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Tax
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July 23, 2024
No Victims, No Fraud, Trump Says In $465M Judgment Appeal
Donald Trump has appealed the $465 million judgment against him, arguing that the New York attorney general exceeded her authority in her civil fraud suit against the former president because the statute in question does not apply to victimless transactions.
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July 23, 2024
India Eyes End Of Digital Tax For E-Commerce, But Not Ads
Foreign e-commerce companies would be exempted from India's equalization levy, a 2% digital tax, but online advertisers would continue to pay a 6% rate on gross revenues sourced to Indian customers under a budget bill presented Tuesday by the government.
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July 23, 2024
Ariz. Court OKs Hospital District Tax For Legal Costs
A property tax levied to fund an Arizona hospital district's expenses including legal fees was properly authorized and did not require approval by voters, the Arizona Tax Court said, rejecting a suit by a local taxpayer.
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July 23, 2024
Orrick Hires Ex-Winston & Strawn Tax Partner In Chicago
Orrick Herrington & Sutcliffe LLP announced the hiring of a former partner at Winston & Strawn LLP for its renewables tax equity and tax credit team.
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July 23, 2024
11th Circ. Should Uphold Tax Court Protection, IRS Says
The Eleventh Circuit should uphold a U.S. Tax Court ruling that denied a widow tax relief and also rejected her claim that Tax Court judges have unconstitutional job protection, the Internal Revenue Service told the circuit court.
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July 23, 2024
5-Hour Energy Partner Owes No Tax On Sale, DC Circ. Says
The D.C. Circuit found Tuesday that a Canadian citizen's $6.5 million in gains from her sale of a U.S. partnership interest in a company that sold 5-hour Energy drinks was not federally taxable as inventory income, reversing a U.S. Tax Court ruling.
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July 22, 2024
Michigan's Cases To Watch 2024: A Midyear Report
Michigan's highest court is preparing to take on cases that could restore imperiled PFAS regulations, prevent employers from cutting short employees' window to file civil rights claims and expand the reach of Michigan's consumer protection law. Here are some of Michigan's most important cases to watch for the rest of the year.
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July 22, 2024
What Attorneys Need To Know About JD Vance
Vice presidential nominee JD Vance's brief legislative record shows he is aligned with his fellow Republicans on hot-button issues like abortion and immigration, but it also indicates that the senator from Ohio may be willing to break with the GOP mainstream when it comes to regulating big business. Here's what attorneys should know about the vice presidential candidate.
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July 22, 2024
HMRC Wins Appeal Over Taxation Of Partnership Rewards
Financial rewards from a partnership were taxable as income even though they were made at the partnership's total discretion and the partners had no legally enforceable right to receive them, a London court ruled, siding with HM Revenue & Customs.
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July 22, 2024
Challenge To Romanian Trading Tax Referred To ECJ
Europe's highest court has been handed a challenge to trading tax in Romania, as a national court seeks guidance on whether EU law would prevent a member country from creating an extra tax liability for some participants in the wholesale energy market.
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July 19, 2024
Edwin Coe Adds To Team Ahead Of Planned UK Tax Changes
Edwin Coe LLP is preparing for an expected surge in disputes following the U.K.'s planned tax changes by hiring as a partner a Harbottle & Lewis lawyer with expertise in litigation and tax planning, according to a news release.
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July 19, 2024
Taxation With Representation: A&O Shearman, Gibson Dunn
In this week's Taxation With Representation, Cleveland-Cliffs Inc. buys Stelco Holdings Inc., KBR acquires LinQuest Corp., Blue Owl Capital Inc. purchases Atalaya Capital Management LP, and Amphenol Corp. buys two mobile networks units from CommScope.
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July 18, 2024
Hunter Biden Wants Charges Tossed After Trump Docs Ruling
Hunter Biden on Thursday asked federal judges in Delaware and California to throw out his conviction on felony gun charges and to toss other charges of tax evasion, citing a Florida federal judge's order disqualifying the special prosecutor in Donald Trump's classified documents case.
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July 18, 2024
State Of 2024 Energy Dealmaking: Midyear Report
Energy dealmaking in the first half of 2024 has, in many ways, picked up where 2023 left off, but companies also increasingly have an eye on the U.S. presidential election this fall that could bring drastic change to the landscape. Here are some transactional trends that have stood out to energy attorneys so far this year.
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July 18, 2024
Bank Exec's Tax Tip Case Wrongly Axed, Estate Tells DC Circ.
The estate of a Dutch bank executive asked the D.C. Circuit to overturn a U.S. Tax Court decision denying him a whistleblower award for reporting on tax avoidance schemes, saying the lower court improperly relied on proposed regulations from the Internal Revenue Service.
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July 18, 2024
Ind. Tax Board Says German Cultural Center Not Tax-Exempt
The Indiana Board of Tax Review determined that an event center owned by an organization that promotes German culture doesn't qualify for a property tax exemption because the property is used for social purposes rather than cultural preservation.
