Federal

  • November 12, 2024

    Tax Court Drills Teacher With Frivolous Argument Penalty

    A Georgia high school teacher's claim that roughly $86,000 in income he received didn't qualify as wages was not just incorrect but frivolous, the U.S. Tax Court said Tuesday, upholding the IRS' determination that he owed taxes on that income as well a $25,000 penalty.

  • November 12, 2024

    Broker Calls 78-Month Sentence For Tax Scheme Unfair

    An insurance agent convicted of conspiracy and tax crimes in a multimillion-dollar tax avoidance scheme told a North Carolina federal court ahead of his sentencing, scheduled for Wednesday, that the 78-month prison sentence recommended by prosecutors is harsher than punishments for similar offenders.

  • November 12, 2024

    Treasury To Host Webinar For Beneficial Ownership Info Filing

    The U.S. Treasury Department's Financial Crimes Enforcement Network will host a free webinar Nov. 19 to aid companies that need to file their initial beneficial ownership information under the Corporate Transparency Act by the start of 2025.

  • November 08, 2024

    Disaster Tax Relief Could Be On Slate In Lame-Duck Session

    Congress returns to Washington, D.C., on Tuesday following former President Donald Trump's reelection, and while lawmakers will likely be gearing up for next year's tax negotiations, there are some tax policies that could pass during the lame-duck session, including disaster tax relief.

  • November 08, 2024

    9th Circ. Says Univ. Wrongly Deprived Of Tax-Exempt Status

    The Ninth Circuit on Friday reversed a decision by an Arizona district court backing the U.S. Department of Education's determination that the privately owned Grand Canyon University didn't qualify as a nonprofit institution for classification related to federal loan and grant programs.

  • November 08, 2024

    Career Butler Snow Attorney Joins Holland & Knight In NYC

    Holland & Knight LLP has hired a transactional attorney who focuses her practice on new markets tax credits and other financial matters, and who spent her entire career up to now with Butler Snow LLP, the firm announced Thursday.

  • November 08, 2024

    Shutts & Bowen Adds Complex Taxation Pro In Sarasota

    Shutts & Bowen LLP has brought on a new partner at the firm's growing Sarasota, Florida, office, bringing close to 20 years of private practice tax law experience to the firm's private client services practice group.

  • November 08, 2024

    Nixon Peabody Helps Boston Supportive Housing Land $153M

    A Boston housing development nonprofit, with guidance from Nixon Peabody LLP, obtained $153 million in financing to develop a 19-story, 126-unit supportive housing project in the city, the law firm announced.

  • November 08, 2024

    Ex-Spouse Entitled To $2.9M Pandemic Tax Refund, Court Told

    A woman is entitled to a $2.9 million tax refund under pandemic-era relief provisions for carryback losses shared with her ex-husband, she told a Texas federal court, accusing the Internal Revenue Service of wrongly requiring both of the former couple's signatures on a consent form.

  • November 08, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included registration guidance for manufacturers of energy efficiency improvement products that qualify for a homeowner tax credit.

  • November 07, 2024

    Vanguard Investors Ink $40M Settlement In Tax Liability Suit

    Vanguard investors have asked a Pennsylvania federal judge to give the first green light to a $40 million settlement reached with the firm over it allegedly breaching its fiduciary duty when it triggered a sell-off of assets that left investors with massive tax bills.

  • November 07, 2024

    Danish Gov't Can't Exclude 2012 Evidence In $2B Tax Case

    A New York federal judge allowed U.S. pension plans to present a Danish firm's 2012 opinion as key evidence in an upcoming trial in the Danish government's $2 billion tax fraud case against them, but barred three other pieces of evidence.

  • November 07, 2024

    Trial Needed In Texas Co.'s $3.5M Dispute, Tax Court Says

    There are too many factual disputes between the Internal Revenue Service and a Texas holding company regarding a determination that it owed nearly $2.9 million in deficient taxes plus $622,000 in penalties, and a trial will be needed to resolve them, the U.S. Tax Court said Thursday.

  • November 07, 2024

    Varian Not Relevant In Liberty Global Case, US Tells 10th Circ.

    A U.S. Tax Court decision that granted medical device company Varian Medical Systems a deduction for dividends received from foreign subsidiaries does not support Liberty Global's claims to a $110 million tax refund, the federal government told the Tenth Circuit on Thursday.

  • November 07, 2024

    IRS Reports Collecting Over $5.1T In Revenue In FY 2024

    The Internal Revenue Service collected more than $5.1 trillion in tax revenue and over $98 billion in enforcement revenue in fiscal year 2024, the agency announced Thursday.

  • November 07, 2024

    Ex-Cop, Brother Admit Energy Contract Kickback Scheme

    A former Massachusetts police officer and his electrician brother pled guilty Wednesday to paying off employees of a utility ratepayer-funded energy savings program administrator who steered $36 million in contracts their way, federal prosecutors said Thursday.

  • November 07, 2024

    Transparency Act Should Exclude Housing Co-Ops, Court Told

    A group of housing cooperatives asked a Michigan federal judge to grant them an exemption from the "dragnet" Corporate Transparency Act, claiming the disclosure requirements will deter members from serving on boards that govern affordable housing developments.

