Federal

  • November 05, 2024

    11th Circ. Says IRS Summons Doesn't Violate 5th Amendment

    A Florida federal court didn't err when it upheld an Internal Revenue Service summons, the Eleventh Circuit said, saying it was unconvinced by a taxpayer's argument that the summons violated his Fifth Amendment rights against self-incrimination.

  • November 05, 2024

    CPA Group Urges IRS To Promote Digital Asset Basis Relief

    The U.S. Treasury Department and Internal Revenue Service should promote a safe harbor for taxpayers that plan to allocate the unused basis of their digital assets before a Jan. 1 deadline for using the relief, a certified public accountants group said in a letter released Tuesday.

  • November 05, 2024

    Crypto Council Seeks Delay In Digital Asset Broker Regs

    The IRS should delay the effective date of a requirement in the digital assets broker regulations that calls for identifying units of the assets in the broker's custody until the agency clarifies the provision, a global council of cryptocurrency companies said in a letter released Tuesday.

  • November 05, 2024

    2nd Circ. Urged To Rethink Dual Citizen's FBAR Penalties

    A dual U.S.-French citizen found liable for tax penalties by the Second Circuit for hiding millions of dollars in foreign accounts asked the court Tuesday to reconsider, saying American authorities demanded she participate in a deposition that would have put her in legal jeopardy abroad.

  • November 05, 2024

    On The Ground: How Attorneys Safeguarded The Election

    Attorneys worked tirelessly Tuesday to support citizens and election workers on the final day of voting in one of history's most contentious presidential contests.

  • November 04, 2024

    'Oh, Come On': 5th Circ. Doubts Intuit Ads Misled Consumers

    The Fifth Circuit on Monday seemed skeptical that the company behind TurboTax duped customers into thinking they could file their tax returns for free, with judges engaging in a lengthy back-and-forth with the Federal Trade Commission over how noticeable disclosures on the ads had to be for the agency to consider them truthful.

  • November 04, 2024

    2nd Circ. Rejects Man's Challenge To IRS Lien For $4.2M

    The U.S. Tax Court correctly found that the IRS appeals office didn't abuse its powers by approving the agency's federal tax lien to collect $4.2 million from a man with a court-ordered payment plan, the Second Circuit said.

  • November 04, 2024

    Ga. Tax Preparer Gets 28 Months In $5M Tax Scheme

    A Georgia accountant was sentenced to more than two years in prison for his role in promoting syndicated conservation easements that resulted in a $5 million tax loss to the Internal Revenue Service, the U.S. Department of Justice announced.

  • November 04, 2024

    US Must Pay Legal Fees To Challenger Of IRS Guidance

    A Michigan federal judge ordered the U.S. to pay roughly $220,000 in attorney fees to a construction company that won its challenge to Internal Revenue Service penalties and overturned underlying agency guidance, rejecting a magistrate judge's recommendation that the company foot its own bill.

  • November 04, 2024

    Ukrainian Pleads To $11M Tax Fraud, Immigration Scheme

    A Ukrainian national charged for immigration fraud and money laundering has pled guilty and could face 20 years in prison, the U.S. Justice Department announced.  

  • November 04, 2024

    Justices Won't Hear UBS Suit Over Disclosed Account Info

    The U.S. Supreme Court declined Monday to hear a couple's suit accusing UBS of fraudulently flagging an account to the Internal Revenue Service in violation of civil provisions under the Racketeer Influenced and Corrupt Organizations Act.

  • November 04, 2024

    Justices Let Stand Bar On Late-Filed Returns In Bankruptcy

    The U.S. Supreme Court said Monday it would let stand a Ninth Circuit decision finding late-filed returns prevented a taxpayer from discharging his federal tax debt in bankruptcy, rejecting the taxpayer's request to resolve what he described as a significant circuit split.

  • November 04, 2024

    IRS Finalizes Seized Property Rules To Include Online Sales

    The Internal Revenue Service issued final rules Monday meant to modernize regulations governing the seizure of property by levy, including facilitating the online sale of a property and the agency's ability to maximize sale proceeds for the property owner's benefit.

  • November 01, 2024

    Previously Taxed Profit Rules Due By Year's End, Official Says

    The Internal Revenue Service will publish the first tranche of long-awaited regulations on offshore earnings and profits previously taxed in the U.S. before the end of the year, an agency counsel said Thursday.

