Federal

  • March 14, 2024

    Tupperware Pans Investor Suit Over 'Small' Accounting Errors

    Tupperware wants to dismiss a proposed class action accusing it of damaging investors by knowingly issuing misleading financial reports, arguing the suit fails to show it acted with ill intent when releasing the allegedly inaccurate information to the public, and that its restatements did not actually hurt shareholders.

  • March 14, 2024

    Man Who Hid Income Had Fraudulent Intent, Tax Court Says

    An Arizona man who hid self-employment income from the Internal Revenue Service in a sham partnership of family trusts owes additional taxes for fraudulently failing to file returns, the U.S. Tax Court ruled Thursday.

  • March 14, 2024

    Ariz. Reps. Urge IRS To Scrap Tax On State Rebates

    Arizona's one-time state tax rebates should not be subject to federal income tax, members of the state's congressional delegation told the Internal Revenue Service, saying the rebates should be exempt under agency guidance issued last year.

  • March 14, 2024

    Israel Tax Authority Claims Owner Of US Biz Underpaid Tax

    A Jerusalem man is suspected of failing to report 50 million Israeli new shekels ($13.7 million) of his income from companies in Israel and abroad, the Israel Tax Authority said Thursday.

  • March 14, 2024

    Absent Returns Justify Rejecting Offers, Tax Court Rules

    The Internal Revenue Service properly sustained a collection action against a Maryland man with a record of failing to file his income tax returns, the U.S. Tax Court ruled Thursday.

  • March 14, 2024

    8th Circ. Questions IRS Ax Of Engineering Co.'s R&D Credit

    Eighth Circuit judges probed claims by the IRS that a Minnesota engineering company didn't qualify for $276,000 in research and development tax credits, asking during oral arguments whether the agency may have overlooked the inherently specialized nature of the company's engineering work.

  • March 14, 2024

    Tax Court Judge John O. Colvin, Ex-Chief, Dead At 77

    John O. Colvin, a senior judge of the U.S. Tax Court, has died, the court announced in a news release Thursday.

  • March 14, 2024

    IRS' Signals On Economic Substance Doctrine Draw Scrutiny

    The Internal Revenue Service's recent legal success asserting a doctrine to invalidate transactions in tax law enforcement matters may embolden the government to broaden that argument's reach, and lawyers are concerned it doesn't properly apply to transfer pricing matters.

  • March 13, 2024

    Siemens Asks Tax Court To Toss $1.2B IRS Bill

    A U.S. subsidiary of German technology company Siemens is pushing the U.S. Tax Court to throw out $1.16 billion in tax deficiencies and penalties the IRS has imposed, saying the agency relied on invalid rules in denying a deduction.

  • March 13, 2024

    Tax Court Calls CPA's Deduction Testimony 'Contradictory'

    A California certified public accountant cannot deduct nearly $600,000 in assorted expenses — including more than $437,000 in net operating losses — after providing "contradictory" testimony and failing to present credible evidence, the U.S. Tax Court ruled Wednesday.

  • March 13, 2024

    Actuary Board Looks To End In-Person Learning Requirement

    The Joint Board for the Enrollment of Actuaries has proposed eliminating a requirement that continuing education programs be attended in person, the Internal Revenue Service said Wednesday.

  • March 13, 2024

    Deputy To Take Over As IRS Criminal Investigation Chief

    The deputy chief of the Internal Revenue Service's Criminal Investigation division will take the helm of the division when its current chief steps down April 6, the agency said Wednesday.

  • March 13, 2024

    2nd Circ. Affirms Barring Of Man's Appeal In Small Tax Case

    The Second Circuit rejected a taxpayer's attempt to resurrect his dispute over a tax deficiency Wednesday, affirming that a statute prohibits appeals of U.S. Tax Court decisions in certain cases involving low dollar amounts.

