Federal

  • December 10, 2024

    Morgan Lewis Gets DLA Piper Tax Pro With DOJ Experience

    Morgan Lewis & Bockius LLP announced that it has added to its Boston office a tax attorney from DLA Piper who served as an appellate attorney at the U.S. Department of Justice, Tax Division.

  • December 10, 2024

    Biz Owner In $2.8M Worker Tax Scheme Gets 18 Months

    A construction company owner who failed to pay $2.8 million in employment taxes by falsely claiming his workers were subcontractors was sentenced to 18 months in prison Tuesday and ordered to pay full restitution, according to Massachusetts federal court documents.

  • December 10, 2024

    FBAR Default Against Widow Should Be Vacated, Judge Says

    A New York federal magistrate judge recommended vacating a default judgment against a widow, which would give her a second chance to defend her dead husband's estate against U.S. government claims that it owes $275,000 for his failure to report his account at an Indian bank.

  • December 10, 2024

    Tax Court Nixes Overpayment Refunds In Tolling Row

    A Florida man was correctly denied a pair of tax overpayment refunds that totaled roughly $88,000 because the statutes covering his claims are not governed by equitable tolling rules, the U.S. Tax Court said Tuesday.

  • December 10, 2024

    9th Circ. Nixes Tax Deductions For Disbarred Calif. Attorney

    A California attorney who fought with his neighbors in court cannot take business deductions for the cost of challenging his disbarment and a court's declaration that he is a "vexatious litigant," the Ninth Circuit said Tuesday, upholding a ruling from the U.S. Tax Court.

  • December 10, 2024

    Exxon's Tax Win Sets Path For Liberty Global, 10th Circ. Told

    A ruling allowing Exxon Mobil a U.S. tax deduction for interest expenses in its natural gas deal with Qatar confirms that Liberty Global is entitled to a deduction related to its sale of a Belgian affiliate, an attorney for the telecommunications company told the Tenth Circuit.

  • December 10, 2024

    Soft Landing For Pilot As Billionaire's Insider Case Wraps

    A pilot who admitted to dodging taxes on $500,000 in income after he was accused of taking stock tips from Joe Lewis, his billionaire boss, avoided prison on Tuesday at a sentencing that closed a high-profile insider trading prosecution.

  • December 10, 2024

    Treasury Finalizes Simplified Foreign Currency Rules

    The U.S. Treasury Department finalized regulations Tuesday that aim to simplify aspects of how corporations determine taxable income or loss with respect to certain affiliates that conduct business in a foreign currency.

  • December 09, 2024

    10th Circ. Affirms Nix Of Atty's Racing Expense Deductions

    The Tenth Circuit affirmed Monday the U.S. Tax Court's determination that a Denver personal injury lawyer shouldn't be allowed to deduct about $300,000 for his car racing-related costs as advertising, despite his claims that his races helped him drum up business.

  • December 09, 2024

    Tax Court Lowers Car Dealership Owner's $4.7M Deficiency

    The U.S. Tax Court sided with the owner of a now-shuttered used car dealership Monday in allowing him to deduct certain business expenses, which reduced the IRS' combined $4.7 million assessment of underreported income over a four-year period.

  • December 09, 2024

    US Investment Cos. Benefit In Updated Norway Tax Treaty

    Regulated U.S. investment and holding companies should be able to reap Norwegian tax treaty benefits on dividends, royalties and capital gains without restriction under an updated agreement announced Monday by the Internal Revenue Service.

  • December 09, 2024

    Woman Appeals Tax Court's Canadian Debt Ruling To 9th Circ.

    A woman appealed to the Ninth Circuit a U.S. Tax Court decision that prevented her from challenging a federal tax lien issued by the Internal Revenue Service to secure her $200,000 tax debt to Canada on behalf of the Canadian government. 

  • December 09, 2024

    Chicago Pol's Lies Enough To Keep Conviction, Feds Say

    The government urged the U.S. Supreme Court not to disturb a former Chicago alderman's conviction for lying about money he'd borrowed from a since-shuttered bank, arguing his knowing understatements were enough to illegally mislead federal investigators.

