Federal

  • April 15, 2024

    Tax Attys, Broker Peddled 'Financial Fantasy,' NC Jury Told

    A North Carolina federal jury on Monday heard a series of secret recordings at the start of a tax fraud trial in which an insurance agent and a St. Louis attorney unwittingly pitched an undercover IRS agent on a way to decrease taxable income — or what the government characterized as a "financial fantasy."

  • April 15, 2024

    Exxon Seeks $1.8B Tax Refund As Qatar Deal Trial Opens

    Exxon Mobil Corp. argued Monday in Texas federal court that its deal with Qatar to extract natural gas from the country's coast was a partnership, rather than a lease agreement, saying at the start of a trial that it's entitled to get $1.8 billion in tax benefits back from the IRS.

  • April 15, 2024

    House OKs Ending Exemption For Terrorist-Supporting Orgs

    The House passed legislation Monday that would authorize the Internal Revenue Service to suspend the tax-exempt status of any nonprofit organization found by the U.S. Treasury secretary to support foreign terrorism.

  • April 15, 2024

    8th Circ. Urged To Revive IRS' Pricing For Medtronic

    The U.S. government urged the Eighth Circuit on Monday to side with the IRS' method for pricing the intangible property that medical device maker Medtronic licensed to a Puerto Rican affiliate, arguing it's the only way to determine arm's-length royalty rates.

  • April 15, 2024

    Donor Fund Regs Could Imperil Nonprofit-Sponsored Projects

    So-called fiscal sponsorship funds set up at established nonprofits to help new projects start charitable work could be unexpectedly threatened by proposed IRS and Treasury rules on donor-advised funds that could subject such arrangements to burdensome taxes, experts say.

  • April 15, 2024

    IRS Boasts Better Service, Direct File Progress On Tax Day

    The IRS achieved an 88% level of service this year on its phone lines and maintained an average call wait time of three minutes while answering more than a million more calls than last year's filing season, the U.S. Department of the Treasury announced Monday.

  • April 15, 2024

    Tax Court Finds Woman Liable Despite Divorce Decree

    A Connecticut woman is jointly and severably liable for tax liabilities despite a divorce decree that calls for them to be her ex-husband's responsibility, according to a transcript released Monday by the U.S. Tax Court.

  • April 15, 2024

    AICPA Calls For Clearer Forms For Tax-Exempt Orgs

    The Internal Revenue Service ought to clarify filing requirements for forms in order to simplify the filing process for tax-exempt organizations, the American Institute of Certified Public Accountants said in a letter made public Monday.

  • April 15, 2024

    'Magician' Tax Preparer Arrested On $100M Fraud Charges

    The owner of a New York tax preparation business who was known as "the magician" was arrested Monday on charges that he caused more than $100 million in tax losses to the government over a decade, according to the U.S. Department of Justice.

  • April 15, 2024

    Madoff Victims Can't Claim Theft Deduction, Tax Court Rules

    A New York couple who fell victim to Bernie Madoff's Ponzi scheme were properly denied a theft loss deduction because they did not own the assets that were stolen, the U.S. Tax Court ruled Monday.

  • April 15, 2024

    9th Circ. To Hear Hunter Biden Appeal In Criminal Tax Case

    The Ninth Circuit will hear Hunter Biden's argument that a California federal judge wrongly rejected requests by his defense team to toss a criminal tax case that Biden has claimed is politically motivated and vindictive, according to a notice filed Monday.

  • April 15, 2024

    IRS Waives Penalties For Not Paying Corp. Minimum Tax

    The Internal Revenue Service is waiving penalties for failure to make estimated quarterly payments of the corporate alternative minimum tax through at least April 15, the agency said Monday.

  • April 15, 2024

    IRS Improves Adherence To FOIA Rules, TIGTA Says

    The Internal Revenue Service "generally followed" Freedom of Information Act protocols for redacting taxpayer information from October 2022 to March 2023 — a considerable improvement from past reports, the Treasury Inspector General for Tax Administration said Monday. 

  • April 12, 2024

    Petition Watch: Judge DQs, 'Excessive' Damages & Price Wars

    A former al-Qaida member has asked the U.S. Supreme Court to clarify disqualification protocol for judges overseeing a case related to their prior work as a government attorney, and energy drink manufacturers want the court to develop a modern-day test to determine if companies qualify as price-discrimination competitors. Here's four high court petitions filed recently that you might've missed.

  • April 12, 2024

    FedEx Not Entitled To $84.6M In Tax Credit Dispute, US Says

    FedEx is not entitled to a judgment of nearly $84.6 million that the company requested in March for its foreign tax credit dispute, the federal government said Friday in a Tennessee federal court filing.

  • April 12, 2024

    4 Takeaways From Tax Court Nix Of Easement Perpetuity Rule

    The U.S. Tax Court's scrapping of an IRS rule on the perpetuity requirements for conservation easements could draw yet more judicial scrutiny to the agency's rulemaking and shift the focus of easement disputes to how the transactions are valued. Here, Law360 examines four key takeaways from the decision.

  • April 12, 2024

    OECD Base Erosion Project Still Percolating, Think Tank Says

    Policymakers should recognize that the Organization for Economic Cooperation and Development's tax project from roughly a decade ago to reduce base erosion and profit shifting may still be affecting companies' behavior, according to a publication released Friday from the fiscally conservative-leaning Tax Foundation.

  • April 12, 2024

    Woman Pleads Guilty To $1.3M COVID Tax Credit Fraud

    A California woman pled guilty to fraudulently obtaining $2 million in COVID-19 government loans and falsely claiming $1.3 million in tax credits, crimes that could result in a 20-year prison sentence, the U.S. Department of Justice said.

  • April 12, 2024

    Final 'Look-Through' Rules Coming Soon, IRS Official Says

    The IRS is about to release final regulations that would, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled, an agency official said Friday.

  • April 12, 2024

    The Week In Trump: Catch Up On The Ex-President's Cases

    Donald Trump and his legal team proved that they are nothing if not persistent as they repeatedly tried — and failed — to hit the brakes on the former president's porn star hush money trial in Manhattan.

  • April 12, 2024

    Construction Co. Owner Cops To Causing IRS $2.8M Tax Loss

    A Massachusetts construction company owner pled guilty to running an "off-the-books" cash payroll scheme that cost the federal government $2.8 million in tax losses, the U.S. Department of Justice said.

  • April 12, 2024

    IRS Adds 12 Census Tracts For Alternative Fuel Credit

    The Internal Revenue Service added additional census tracts to the list of those where people and businesses can qualify for the alternative fuel vehicle refueling property credit, the agency said Friday.

  • April 12, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, featuring a clarification surrounding qualified student loan bonds.

  • April 12, 2024

    Taxation With Representation: Freshfields, Kirkland & Ellis

    In this week's Taxation with Representation, eBay acquires Collectors' Goldin auction house, Vertex Pharmaceuticals buys Alpine Immune Sciences, Vista Equity Partners purchases Model N and Tradeweb Markets buys Institutional Cash Distributors.

  • April 12, 2024

    IRS Schedules Advisory Council Meeting For May

    The Internal Revenue Service Advisory Council will hold its next meeting May 8, the agency announced Friday.

Expert Analysis

  • 4 Legal Ethics Considerations For The New Year

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    As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.

  • 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.

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