Foreigners could see reduced or eliminated capital-gains withholding from investments in federal opportunity zones, under proposed rules that also would tighten requirements for non-U.S. parties and refine guidance on safe harbors in disaster areas, the IRS said Monday.
A Wisconsin federal judge has ruled that the state generally can't tax Indian-owned land on four Chippewa tribes' reservations, but also said that such land can be taxed once it's sold to non-Indians, even if tribe members eventually buy it back.
After overseeing cases ranging from employment and Native American law to a major solar energy tax write-off scheme, Utah U.S. District Judge David O. Nuffer's transition to senior status next year will give President Joe Biden a rare and delicate red-state opening.
A law denying passports to individuals until they repay tax debts violates their fundamental right to travel enshrined in the roots of American constitutional law, an attorney whose passport was restricted over tax debt told the Eleventh Circuit.
Large online companies such as Google and Facebook would be prohibited from passing along the cost of a new tax on digital advertising in Maryland under a bill sent Monday to the state's governor.
A Minnesota House committee advanced a bill Monday to legalize recreational cannabis and impose gross receipts and use taxes on sales of cannabis products.
New Mexico Gov. Michelle Lujan Grisham signed off Monday on legislation that legalizes marijuana for adult use and expunges criminal records for certain marijuana-related convictions, making the state the 18th in the country to launch a recreational cannabis industry.
Jackson Lewis PC has added an executive compensation and employee benefits attorney to bolster its ranks in Houston, bringing him back into the fold after almost two years with Morrison Cohen LLP.
The Montana House of Representatives advanced multiple bills implementing voter-approved adult-use legalization, but with dueling proposals on how to spend the tax revenue, while North Carolina lawmakers pitched medical and recreational cannabis legislation on the same day. Here are the major developments in cannabis reform from the past week.
A Swiss court rejected bids by five UBS Group clients to stop the transfer of their data to France in a wider case in which the bank has been fined for helping French clients dodge taxes, rulings released Friday show.
A Michigan federal court correctly dismissed a suit by cannabis business owners seeking to quash a third-party summons issued by the IRS requesting their companies' records because the summons aided a criminal investigation, the Sixth Circuit said Friday.
Two executives should be dismissed from a lawsuit against pharmaceutical company Perrigo alleging it hid a €1.6 billion ($1.9 billion) tax bill because there is no evidence of their wrongdoing, they told a New York federal court.
A provision in the federal pandemic relief law disallowing states from using relief funds to "directly or indirectly" cut taxes or else risk losing money is unconstitutional, 74 Republican members of Congress told a federal court Friday.
A Brooklyn landlord must face a putative class action from tenants accusing the owner of reporting rents that were higher than what was charged as a way to skirt rent stabilization obligations while still accepting property tax breaks.
In this week's Taxation With Representation, U.K.-based LumiraDx goes public with a $5 billion valuation, Israeli digital investigations support business Cellebrite inks a $2.4 billion merger, and Topps Inc. is valued at $1.3 billion.
A split Fifth Circuit declined to reconsider its ruling that six states were wrongly awarded $479 million in disgorgement from the federal government over the Affordable Care Act's health insurance provider fees, according to a Friday order.
The wife of a former Jenkens & Gilchrist PC lawyer imprisoned for tax fraud told a Manhattan federal judge Thursday that the government should be sanctioned for failing to preserve bank records that could support her bid to recoup funds claimed by the government in connection with the ex-attorney's purported crimes.
A proposal from Senate Democrats to use existing U.S. Treasury regulations to enhance the tax on global intangible low-taxed income could reduce administrative complexity, but likely won't avoid all potential compliance and enforcement headaches with the proposal.
The Florida Legislature passed a bill Thursday that would require remote sellers and marketplace facilitators to collect and remit sales and use tax, eventually slash the state's business rent tax and raise an estimated $1.08 billion annually.
Minnesota would provide a capped tax exclusion for Paycheck Protection Program loans and expand its combined reporting regime to include foreign corporations that have global intangible low-taxed income, under an omnibus tax bill a state House committee approved Thursday.
The West Virginia Senate advanced a bill to cut the state's personal income tax by about $818 million starting next year after stripping the bill of several changes made by the chamber's Finance Committee.
The commissioner of the Internal Revenue Service's Large Business and International Division will become the agency's deputy commissioner for services and enforcement, the IRS announced Thursday.
Long Island-based law firm Rivkin Radler LLP has added four partners to its trust and estates practice, which is being rebranded as the personal, family and business planning practice group.
Kirkland & Ellis' New York tax practice group added a partner, hiring a former Weil Gotshal & Manges LLP partner with deep experience in the legal art of negotiating complex financial transactions, the firm said.
