Federal
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July 22, 2024
US Treasury Working To Extend Pillar 1 DST Compromise
As OECD-led negotiations continue on a taxing rights overhaul known as Pillar One after a missed June deadline, the U.S. Treasury Department is working to extend the political agreement between it and several countries to nullify their digital services taxes once the rights overhaul is implemented.
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July 22, 2024
Pension Plans Slam Biz Docs In $2B Danish Tax Fraud Case
Denmark's tax agency has produced experts who are relying on unauthenticated documents in litigation accusing U.S. pension plans of participating in a $2.1 billion fraud scheme, the pension plans claimed in urging a New York federal court to exclude the testimony.
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July 22, 2024
11th Circ. Denies Rehearing On Social Security Garnishment
The Eleventh Circuit on Monday turned down a Florida woman's request to reconsider its rejection of her challenge to the Internal Revenue Service's garnishment of her Social Security payments.
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July 22, 2024
Werfel Wants IRS to Help Eligible EITC Nonclaimaints
The Internal Revenue Service needs to do more to help people who are eligible for the earned income tax credit but don't claim it, Daniel Werfel, the agency's commissioner, said Monday.
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July 22, 2024
IRS Delays Tax Deadlines For Texans Affected By Hurricane
Certain Texas taxpayers affected by Hurricane Beryl, which hit the state this month, will have until a delayed deadline of Feb. 3 to file individual and business tax returns and make payments, the Internal Revenue Service said Monday.
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July 22, 2024
Kyocera Failed To Back R&D Credits With Records, US Says
Multinational electronics maker Kyocera AVX Components Corp. failed to back up its claim to research tax credits with the required paperwork, the U.S. government told a South Carolina federal court in asking it to stop part of the company's nearly $9 million refund suit from going to trial.
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July 19, 2024
House Panel To Weigh EV Credit Restrictions, IRS' Use Of AI
The House Rules Committee will consider amendments Monday to a fiscal 2025 funding bill that would give the IRS $10.1 billion, sorting through divergent priorities of lawmakers from integrating artificial intelligence into agency operations to restricting tax credits for electric vehicles and helping seniors file tax returns.
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July 19, 2024
Partnership Protests IRS' Reasons For $84M Deduction Denial
The Internal Revenue Service wrongly denied a partnership's charitable contribution deduction of nearly $84 million for a donated conservation easement for reasons including the partnership failing to demonstrate it made the contribution, the partnership's representative told the U.S. Tax Court.
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July 19, 2024
Cox Owner's Estate Claims IRS Miscalculated $46M Tax Bill
The estate of an owner of the Cox Enterprises media empire challenged a $46 million tax bill from the Internal Revenue Service, telling the U.S. Tax Court that the agency erroneously calculated the tax by inflating the value of the company's stock by about $20 per share.
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July 19, 2024
Attorney Denied Separate Trial In $2.1B Danish Tax Fraud
An attorney facing trial alongside his clients for alleged ties to a $2.1 billion Danish tax fraud has been denied a separate hearing by a New York federal court, which remained unconvinced that his co-workers' advice to the clients could rebound on him prejudicially in a joint trial.
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July 19, 2024
Taxation With Representation: A&O Shearman, Gibson Dunn
In this week's Taxation With Representation, Cleveland-Cliffs Inc. buys Stelco Holdings Inc., KBR acquires LinQuest Corp., Blue Owl Capital Inc. purchases Atalaya Capital Management LP, and Amphenol Corp. buys two mobile networks units from CommScope.
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July 19, 2024
Chippewa Lawyer Not Exempt From Taxes, 8th Circ. Says
The Eighth Circuit said Friday that an attorney who belongs to the Minnesota Chippewa Tribe is not exempt from federal taxes on his self-employment income, saying no treaty or statute specifically allows Native Americans to skirt the tax.
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July 19, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the finalized rules that curb the conservation easement tax deduction claimed by certain partnerships.
