Federal
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June 25, 2024
US Needs To Broaden Tax Base, Increase Rates, OECD Says
The United States' debt-to-gross-domestic-product ratio is the highest it's been since World War II, necessitating a wide range of tax changes to both expand the tax base and increase rates to alleviate fiscal pressures, the OECD said Tuesday.
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June 25, 2024
Tax Court Says Missed Deadline Doesn't Sink Its Jurisdiction
A jewelry company's one-day-late filing of a petition for reconsideration of an employment tax determination does not deprive the U.S. Tax Court of jurisdiction in the case, the court said Tuesday, denying the IRS' attempt to get the case tossed.
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June 25, 2024
Pension Plans Can't Escape $2B Danish Tax Fraud Dispute
Two U.S. pension plans made an "extremely strained" contention that Denmark's tax administrator waited too long to accuse them of participating in a $2.1 billion fraud scheme, a New York federal judge said in declining to toss the case.
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June 25, 2024
Ex-DOJ Atty Among New Trio At Chamberlain Hrdlicka
Chamberlain Hrdlicka White Williams & Aughtry has strengthened its tax controversy and litigation practice with the addition of three attorneys in Atlanta, including a former senior trial attorney in the Tax Division of the U.S. Department of Justice for more than three decades.
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June 25, 2024
IRS Apologizes To Hedge Fund Founder Over Leaked Tax Data
The IRS issued an extraordinary public apology Tuesday to hedge fund founder and billionaire Ken Griffin for the leak of his and others' tax information to the media by a former contractor who admitted to stealing the returns of thousands of wealthy individuals, including former President Donald Trump.
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June 25, 2024
House Bill Seeks 95% Windfall Tax On Excessive Profits
Large corporations would face a 95% windfall tax on excessive profits under legislation reintroduced in the House.
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June 25, 2024
Tax Pros Worry Credit Sales Could Raise Substance Issues
Tax professionals are concerned that deals involving a new way to sell clean energy tax credits for cash could face IRS scrutiny after the agency scored a high-profile win over a telecommunications company by deploying an aggressive interpretation of what's known as the economic substance doctrine.
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June 25, 2024
J&J Counsel Urges OECD To Ease Burdens Of Global Min. Tax
Counsel for Johnson & Johnson on Tuesday urged the OECD and government officials working on the Pillar Two global minimum corporate tax to consider more permanent safe harbor provisions to reduce the compliance burdens associated with the levy.
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June 25, 2024
Global Tax Overhaul Won't Squash Competition, US Rep. Says
The global tax overhaul designed by the Organization for Economic Cooperation and Development won't eliminate countries competing for companies' investments, a U.S. House lawmaker said Tuesday.
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June 25, 2024
Fla. Construction Co. Says It's Owed $4M In Worker Credits
A road construction company in Chapter 7 bankruptcy proceedings asked a Florida federal court to force the IRS to give it nearly $4 million in tax refunds for pandemic-era employee retention credits that its bankruptcy trustee determined it was eligible to receive.
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June 24, 2024
Billionaire Drops Case Against IRS Over Tax Info Leak
Billionaire hedge fund founder Ken Griffin dropped his case Monday seeking to hold the IRS accountable for the leak of his tax return information in a data breach that affected thousands of wealthy and powerful taxpayers, including former President Donald Trump.
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June 24, 2024
Tax Court Rejects Collection Appeal Over Amended Return
An IRS agent did not abuse his discretion when he didn't consider a supposed amended tax return that a Rhode Island woman said would lower her tax liability and therefore a proposed installment agreement amount, the U.S. Tax Court said Monday.
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June 24, 2024
Illinois, Other States Back FTC Bid To Affirm Intuit Ad Ruling
Illinois, along with 20 other states and the District of Columbia, defended the Federal Trade Commission in tax software giant Intuit's Fifth Circuit constitutional challenge to the agency's findings that the company engaged in deceptive advertising, saying in an amicus brief that the FTC's conclusion was correct.
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June 24, 2024
Ex-Chicago Alderman Gets Two Years For Boosting Law Firm
An Illinois federal judge on Monday sentenced former Chicago Alderman Ed Burke to two years in prison and fined him $2 million for using his official position to steer tax business to his personal law firm, closing what prosecutors called "another sordid chapter" in the city's history of public corruption.
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June 24, 2024
Better Digital Tax Ban In Pillar 1 Treaty, Treasury Official Says
The final text of a multilateral convention to implement the OECD-designed taxing rights overhaul will include improved language to eliminate existing digital services tax and prohibit prospective ones, a U.S. Treasury Department official said Monday.