Virginia will legalize and tax marijuana for adult recreational use starting July 1, after lawmakers Wednesday approved amendments from the governor to move up the date from Jan. 1, 2024.
From a proposal to overhaul California’s property tax system to imposing a graduated income tax in Illinois, voters will have the final say on a number of significant tax-related ballot measures on Election Day. Here, Law360 examines five measures that headline this year’s slate of initiatives.
Law360 is proud to present a new series profiling a select group of women in tax law, spotlighting attorneys who have provided outstanding service to their clients and the public, changing the dynamics at their workplaces while they did so.
The IRS has started mailing letters to cryptocurrency users warning they could face penalties or worse if they don't properly report transactions and pay taxes on them. Law360 explores important considerations for cryptocurrency users who have received such a letter.
The U.S. Tax Court's recent ruling in Olsen v. Commissioner, the first of 200 cases involving individual taxpayers who invested in a tax shelter involving solar equipment, is a case study in how not to structure an energy tax credit investment, says David Burton at Norton Rose.
Lawmakers' calls to repeal the cap on federal deductions for state and local taxes are controversial because doing so could cost over $600 billion, but a partial repeal could be accomplished on a revenue-neutral basis, providing relief to some, if not most, affected taxpayers, says Joseph Mandarino at Smith Gambrell.
The current high demand for midlevel associates provides them a rare opportunity to potentially explore new practice areas, but associates should first ask themselves six questions to begin figuring out why a change sounds appealing, says Stephanie Biderman at Major Lindsey.
To truly support a client going through a complicated lawsuit or a painful experience, lawyers must think beyond interpreting legal guidelines and navigating court proceedings, says attorney Scott Corwin.
Due to the pandemic, the gap between law school and the first day on the job has never been wider, but law firms can leverage training to bridge that intimidating gap and convey the unique value of their culture in a virtual environment, say Melissa Schwind at Ward and Smith, and William Kenney and Jaron Luttich at Element Standard.
Robert Weiss and David Vanaskey at Wilmington Trust describe some of the core considerations for trustees that administer settlements resulting from mass tort and class action litigation, based on their experience working on the Volkswagen diesel emissions settlement.
The virtual courtroom limits a narcissistic lawyer's ability to intimidate witnesses and opposing counsel, boast to clients or engage in grandstanding — an unexpected benefit of the global pandemic as some aspects of remote litigation are likely here to stay, says Jennifer Gibbs at Zelle.
A recent American Bar Association opinion on lawyers' ethical duties of competence and confidentiality when working remotely should be viewed as part of a larger movement by which attorneys are being exhorted to develop competence in 21st century technology, say Jennifer Goldsmith at Ironshore and Barry Temkin at Mound Cotton.
Elements of New York's recently passed Marijuana Regulation and Taxation Act, such as its prohibition of vertically integrated operators, show consideration for social and economic equity in the new industry, says Simon Malinowski at Harris Bricken.
Steptoe & Johnson's Matthew Frank, former director of the U.S. Advance Pricing Agreement Program, shares insights from an Internal Revenue Service report revealing an uptick in APA completions amid the pandemic, discusses trends over the program's 30-year history, and suggests ways taxpayers and the IRS could bolster program participation.
While a Texas federal court recently denied a motion to disqualify DLA Piper from representing Apple in a patent dispute after the law firm hired an attorney who formerly represented opponent Maxwell, the case is a reminder that robust conflict checks during lateral hiring can save firms the time and expense of defending disqualification motions, says Hope Comisky at Griesing Law.
If the U.S. Supreme Court upholds the Fifth Circuit in the upcoming San Antonio v. Hotels.com case, ruling that district courts may not amend taxable appellate costs, it could reprioritize the incentive structure and decision-making calculus of appeals, says Patrick Hammon at McManis Faulkner.
Samuel Pollack and Naoko Watanabe at Baker McKenzie examine the corporate and U.S. tax law considerations involved in deciding whether a branch or subsidiary is the most efficient way to expand operations overseas, now that recent Treasury regulations clarified the complicated international tax regime created by the Tax Cuts and Jobs Act.
The South Coast Air Quality Management District's proposal to regulate Southern California warehouses as indirect sources of truck-related greenhouse gas emissions will almost certainly face legal challenges if adopted, including arguments that it improperly imposes a tax and exceeds the district's regulatory authority, says Niran Somasundaram at Hanson Bridgett.
Lawyers preparing to mediate or arbitrate a case through videoconference should take steps to ensure they and their alternative dispute resolution providers are employing reasonable security precautions to protect digital client data and conform to confidentiality obligations, say F. Keith Brown and Michael Koss at ADR Systems.