Federal
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August 09, 2024
IRS Direct File To Be Offered In Connecticut Next Year
The Internal Revenue Service's free electronic tax filing program known as Direct File will be available in Connecticut for the 2025 tax filing season, the agency and the U.S. Department of the Treasury announced Friday.
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August 09, 2024
7 Taxpayer Advocacy Panel Committees To Meet In September
Seven Taxpayer Advocacy Panel committees will meet in September to discuss possible improvements to customer services, the Internal Revenue Service said Friday.
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August 09, 2024
IRS Updates Digital Asset Form For Custodial Brokers
The Internal Revenue Service released a revised draft form Friday for brokers to report their digital asset sales, which reflects the treatment of custodial industry participants in final regulations and the transitional relief for filers that fail to report the transactions.
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August 09, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included final regulations that clarify potential situations that could trigger an anti-abuse rule that covers transactions involving foreign corporations.
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August 09, 2024
What Books Tax Pros Recommend For This Summer
As practitioners monitor the tax implications of the U.S. presidential election as well as what might come out of the next European Commission, they may want to take a break with a good book. Here, Law360 takes a look at tax specialists' summer reading recommendations.
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August 09, 2024
Taxation With Representation: Latham, Freshfields, Wachtell
In this week's Taxation With Representation, Quantum Capital Group agrees to a roughly $3 billion deal for Cogentrix Energy, Apax Partners LLP is acquiring Thoughtworks for roughly $1.75 billion, and Mallinckrodt inks a $925 million deal for Therakos.
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August 08, 2024
Cayman Co. Owes Tax On Partners' Income, Tax Court Says
A Cayman Islands partnership is liable for withholding taxes on the share of about $24.8 million in income from its U.S. operations that was allocated to its foreign partners through special purpose vehicles, the U.S. Tax Court said Thursday.
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August 08, 2024
IRS Agents Seek To Join Hunter Biden's Tax Privacy Case
Accusations of wrongdoing against two Internal Revenue Service whistleblowers who said the government downplayed tax fraud allegations against Hunter Biden give the pair standing to intervene in Biden's privacy case against the U.S. government, the men told a federal court.
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August 08, 2024
Feds Seek 2 Years For Accountant In $8M Payroll Tax Scheme
A New Jersey moving company's head accountant should serve a two-year sentence for being the "nerve center" of a nearly $8 million payroll tax scheme, prosecutors told a New York federal judge in a bid to deny the man's request for a noncustodial sentence.
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August 08, 2024
IRS Targeting Up To $5B In Employee Retention Credit Claims
The Internal Revenue Service in recent weeks sent 28,000 rejection letters to businesses to target high-risk employee retention tax credits that could prevent up to $5 billion in improper credit claims, Commissioner Daniel Werfel said Thursday.
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August 08, 2024
5th Circ. Asked To Back Dell Worker's Penalty For Tax Protest
The Fifth Circuit should uphold a U.S. Tax Court ruling that found a Texas man was required to pay income taxes on nearly $300,000 worth of wages he earned from Dell and a penalty for advancing frivolous arguments, the government said Thursday.
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August 08, 2024
Nixon Peabody Hires Community Development Counsel In DC
When Steven Feenstra, the newest member of Nixon Peabody LLP's the community development finance practice, visited a client's office some 25 years ago, the photos of the community housing projects the client had helped develop made a lasting impression on him, he told Law360 Pulse in an interview Thursday.
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August 08, 2024
Cabinet Cos. Say They're Owed $1.35M In Retention Credits
The Internal Revenue Service owes a pair of Arizona-based cabinet manufacturers that operate as a single employer nearly $1.35 million in employee retention tax credits, the companies told an Arizona federal court, adding that the agency has failed to even respond to their claims.
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August 08, 2024
Colo. Couple Settle $3.4M Hardship Refund Case
A Colorado couple hit by a series of economic and personal hardships have reached a settlement with the federal government that will grant the couple a portion of the $3.4 million refund they sought and resolve their case, the two sides told a Colorado federal court.
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August 08, 2024
US Asks 2nd Circ. To Uphold IRS Lien For $4.2M Restitution
The Internal Revenue Service should be allowed to proceed with a lien to collect some $4.2 million in restitution from a man who pled guilty to three counts of tax fraud, the U.S. told the Second Circuit.
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August 07, 2024
Weak Link Doomed $690M Whistleblower Claim, DC Circ. Says
A whistleblower could not get up to $690 million, or 30% of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program, because the connection between his actions and the program was weak, the D.C. Circuit said Wednesday.
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August 07, 2024
Waste Co. Not Entitled To Audit Records, IRS Tells Court
Garbage-hauling giant Waste Management Inc. is not entitled to the IRS' tax files on the company from 2017, including audit records, because some documents contain return information of third parties, the agency said Wednesday.
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August 07, 2024
5th Circ. Grapples With 'Ridiculous' $100M Arbitration
A Fifth Circuit panel struggled to make sense out of a "ridiculous" arbitration proceeding that produced four contradictory arbitration awards in a legal malpractice dispute, one awarding $100 million, pressing both sides during oral arguments Wednesday to give answers about how the "spectacle" unfolded.