  • November 07, 2024

    Gov't Gets Default In $4.9M Son-Of-Boss Case

    A federal judge entered a $4.9 million default against the estate of a Michigan man and his widow after having threatened to dismiss the case, in which the government says the couple avoided taxes by participating in a Son-of-Boss scheme.

  • November 07, 2024

    Judge Finds No Fraud By IRS In FOIA Fight Over $18M Case

    The widow of a man whose offshore businesses were raided by the IRS, giving rise to a nearly $18 million tax judgment, didn't prove the IRS committed fraud against the court in ensuing Freedom of Information Act litigation in which the agency claimed evidence was lost, a D.C. federal court ruled.

  • November 07, 2024

    IRS To Hold Hearing On Dual Consolidated Loss Regs

    The Internal Revenue Service plans to hold a public hearing Nov. 22 on proposed regulations that outline when foreign taxes under the Pillar Two international minimum tax agreement could trigger U.S. rules that aim to prevent companies from double-dipping the same economic loss.

  • November 06, 2024

    Chicago Pol Urges Narrow Reading Of False Statement Law

    The U.S. Supreme Court should narrowly interpret the federal statute barring people from using false statements to influence certain financial institutions because backing the government's broad reading could expose borrowers to criminal liability that was never intended, former Chicago alderman Patrick Daley Thompson argued Wednesday.

  • November 06, 2024

    After Electoral Defeats, Cannabis Advocates Eye Next Steps

    Cannabis industry advocates and reform activists struck a note of cautious optimism Wednesday following an expected Republican electoral sweep of the federal government, while opponents of legalization touted the defeat of multiple statewide ballot measures as proof of their position that marijuana reform efforts were losing support.

  • November 06, 2024

    Finance Committee Helm Awaits Crapo After GOP Wins Senate

    Idaho Republican Mike Crapo is expected to lead the Senate Finance Committee when Congress convenes next year, following President-elect Donald Trump's win Tuesday in the election that also handed Republicans control of the U.S. Senate for the first time since 2021.

  • November 06, 2024

    Feds Look To Halt Vitamin Co. Payouts Amid $1.4M Tax Fight

    A couple who bought a vitamin supplement company shouldn't continue to get payments from the business amid a suit claiming they're liable for a previous owner's $1.4 million tax lien, the U.S. Department of Justice told a Connecticut federal court Wednesday.

  • November 06, 2024

    Atty Failed To Prove Theft Loss, Tax Court Says

    An attorney is not entitled to deduct a theft loss for his legal expenses after a company he managed was sued for fraud, the U.S. Tax Court ruled Wednesday, sustaining the Internal Revenue Service's determination that he owed taxes and penalties.

Expert Analysis

  • Geothermal Energy Has Growing Potential In The US

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    Bipartisan support for the geothermal industry shows that geothermal energy can be an elegant solution toward global decarbonization efforts because of its small footprint, low supply chain risk, and potential to draw on the skills of existing highly specialized oil and gas workers and renewable specialists, say attorneys at Weil.

  • Exploring An Alternative Model Of Litigation Finance

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    A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.

  • Trump Hush Money Case Offers Master Class In Trial Strategy

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    The New York criminal hush money trial of former President Donald Trump typifies some of the greatest challenges that lawyers face in crafting persuasive presentations, providing lessons on how to handle bad facts, craft a simple story that withstands attack, and cross-examine with that story in mind, says Luke Andrews at Poole Huffman.

  • A Vision For Economic Clerkships In The Legal System

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    As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.

  • State-Regulated Cannabis Can Thrive Without Section 280E

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    Marijauna's reclassification as a Schedule III-controlled substance comes at a critical juncture, as removing marijuana from being subjected to Section 280E of the Internal Revenue Code is the only path forward for the state-regulated cannabis industry to survive and thrive, say Andrew Kline at Perkins Coie and Sammy Markland at FTI Consulting.

  • Asset Manager Exemption Shifts May Prove Too Burdensome

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    The U.S. Department of Labor’s recent change to a prohibited transaction exemption used by retirement plan asset managers introduces a host of new costs, burdens and risks to investment firms, from registration requirements to new transition periods, say attorneys at Simpson Thacher.

  • A Look At New IRS Rules For Domestically Controlled REITs

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    The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.

  • E-Discovery Quarterly: Recent Rulings On Text Message Data

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    Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.

  • Should NIL Collectives Be Allowed Tax-Favored Status?

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    Arguments are being made for and against allowing organizations to provide charitable contribution tax deductions for donations used to compensate student-athletes, a practice with impacts on competition for student-athletes and overall tax fairness, but ultimately it is a question for Congress, say Andres Castillo and Barry Gogel at the University of Maryland School of Law.

  • Understanding The IRC's Excessive Refund Claim Penalty

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    Taxpayers considering protective refund claims pending resolution of major questions in tax cases like Moore v. U.S., which is pending before the U.S. Supreme Court, should understand how doing so may also leave them vulnerable to an excessive refund claim penalty under Internal Revenue Code Section 6676, say attorneys at McDermott.

  • Don't Use The Same Template For Every Client Alert

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    As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

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    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

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    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.

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