Federal
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October 17, 2024
A&O Shearman Taps Governance Veteran To Co-Lead Practice
A&O Shearman said Thursday that it has tapped a longtime partner to co-head the firm's compensation, employment, pensions and governance practice, bringing it under the joint leadership of alum from each of its two legacy firms after the merger between New York-based Shearman & Sterling and London-based legacy firm Allen & Overy became official last May.
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October 17, 2024
Justices Told Woman Can't Dispute Levy For Paid-Off Tax
A Third Circuit decision allowing a woman to challenge her tax liabilities in a property-seizure proceeding should be overturned, the Internal Revenue Service told the U.S. Supreme Court, saying her case became moot after the agency withheld her tax refunds to pay off her debt.
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October 17, 2024
Polsinelli Hires McDermott Tax Counsel In DC
Polsinelli PC has hired an attorney who joined the firm's tax group as a shareholder after 12 and a half years with McDermott Will & Emery LLP.
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October 17, 2024
IRS To Hold Hearing On Tax Payments With Cards
The Internal Revenue Service will hold a public hearing Dec. 6 regarding proposed regulations that would allow taxpayers to make payments using credit and debit cards directly with the agency instead of through a third party, the IRS said Thursday.
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October 16, 2024
2 CPAs Get 20 Months For Roles In $1.3B Tax Shelter Scheme
Two certified public accountants were each sentenced in Georgia federal court to nearly two years in prison for selling tens of millions of dollars in false tax deductions to their rich clients as part of a $1.3 billion tax fraud scheme, the U.S. Department of Justice announced Wednesday.
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October 16, 2024
3rd Par Funding Exec Admits To Racketeering In $100M Scam
The last member of the triumvirate behind Par Funding, a cash advance company that federal prosecutors say bilked investors out of $100 million, pleaded guilty to racketeering in Pennsylvania federal court Wednesday, just weeks before he was scheduled to stand trial.
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October 16, 2024
Utah Groups Can't Scrap Corporate Transparency, US Says
A Utah federal court hasn't seen sufficient evidence to block the Corporate Transparency Act's disclosure requirements in presentations by an off-the-grid community, an online meat market and a trade group for cattle producers that have sued over the statute, the federal government said.
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October 16, 2024
Justices Won't Review Tax Scam Co-Conspirator's Sentence
The U.S. Supreme Court declined to review the more than eight-year prison sentence for one of the men who conspired with a Canfield, Ohio defense attorney to perpetrate a tax refund scam that defrauded the U.S. Internal Revenue Service out of $1.3 million.
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October 16, 2024
Nev. Businessman, Trump Donor Challenges $12M Tax Bill
A Nevada businessman and major donor to former President Donald Trump challenged what the IRS claimed are more than $12 million in tax liabilities, telling the U.S. Tax Court that the agency incorrectly adjusted his rental real estate losses and other reported calculations.
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October 16, 2024
Construction Co., Gov't Drop $4M Retention Credit Suit
A former construction business' suit against the Internal Revenue Service seeking nearly $4 million in employee retention credit refunds was dismissed by a Florida federal judge Wednesday after the company and the federal government agreed to drop the case.
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October 16, 2024
5th Circ. Upholds Frivolity Penalty In Dell Worker Tax Case
A Texas man who claimed that nearly $300,000 he earned from working at Dell Technologies Inc. wasn't taxable must pay the taxes in addition to a $25,000 fine for making frivolous arguments, the Fifth Circuit said.
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October 16, 2024
Ex-BigLaw Partner Gets 16 Months For Tax Evasion
A former partner at Husch Blackwell LLP and Dykema Gossett PLLC who pled guilty to refusing to pay taxes on millions of dollars in income was sentenced to 16 months in prison.
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October 15, 2024
Applicable Federal Rates Set For Mixed Changes In Nov.
While the short-term applicable federal rate for income tax purposes will continue a monthslong decline in November, related rates will either hold steady or increase, the Internal Revenue Service said Tuesday.
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October 15, 2024
IRS Issues Benefit Overpayments Guidance Under Secure 2.0
The Internal Revenue Service published guidance Tuesday related to certain inadvertent benefit overpayments as they relate to changes made in the Secure 2.0 Act of 2022, including the treatment of certain overpayments as eligible rollover distributions.
