Federal

  • June 28, 2024

    Chevron's End Is Just The Start For Energized Agency Foes

    By knocking down a powerful precedent that has towered over administrative law for 40 years, the U.S. Supreme Court's right wing Friday gave a crowning achievement to anti-agency attorneys. But for those attorneys, the achievement is merely a means to an end, and experts expect a litigation blitzkrieg to materialize quickly in the aftermath.

  • June 28, 2024

    In Chevron Case, Justices Trade One Unknown For Another

    The U.S. Supreme Court's decision to overrule a decades-old judicial deference doctrine may cause the "eternal fog of uncertainty" surrounding federal agency actions to dissipate and level the playing field in challenges of government policies, but lawyers warn it raises new questions over what rules courts must follow and how judges will implement them.

  • June 28, 2024

    The Tax Angle: IRS Budget Vote, TCJA's Racial Impact

    From a look at an upcoming vote on IRS funding for fiscal 2025 to an analysis of GOP claims that tax incentives in the 2017 Tax Cuts and Jobs Act benefited Black Americans, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • June 28, 2024

    IRS Finalizes Broker Rules For Digital Asset Sales

    Brokers of digital assets such as cryptocurrency and non-fungible tokens will face tax reporting requirements for the first time similar to those for brokers of securities and other financial instruments under final regulations issued Friday by the Internal Revenue Service.

  • June 28, 2024

    Final Rules Exempt REITs From Stock Buyback Tax

    Real estate investment trusts and regulated investment companies may be able to avoid the stock buyback tax but would still be required to keep records under final regulations on reporting and paying the tax released by Treasury and the IRS Friday.

  • June 28, 2024

    IRS Plans To Quickly Finalize Partnership Basis-Shifting Regs

    The IRS is moving quickly to finalize partnership rules that target abusive tax avoidance using basis shifting within related partnerships, the agency's top attorney said Friday, asking practitioners to weigh in on the rulemaking so enforcement can properly target the problematic transactions.

  • June 28, 2024

    IRS Improves Availability But Can Do More, TIGTA Says

    The Internal Revenue Service has improved the accessibility and availability of customer services in underserved, underrepresented and rural communities, but it could do more to expand into other geographic areas, the Treasury Inspector General for Tax Administration said Friday.

  • June 28, 2024

    IRS Whistleblower Office Overhaul In Process, Chief Says

    The Internal Revenue Service is working through initiatives to improve its whistleblower program that were laid out in the agency's strategic operating plan, including improving systems and processes and drastically increasing staffing, the director of the agency's Whistleblower Office said Friday.

  • June 28, 2024

    NY Law Firm Botched Gas Co. Sale, Ex-Client Says

    Albany, New York-based Whiteman Osterman & Hanna LLP is facing a lawsuit in New York federal court alleging it failed to properly structure the sale of a gas company and caused its owner to incur an avoidable tax liability.

  • June 28, 2024

    IRS Reminds Marijuana Businesses They Can't Get Tax Breaks

    The Internal Revenue Service sought to remind taxpayers Friday that businesses selling marijuana, even in states where it's legal, are not entitled to federal tax deductions, saying some taxpayers are filing invalid claims for refunds through amended returns.

  • June 28, 2024

    Chevron Ruling No Sea Change For Tax Court, Judge Says

    The U.S. Tax Court will continue to rely on the IRS and Treasury's expertise in the tax code following the U.S. Supreme Court's landmark decision to overturn the 40-year-old Chevron doctrine that directed courts to defer to federal agencies' interpretations of ambiguous law, a judge said Friday.

  • June 28, 2024

    Spouse's Prenup Payments Count As Income, IRS Says

    Support payments to a taxpayer from a former spouse made before they officially divorce constitute alimony and should be included in the taxpayer's gross income, the Internal Revenue Service said in a private letter ruling released Friday.

  • June 28, 2024

    IRS Revokes Variable Annuity Ruling From 2014

    The IRS revoked part of a 2014 private letter ruling regarding an annuity option with variable payments that a taxpayer had planned to offer, saying in a ruling released Friday that it no longer agreed with its former position.

  • 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.

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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