax matters, including transfer pricing issues and the treatment of financial transactions within a company, earning her a spot among the tax law practitioners under 40 honored by Law360 as Rising Stars.

  • July 16, 2024

    The 2024 Diversity Snapshot: What You Need To Know

    Law firms' ongoing initiatives to address diversity challenges have driven another year of progress, with the representation of minority attorneys continuing to improve across the board, albeit at a slower pace than in previous years. Here's our data dive into minority representation at law firms in 2023.

  • July 16, 2024

    These Firms Have The Most Diverse Equity Partnerships

    Law360’s law firm survey shows that firms' efforts to diversify their equity partner ranks are lagging. But some have embraced a broader talent pool at the equity partner level. Here are the ones that stood out.

  • July 16, 2024

    Applicable Federal Interest Rates To Drop In August

    Applicable federal rates for income tax purposes will decrease in August, the Internal Revenue Service said Tuesday, the second month-to-month drop in a row.

  • July 16, 2024

    3 Tax Reg Groups That May Be Shaky After High Court Rulings

    The U.S. Supreme Court issued two rulings that, when combined, open up long-standing federal regulations to challenges without judicial deference to agencies — a pairing that could weaken several categories of tax rules, including guidance issued under the 2017 federal overhaul. Here, Law360 looks at three batches of tax regulations that may be vulnerable in the aftermath of the high court's decisions.

  • July 15, 2024

    Israeli Firm Seeks To Amend Suit Against GILTI Regs

    The owner of an Israeli law firm asked a D.C. federal court to let him amend his challenge to regulations for the U.S. tax on global intangible low-taxed income after the D.C. Circuit determined parts of his arguments went unconsidered.

  • July 15, 2024

    4th Circ. Rejects Couple's $5.1M Easement Deduction

    The Fourth Circuit rejected Monday a married couple's bid to revive a claimed $5.1 million conservation easement deduction, saying it represented a "remarkable" attempt to inflate the value of a 41-acre property that was worth just $652,000 the year before they donated it.

  • July 15, 2024

    Former Doctor Seeks Jail Release In FBAR Fight

    An incarcerated former doctor asked a Michigan federal court Monday to lift its order of civil contempt for his failure to pay about $1 million in foreign account reporting penalties, saying he has done all he can to repatriate offshore securities.

  • July 15, 2024

    Widow To Pull $1.7M From Swiss Bank To Pay FBAR Penalties

    A logger's widow agreed to pull about $1.7 million from her Swiss bank account to pay down penalties that her late husband's estate owes the IRS for his failure to report offshore accounts, according to a filing Monday in a Colorado federal court.

  • July 15, 2024

    AICPA Suggests Revising Foreign Trust Loan Anti-Abuse Rule

    The U.S. Treasury Department should scrap or revise significantly an anti-abuse rule for nonresident aliens who receive loans from foreign trusts, which was included in proposed regulations on how to report foreign trust transactions, the American Institute of Certified Public Accountants said in a letter published Monday.

Expert Analysis

  • Weisselberg's Perjury At Trial Spotlights Atty Ethics Issues

    Author Photo

    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.

  • Practicing Law With Parkinson's Disease

    Author Photo

    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.

  • 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.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

    Author Photo

    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.

  • Trump's NY Civil Fraud Trial Spotlights Long-Criticized Law

    Author Photo

    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.

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

    Author Photo

    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.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

    Author Photo

    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.

  • How IRA Unlocks Green Energy Investments For Tribes

    Author Photo

    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.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

    Author Photo

    Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.

  • What To Know About IRS' New Jet Use Audit Campaign

    Author Photo

    The Internal Revenue Service recently announced plans to open several dozen audits scrutinizing executive use of company jets, so companies should be prepared to show the business reasons for travel, and how items like imputed income and deduction disallowance were calculated, say attorneys at Morgan Lewis.

  • Stay Interviews Are Key To Retaining Legal Talent

    Author Photo

    Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.

  • Judicial Independence Is Imperative This Election Year

    Author Photo

    As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.

  • Spartan Arbitration Tactics Against Well-Funded Opponents

    Author Photo

    Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.