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July 18, 2024
Ind. Tax Board Agrees With $2M Valuation Of Unfinished Home
An Indiana local assessor correctly valued an unfinished mansion at $2.2 million in 2021 and $2.4 million in 2022, a state review board determined after agreeing with the assessor's cost approach.
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July 18, 2024
Tax Court Affirms IRS Whistleblower Award Computation
The Internal Revenue Service's Whistleblower Office did not abuse its discretion when it set an award at 22% of collected proceeds even though other awards tied to related claims were set at 30%, the U.S. Tax Court said Thursday.
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July 18, 2024
Mixed Results Greet 2 IPOs For Hospital Giant, Insurance Firm
Private equity-backed hospital operator Ardent Health and insurance brokerage TWFG Inc. began trading Thursday after completing two initial public offerings that raised $379 million combined at varying points of their price ranges, guided by four law firms.
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July 18, 2024
Ex-Venable Trusts And Estates Partner Joins Stradling In LA
Stradling Yocca Carlson & Rauth PC announced that it launched a trusts and estates practice with the hiring of an experienced Los Angeles-based partner from Venable LLP.
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July 18, 2024
Most Top US Cos. To Report Tax Under Aussie Bill, Study Says
Australia's Senate is expected to consider adoption next month of the world's most extensive public country-by-country reporting rules, which would require 51% of large U.S. multinational corporations to disclose tax arrangements retroactively from July 1, according to a study published Thursday.
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July 18, 2024
Final IRS Rules Require Beneficiaries To Take Distributions
Beneficiaries of retirement account owners who died after starting to take distributions must continue taking the distributions annually, the Internal Revenue Service said Thursday in final regulations on required minimum distributions that rejected feedback saying the requirement was overly complex.
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July 18, 2024
Rising Star: Latham's Eric Kamerman
Eric Kamerman of Latham & Watkins LLP in recent years handled the tax aspects of several multibillion-dollar acquisitions of powerhouses in British soccer and American fashion, earning him recognition as one of the tax attorneys under age 40 honored by Law360 as Rising Stars.
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July 18, 2024
GE Can't Claim Credit For £189M In Double Tax, Court Says
A U.K.-registered subsidiary of General Electric does not qualify for at least £189 million ($245 million) in double tax relief under a U.S.-U.K. treaty because it lacks a U.S. presence akin to a domicile, a London appellate court ruled.
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July 17, 2024
Client Bids Didn't Trigger Fla. Long-Arm Law In Breach Suit
A Florida appellate court on Wednesday tossed a breach of contract lawsuit brought by a wealth planner against two out-of-state companies, saying that the parties did not do business in Florida and that a visit to win over potential clients wasn't enough to establish jurisdiction in the Sunshine State.
Expert Analysis
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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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Series
Glassblowing Makes Me A Better Lawyer
I never expected that glassblowing would strongly influence my work as an attorney, but it has taught me the importance of building a solid foundation for your work, learning from others and committing to a lifetime of practice, says Margaret House at Kalijarvi Chuzi.
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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.
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'Energy Communities' Update May Clarify Tax Credit Eligibility
A recent IRS notice that includes updated lists of locations where clean energy projects can qualify for additional tax credits — based 2023 unemployment data and placed-in-service dates — should help provide clarity regarding project eligibility that sponsors and developers need, say attorneys at Troutman Pepper.
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Think Like A Lawyer: Always Be Closing
When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.
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Series
Playing Chess Makes Me A Better Lawyer
There are many ways that chess skills translate directly into lawyer skills, but for me, the bigger career lessons go beyond the direct parallels — playing chess has shown me the value of seeing gradual improvement in and focusing deep concentration on a nonwork endeavor, says attorney Steven Fink.
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Calif. Budget Will Likely Have Unexpected Tax Consequences
A temporary suspension of net operating loss deductions and business incentive tax credits, likely to be approved on June 15 as part of California’s next budget, may create unanticipated tax liabilities for businesses that modeled recently completed transactions on current law, says Myra Sutanto Shen at Wilson Sonsini.
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.
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Lean Into The 'Great Restoration' To Retain Legal Talent
As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.
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How Cannabis Rescheduling May Alter Paraphernalia Imports
The Biden administration's recent proposal to loosen federal restrictions on marijuana use raises questions about how U.S. Customs and Border Protection enforcement policies may shift when it comes to enforcing a separate federal ban on marijuana accessory imports, says R. Kevin Williams at Clark Hill.
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NCAA Settlement May End The NIL Model As We Know It
The recent House v. NCAA settlement in California federal court, in which the NCAA agreed to allow schools to directly pay March Madness television revenue to their athletes, may send outside name, image and likeness collectives in-house, says Mike Ingersoll at Womble Bond.