  • December 09, 2024

    Man Owed $264K Under US-Canada Tax Treaty, Court Says

    A U.S. man living abroad is allowed under the U.S.-Canada tax treaty to claim a foreign tax credit for nearly $264,000 in payments of the Affordable Care Act's net investment income tax, the Federal Claims Court said.

  • December 09, 2024

    Feds Seek 2-Year Sentence In Landmark Crypto Tax Case

    The first person ever criminally charged for failing to report gains from the sale of cryptocurrency by filing false returns should be sentenced to more than two years in prison after he admitted underreporting $4 million in bitcoin proceeds, prosecutors told a Texas federal court.

  • December 06, 2024

    DC Circ. Affirms Man's $1.2M 'Seriously Delinquent' Tax Debt

    A Florida man owes more than $1.2 million in federal taxes, the D.C. Circuit said Friday, affirming the Internal Revenue Service's certification of his liability under a law that allows those with a "seriously delinquent" tax debt to have their passport revoked.

  • December 06, 2024

    Trust Distribution Doesn't Violate Holding Law, IRS Says

    A distribution from a trust of tenancy-in-common interests that resulted from the trust's involuntary termination will not prevent the interests from being held for certain investment and business purposes, the IRS said in a private letter ruling released Friday.

  • December 06, 2024

    Gov't Appeals Texas Judge's Block On Anti-Laundering Law

    The U.S. government has appealed a Texas federal judge's order that halted the rollout of new reporting requirements aimed at unmasking anonymous shell companies, setting the stage for the Fifth Circuit to weigh in on the nationwide preliminary injunction.

  • December 06, 2024

    Simpson Thacher Adds Tax Pro From Ropes & Gray

    Simpson Thacher & Bartlett LLP announced the firm has added a tax professional from Ropes & Gray LLP as a partner in its Washington, D.C., office.

  • December 06, 2024

    Biz Owner In $2.8M Worker Tax Scheme Asks To Avoid Prison

    A construction company owner who admitted skirting $2.8 million in employment taxes by claiming that his workers were subcontractors, including one who fell to his death on a job, asked a Massachusetts federal court Friday for a sentence of home confinement rather than prison.

  • December 06, 2024

    Taxation With Representation: Skadden, Gibson Dunn

    In this week's Taxation With Representation, BlackRock buys HPS Investment Partners, TreeHouse Foods Inc. buys Harris Tea, Aya Healthcare acquires Cross Country Healthcare, and Bruin Capital launches a soccer representation business.

  • December 06, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included regulations aimed at making it easier for tax-exempt entities that co-own development projects to qualify for a direct cash payment of clean energy tax credits by electing out of their partnership tax status.

  • December 05, 2024

    IRS Pick's Retention Credit History Raises Sens.' Hackles

    As senators digested President-elect Donald Trump's nomination of a former U.S. House member to be commissioner of the Internal Revenue Service, some Democrats said the nominee's experience promoting problematic employee retention credits immediately raised questions about his fitness to run the agency.

  • December 05, 2024

    11th Circ. Won't Rethink $100M Credit For John Hancock

    The Eleventh Circuit won't reconsider its decision to let John Hancock Life Insurance Co. keep $100 million in foreign tax credits, leaving in place its October ruling against a Florida law firm retirement plan's trustees.

  • December 05, 2024

    Tax Court Penalizes Mail Carrier For Frivolous Returns

    A retired U.S. Postal Service carrier from Texas owes $10,000 in civil penalties for making frivolous claims that his income wasn't subject to taxes because he wasn't a federal employee, the U.S. Tax Court ruled in a bench opinion released Thursday.

Expert Analysis

  • 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.

  • Lessons From Country Singer's Personal Service Saga

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    Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.

  • 5 Litigation Funding Trends To Note In 2024

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    Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.

  • Tech CEO Tax Ruling A Warning For Forward Contracts

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    In McKelvey v. Commissioner, the U.S. Tax Court decided that deceased Monster.com founder Andrew McKelvey terminated his underlying obligations when he extended variable prepaid forward contracts, demonstrating why startup founders, early employees and investors should think carefully before amending derivative agreements, say Daren Shaver and Trent Tanzi at Hanson Bridgett.

  • 4 Legal Ethics Considerations For The New Year

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    As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.

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