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June 24, 2024
Tax Preparers Win Recommendation For Class Cert. In OT Suit
A group of tax preparers have met the requirements to form a class in a suit accusing their former employer of failing to pay overtime, a New York federal magistrate judge said, rejecting the employer's argument that their request for class status came too late.
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June 24, 2024
IRS Finalizes Limits To Partnership Conservation Easements
The Internal Revenue Service finalized rules Monday that curb the conservation easement tax deduction claimed by certain partnerships, with some changes to last year's proposed version, such as limiting the opportunity for entities to adjust their tax returns to avoid the new restrictions.
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June 24, 2024
Loss Guidance Will Cover Pillar 2, IRS Official Says
Forthcoming guidance to address U.S. tax issues with dual consolidated losses will also include language advising taxpayers how to account for those losses under the Pillar Two global minimum tax, the IRS' top international tax counsel said Monday.
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June 24, 2024
NJ Tax Evader's Wife Owes IRS, Too, Tax Court Rules
A New Jersey woman owes more than $125,000 in taxes jointly with her husband, the U.S. Tax Court ruled Monday, saying she should have questioned the returns her husband prepared for her signature after he pled guilty to tax evasion and bribery.
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June 24, 2024
Julie Chrisley To Be Resentenced, But Convictions Stand
The Eleventh Circuit on Friday upheld the tax evasion and fraud convictions of former reality TV stars Todd and Julie Chrisley, but ordered a Georgia federal judge to resentence Julie Chrisley after finding that the judge failed to fully explore her discrete role in the $36 million scheme.
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June 24, 2024
Supreme Court Won't Review Tax Challenge Deadline
The U.S. Supreme Court declined Monday to review a Third Circuit finding that the U.S. Tax Court's 90-day deadline for filing challenges to tax bills isn't hard and fast.
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June 24, 2024
4th Circ. Affirms Nix Of $1.2M R&D Credit For Biotech Co.
A biotechnology company that claimed tax credits for increasing its scientific research was correctly denied about $1.2 million of its request, the Fourth Circuit ruled Monday in upholding a U.S. Tax Court decision that found the company was wrongly counting research expenses twice.
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June 24, 2024
IRS Assessment Of $10M Earner Audits Faulty, TIGTA Says
The Internal Revenue Service says it is rolling back its audits of returns claiming at least $10 million in income because it found them unproductive, but the Treasury Inspector General for Tax Administration said Monday that that is not true in every case.
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June 24, 2024
OECD Tax Plan Issues Still Being Hashed Out, US Official Says
Both the global minimum corporate tax and taxing rights overhaul plans designed by the Organization for Economic Cooperation and Development have outstanding issues that stakeholders are attempting to resolve, a U.S. Treasury Department official said at a conference Monday.
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June 24, 2024
Justices To Review If Ch. 7 Trustee Can Recover Tax Payments
The U.S. Supreme Court said Monday it would review a Tenth Circuit decision that found that the Chapter 7 bankruptcy trustee of a defunct Utah company could recover $145,000 in tax payments from the IRS.
Expert Analysis
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Tips For Litigating Against Pro Se Parties In Complex Disputes
Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.
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Anticipating Intensified Partnership Enforcement From IRS
The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.
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Pro Bono Work Is Powerful Self-Help For Attorneys
Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.
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The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'
The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.
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Newman Suspension Shows Need For Judicial Reform
The recent suspension of U.S. Circuit Judge Pauline Newman following her alleged refusal to participate in a disability inquiry reveals the need for judicial misconduct reforms to ensure that judges step down when they can no longer serve effectively, says Aliza Shatzman at The Legal Accountability Project.
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How And Why Your Firm Should Implement Fixed-Fee Billing
Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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How Law Firms Can Use Account-Based Marketing Strategies
Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.
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While Risks Exist, AI Could Transform IRS Enforcement
The Internal Revenue Service's recently announced use of artificial intelligence could revolutionize the agency's enforcement efforts, and transparency about its use and a forum for challenging AI findings could help mitigate fears that the technology will increase bias, say attorneys at Lewis Brisbois.
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Strategic Succession Planning At Law Firms Is Crucial
Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.
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Maximizing Law Firm Profitability In Uncertain Times
As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.
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Enforcement Of International Tax Reporting Is Heating Up
Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.
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How Gov't Agencies Will Fare In The Event Of A Shutdown
With a federal shutdown potentially set to begin at the end of this month, it may be useful to consider the approximate timelines that agencies such as the Federal Trade Commission and IRS have announced for curtailing operations, and potential strategies for mitigating challenges that may arise while agency functions are limited, say attorneys at Cleary.
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IRS Notice Clarifies R&E Amortization, But Questions Remain
The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.