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July 18, 2024
Hunter Biden Wants Charges Tossed After Trump Docs Ruling
Hunter Biden on Thursday asked federal judges in Delaware and California to throw out his conviction on felony gun charges and to toss other charges of tax evasion, citing a Florida federal judge's order disqualifying the special prosecutor in Donald Trump's classified documents case.
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July 18, 2024
Treasury Starting To Address Amount B, Official Says
The U.S. Department of the Treasury is just starting to decide how to handle a transfer pricing regime under a prong of the OECD-led global tax overhaul, a Treasury official said Thursday.
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July 18, 2024
Bank Exec's Tax Tip Case Wrongly Axed, Estate Tells DC Circ.
The estate of a Dutch bank executive asked the D.C. Circuit to overturn a U.S. Tax Court decision denying him a whistleblower award for reporting on tax avoidance schemes, saying the lower court improperly relied on proposed regulations from the Internal Revenue Service.
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July 18, 2024
New IRS Easement Settlements Put Tax Pros In A Pickle
The IRS' new settlement program for partnerships that participated in conservation easements that haven't yet ended up in court comes with terms far sweeter than past offers, making it difficult for practitioners to advise clients to take the deal or wait for a better one.
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July 18, 2024
Tax Pros Say Gov'ts Stretching 'Realistic Alternative' Analysis
Tax authorities including the Internal Revenue Service are overstepping in their use of "realistic alternative" arguments, substituting their own judgment for that of businesses, transfer pricing specialists said Thursday.
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July 18, 2024
Tax Court Affirms IRS Whistleblower Award Computation
The Internal Revenue Service's Whistleblower Office did not abuse its discretion when it set an award at 22% of collected proceeds even though other awards tied to related claims were set at 30%, the U.S. Tax Court said Thursday.
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July 18, 2024
Ex-Venable Trusts And Estates Partner Joins Stradling In LA
Stradling Yocca Carlson & Rauth PC announced that it launched a trusts and estates practice with the hiring of an experienced Los Angeles-based partner from Venable LLP.
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July 18, 2024
Most Top US Cos. To Report Tax Under Aussie Bill, Study Says
Australia's Senate is expected to consider adoption next month of the world's most extensive public country-by-country reporting rules, which would require 51% of large U.S. multinational corporations to disclose tax arrangements retroactively from July 1, according to a study published Thursday.
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July 18, 2024
Final IRS Rules Require Beneficiaries To Take Distributions
Beneficiaries of retirement account owners who died after starting to take distributions must continue taking the distributions annually, the Internal Revenue Service said Thursday in final regulations on required minimum distributions that rejected feedback saying the requirement was overly complex.
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July 18, 2024
Rising Star: Latham's Eric Kamerman
Eric Kamerman of Latham & Watkins LLP in recent years handled the tax aspects of several multibillion-dollar acquisitions of powerhouses in British soccer and American fashion, earning him recognition as one of the tax attorneys under age 40 honored by Law360 as Rising Stars.
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July 18, 2024
IRS Issues Corp. Bond Monthly Yield Curve For July
The Internal Revenue Service published Thursday the corporate bond monthly yield curve for July for use in calculations for defined benefit plans, as well as corresponding segment rates and other related provisions.
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July 18, 2024
Man Can't Annul Agreement To Pay $2M In Taxes, Court Told
A federal district court should force a Florida man to pay the over $2 million in taxes, interest and penalties he owes despite his change of heart about an agreement regarding his deficient filings, the government said.
Expert Analysis
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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.
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Planning A Defense As IRS Kicks Off Sports Losses Campaign
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.
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What New Calif. Strike Force Means For White Collar Crimes
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.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
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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The Legal Industry Needs A Cybersecurity Paradigm Shift
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.
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As Promised, IRS Is Coming For Crypto Tax Evaders
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.
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5 Reasons Associates Shouldn't Take A Job Just For Money
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.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
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.
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Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules
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.