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August 07, 2024
'Looting' Of Co. Doesn't End S Corp. Status, Tax Court Says
While a co-owner of a California S corporation may have been the victim of two other owners "looting" the company through disproportionate distributions, such actions didn't dissolve its S corporation status, the U.S. Tax Court ruled Wednesday.
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August 07, 2024
Pension Plans' Expert Testimony Limited In $2B Tax Fraud Suit
A New York federal court decided to exclude portions of an expert's testimony on behalf of pension plans that are accused of seeking to defraud Denmark's tax agency in a $2.1 billion tax refund fraud scheme.
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August 07, 2024
Tax Court's Economic Substance Foray May Clarify Limits
A U.S. Tax Court judge plans to address an ill-defined provision governing the relevance of the economic substance doctrine in a microcaptive insurance case, offering the courts another chance to clarify an anti-abuse tool the IRS has been deploying more often.
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August 07, 2024
US Taxpayers Claimed $8.4B In Energy Credits In 2023
Taxpayers claimed $6.3 billion is residential clean energy credits and $2.1 billion in energy-efficient home improvement credits in 2023, the U.S. Treasury Department and Internal Revenue Service said Wednesday.
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August 06, 2024
US Wants Israeli Businessman Sanctioned In $3.6M FBAR Suit
An Israeli businessman should be sanctioned for defying a Washington federal court's discovery orders by a default judgment in the U.S. government's $3.6 million case over his unreported foreign bank accounts and by another order to comply, the government said Tuesday.
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August 06, 2024
Wind Tower Co. Asks Full Fed. Circ. To Revisit Subsidy Duties
A Federal Circuit panel wrongly concluded that a 10% depreciation rate for deducting costs related to manufacturing facilities set by Canadian law was an unfair trade subsidy that justified countervailing trade duties, a wind tower manufacturer told the court in seeking a rehearing.
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August 06, 2024
Businessman Found To Owe Over $2.9M In FBAR Fines
A U.S. inventor and businessman who had been based in Hong Kong and started a company there must pay over $2.9 million in penalties for failing to report his overseas bank accounts for eight years, a Virginia federal judge ruled Tuesday.
Expert Analysis
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3 Ways Agencies Will Keep Making Law After Chevron
The U.S. Supreme Court clearly thinks it has done something big in overturning the Chevron precedent that had given deference to agencies' statutory interpretations, but regulated parties have to consider how agencies retain significant power to shape the law and its meaning, say attorneys at K&L Gates.
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Atty Well-Being Efforts Ignore Root Causes Of The Problem
The legal industry is engaged in a critical conversation about lawyers' mental health, but current attorney well-being programs primarily focus on helping lawyers cope with the stress of excessive workloads, instead of examining whether this work culture is even fundamentally compatible with lawyer well-being, says Jonathan Baum at Avenir Guild.
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Tracking Implementation Of IRA Programs As Election Nears
As the Biden administration races to cement key regulations implementing the Inflation Reduction Act, a number of the law's programs and incentives are at risk of delay or repeal if Republicans retake control of Congress, the White House or both — so stakeholders should closely watch ongoing IRA implementation and guidance, say attorneys at Squire Patton.
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Unpacking The Circuit Split Over A Federal Atty Fee Rule
Federal circuit courts that have addressed Rule 41(d) of the Federal Rules of Civil Procedure are split as to whether attorney fees are included as part of the costs of a previously dismissed action, so practitioners aiming to recover or avoid fees should tailor arguments to the appropriate court, says Joseph Myles and Lionel Lavenue at Finnegan.
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Takeaways From Justices' Redemption Insurance Decision
The U.S. Supreme Court’s recent decision in Connelly v. U.S. examines how to determine the fair market value of shares in a closely held company for estate tax purposes, and clarifies how life insurance held by the company to enable redemption of a decedent’s shares affects that calculation, says Evelyn Haralampu at Burns & Levinson.
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6 Tips For Maximizing After-Tax Returns In Private M&A Deals
With potential tax legislation likely to spur a surge in private business sales, sellers can make the most of after-tax proceeds with strategies that include price allocation and qualified investment options, say Isaac Grossman and Daniel Studin at Morrison Cohen.
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After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1
The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.
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Recruitment Trends In Emerging Law Firm Frontiers
BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.
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What DOL Fiduciary Rule Means For Private Fund Managers
Attorneys at Ropes & Gray discuss how the U.S. Department of Labor's recently released final fiduciary rule, which revises the agency's 1975 regulation, could potentially cause private fund managers' current marketing practices and communications to be considered fiduciary advice, and therefore subject them to strict prohibitions.
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Money, Money, Money: Limiting White Collar Wealth Evidence
As courts increasingly recognize that allowing unfettered evidence of wealth could prejudice a jury against a defendant, white collar defense counsel should consider several avenues for excluding visual evidence of a lavish lifestyle at trial, says Jonathan Porter at Husch Blackwell.
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How Associates Can Build A Professional Image
As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.
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Navigating New Safe Harbor For Domestic Content Tax Credits
The U.S. Department of the Treasury’s recent notice simplifying domestic content calculations for certain solar, onshore wind and battery storage projects, which directly acknowledges the difficulty for taxpayers in gathering data to support a domestic content analysis, should make it easier to qualify additional domestic content bonus tax credits, say attorneys at A&O Shearman.
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Firms Must Rethink How They Train New Lawyers In AI Age
As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.