  • November 01, 2024

    NOL Rules May Retain Favorable Approach, IRS Counsel Says

    New proposed regulations governing business net operating losses that could retain a popular provision allowing some businesses expanded use of those losses are a priority to be published next year, a top Internal Revenue Service lawyer said.

  • November 01, 2024

    Brazil Should Adopt Latest Pillar 2 Safe Harbor, NFTC Says

    Brazil should include the latest updates to globally agreed-upon safe harbors in its legislation to enact an international minimum tax agreement known as Pillar Two, according to the National Foreign Trade Council, which said these measures help prevent double taxation.

  • November 01, 2024

    Couple Tries To Block IRS Summons Issued For Spain

    A couple asked a California federal court to block an IRS summons for their financial information issued on behalf of Spain, saying the demand is tantamount to a fishing expedition meant to help the foreign government prosecute them.

  • November 01, 2024

    Taxation With Representation: Kirkland, Davis Polk, Wachtell

    In this week's Taxation with Representation, BC Partners sells its majority equity interest in GardaWorld, Lone Star Funds sells specialty chemicals company AOC to Nippon Paint Holdings, Crescent Biopharma takes GlycoMimetics private, and Francisco Partners buys AdvancedMD from Global Payments.

  • November 01, 2024

    Danish Tax Agency To Settle With Atty In $2.1B Tax Fraud Suit

    Denmark's tax authority has agreed to settle with an attorney whom it has accused of helping clients claim fraudulent tax refunds in a sprawling $2.1 billion case, according to a letter by its attorney in New York federal court.

  • November 01, 2024

    GOP Gains Could Prompt Push For Endowment Tax Hike

    If Republicans make significant gains in the upcoming elections, it could clear the way for GOP lawmakers to push to boost taxes on the endowments of some private colleges and universities.

  • November 01, 2024

    IRS Ups Contribution Limit For 401(k), Other Plans

    The annual amount that employees can contribute to various retirement plans has been increased to $23,500 from $23,000 as part of cost-of-living adjustments released Friday by the IRS.

  • November 01, 2024

    CFC Dividend Tax Issue Brewing In Exams, IRS Official Says

    A memorandum from the IRS chief counsel explaining why a controlled foreign corporation cannot claim a 100% deduction for certain foreign-based earnings was necessary to inform field agents dealing with the issue in the exam process, an agency official said Thursday.

  • November 01, 2024

    Accountant Gets 1 Year For Failing To Report Stolen Income

    An accountant for a manufacturing company who embezzled more than $800,000 and failed to report it on his tax returns was sentenced to just over a year in prison and ordered to pay $1 million in restitution, according to New Jersey federal court documents.

  • November 01, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included the annual inflation adjustments to over 60 tax provisions.

  • October 31, 2024

    Man Didn't Justify His Claims He Couldn't Pay, Tax Court Says

    The Internal Revenue Service didn't abuse its discretion when it upheld levies to collect over $58,000 in outstanding tax liabilities, including penalties and interest, after a man failed to substantiate his claims of medical hardship, the U.S. Tax Court said Thursday.

Expert Analysis

  • What The Law Firm Of The Future Will Look Like

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    As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • 4 PR Pointers When Your Case Is In The News

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    Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Charting The Course For Digital Assets In 2024

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    Although 2023 was a tough year for the digital asset industry, upcoming court decisions, legislation and regulatory action will bring clarity, allowing the industry to expand and evolve, and the government will decide what innovation it will allow without challenge, says Joshua Smeltzer at Gray Reed.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • Giving The Gov't Drug Patent March-In Authority Is Bad Policy

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    The Biden administration's recent proposal to allow government seizure of certain taxpayer-funded drug patents is a terrible idea that would negate the benefits of government-funded research, to the detriment of patients and the wider economy, says Wayne Winegarden at Pacific Research Institute.

  • How Clients May Use AI To Monitor Attorneys

    Excerpt from Practical Guidance
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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

  • The Pop Culture Docket: Judge D'Emic On Moby Grape

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    The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.

  • How 'As Such' Changes LPs' Self-Employment Tax Exposure

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    In light of the U.S. Tax Court’s recent Soroban Capital Partners decision hinging on "as such" to define the statutory limited partners exemption, state law limited partnerships should consider partners' roles and responsibilities before determining whether they are obligated to pay self-employment income tax, say attorneys at Morgan Lewis.

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

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