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October 15, 2024
Justices Told Split On Shedding Tax Debts Can't Be Ignored
The U.S. Supreme Court should review a Ninth Circuit decision that found late-filed returns prevented a taxpayer from discharging his federal tax debt in bankruptcy, the taxpayer argued, saying both sides in the case have agreed the circuits are split on the issue.
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October 15, 2024
Israel-US Citizen Owes $1.1M In FBAR Penalties, US Says
A dual Israeli-American citizen who owns a Chicago pub faces more than $1 million in penalties for failing to report bank accounts that he maintained in Israel, the U.S. government told an Illinois federal court.
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October 15, 2024
New ABA Tax Chair Wants To Revamp Practice's Dry Image
The new chair of the American Bar Association Section of Taxation told Law360 she wants to boost the section's recent efforts to revamp the tax practice's image as a boring, numbers-intensive profession with limited opportunities to improve society and inspire more students to enter tax law. Here, she shares her background and goals for the tax section.
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October 15, 2024
Alvarez & Marsal Tax Brings On Restructuring Leader
Alvarez & Marsal's tax affiliate added a restructuring professional from investment bank Houlihan Lokey to serve as its head of global restructuring tax services.
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October 15, 2024
V&E Adds Energy Tax Pro From Bracewell In Houston
Vinson & Elkins LLP has bolstered its energy transition and tax practices with a partner in Houston who came aboard from Bracewell LLP and whose background includes substantial in-house experience advising on renewable projects.
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October 15, 2024
Law Firms Diverge As Anti-ESG Pushback Continues
A continuing onslaught of legislation and litigation opposing corporate environmental, social and governance actions has created a fork in the road for law firms, with some choosing to scale back efforts and others pushing ahead with their internal ESG and diversity, equity and inclusion goals.
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October 15, 2024
The 2024 Law360 Pulse Social Impact Leaders
Check out our Social Impact Leaders ranking, analysis and interactive graphics to see which firms stand out for their engagement with social responsibility and commitment to pro bono service.
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October 15, 2024
Gov't Resists DC Circ. Redo In Ayahuasca Church Tax Case
An Iowa church that used a psychedelic in its rites was correctly denied tax-exempt status on grounds that it was organized for illegal aims, the federal government told the D.C. Circuit in urging it to reject the church's request for a rehearing.
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October 11, 2024
Julie Chrisley Appeals Ga. Judge's Resentencing Ruling
Former real estate mogul and reality television star Julie Chrisley, who was convicted of running a yearslong bank fraud scheme with her husband, Todd, is appealing a federal judge's decision to resentence her to the same seven-year prison term she first received nearly two years ago.
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October 11, 2024
Philly Pizzeria Owner Accused Of Dodging Taxes
A Pennsylvania pizzeria owner evaded taxes for multiple years by paying himself and employees in cash and lied about it to his accountant, the U.S. Department of Justice said in announcing charges against him.
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October 11, 2024
Tribal Wildfire Victims Can File Returns Late, IRS Says
Members of the San Carlos Apache Tribe in Arizona who were affected by a wildfire in July may put off filing certain tax returns until Feb. 5, the Internal Revenue Service said Friday.
Expert Analysis
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Employers, Prep For Shorter Stock Awards Settlement Cycle
Companies that provide equity compensation in the form of publicly traded stock will soon have one less day to complete such transactions under U.S. Securities and Exchange Commission and Nasdaq rules — so employers should implement expedited equity compensation stock settlement and payroll tax deposit procedures now, say attorneys at Morgan Lewis.
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Demystifying IRS' Claims Of $851B Return On Investment
The IRS' recently released analysis, estimating a $851 billion return on the government’s $80 billion investment in the agency, represents a huge increase over its 2022 estimate and that of the Congressional Budget Office and may be best viewed as a best-case scenario, says Joyce Beebe at the Baker Institute.
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How Firms Can Ensure Associate Gender Parity Lasts
Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.
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A Proposal For Fairer, More Efficient Innocent Spouse Relief
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.
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7 Common Myths About Lateral Partner Moves
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.
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Proposed Hydrogen Tax Credit Regs May Be Legally Flawed
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.
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Navigating ACA Reporting Nuances As Deadlines Loom
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.
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6 Pointers For Attys To Build Trust, Credibility On Social Media
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.
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Why Biz Groups Disagree On Ending Chevron Deference
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.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
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.
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A Look Ahead For The Electric Vehicle Charging Industry
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.
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A Post-Mortem Analysis Of Stroock's Demise
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.
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SG's Office Is Case Study To Help Close Legal Gender Gap
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.