  • March 13, 2024

    6th Circ. Told Woman Helped Life Partner Avoid $3M In Taxes

    The federal government justifiably sold off the property of a woman who paid for it with money from her dead long-term life partner, the U.S. government told the Sixth Circuit on Wednesday, saying the purchase helped her partner skirt more than $3 million in tax liabilities.

  • March 13, 2024

    JCT Indicates Pillar 1 Is Bad Deal For US, GOP Lawmakers Say

    An analysis of the Organization for Economic Cooperation and Development's Pillar One taxing rights overhaul by congressional scorekeepers makes clear the plan should not receive U.S. support because it would disadvantage U.S. multinationals and federal tax revenue, Republican leaders of Congress' taxwriting committees said Wednesday.

  • March 13, 2024

    Longtime Stradley Ronon Tax Partner Joins Grant Thornton

    Following more than a quarter-century practicing law with Stradley Ronon Stevens & Young LLP, longtime tax attorney Chris Scarpa decided to change career paths, joining accounting firm Grant Thornton LLP.

  • March 13, 2024

    Ex-Super Bowl Champ Owes $15M Tax After Default, US Says

    A California federal court should issue a default judgment for $15.5 million in federal income taxes against four-time Super Bowl champion Bill Romanowski and his wife, the U.S. government argued, saying the couple has failed to participate in a collection case against them.

  • March 13, 2024

    IRS Art Appraisal Panel Schedules April Meeting

    The Internal Revenue Service committee that appraises art for tax purposes will hold its next meeting April 17, the agency said Wednesday.

  • March 12, 2024

    IRS Mulling Partnership Foreign Currency Rules, Official Says

    The Internal Revenue Service will likely propose rules that would provide additional guidance to partnerships for determining taxable income or loss with respect to certain affiliates that conduct business in a foreign currency, an agency official said Tuesday.

  • March 12, 2024

    NC Software Execs Convicted Of Payroll Tax Crimes

    Two former software executives in North Carolina were convicted Tuesday of failing to pay hundreds of thousands of dollars in employment taxes, but were absolved of charges that they lied on their individual tax returns, bringing to a close their five-day trial in Charlotte's federal courthouse.

  • March 12, 2024

    IRS Fully Opens Direct E-File Pilot Program In 12 States

    The Internal Revenue Service's free electronic tax-return filing pilot program is now open to all 19 million eligible taxpayers in the 12 states where people can participate, agency Commissioner Daniel Werfel told reporters Tuesday.

  • March 12, 2024

    Calif. Man Agrees To Pay Nearly $500K In FBAR Penalties

    A California man agreed to pay almost $500,000 in penalties, late fees and interest for failing to report his bank accounts in the Bahamas on his tax forms, according to a stipulated order entered by a California federal court.

  • March 12, 2024

    Wis. Firm Must Comply With IRS Search, Tax Court Says

    A Wisconsin engineering firm must prove it is eligible for $240,000 in research tax credits by accommodating a broadened discovery initiated by the Internal Revenue Service, not just a sampling of the firm's data, the U.S. Tax Court ruled Tuesday.

  • March 12, 2024

    GOP's Crapo Wants Quick Resolution Of Tax Relief Package

    The Senate Finance Committee's top Republican tax writer said Tuesday that he wants to quickly resolve sticking points in pending bipartisan tax legislation that contains key incentives for families and businesses in order to advance a bill that would boost U.S. manufacturing.

  • March 12, 2024

    Businessman Hid $20M In Swiss Accounts, US Says

    A Brazilian-American businessman hid $20 million from the Internal Revenue Service over 35 years using accounts at Swiss banks including UBS and Credit Suisse, the U.S. government said in a criminal complaint that accuses him of conspiring to defraud the U.S. and lying to authorities.

Expert Analysis

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • Unpacking Long-Awaited Clean Energy Tax Credit Guidance

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    Recently proposed Internal Revenue Service regulations provide welcome confirmatory guidance on the application of investment tax credits as reworked by 2022's Inflation Reduction Act, prevailing wage and apprenticeship rules that are largely consistent with market expectations, and broader eligibility criteria that should please the wind power industry in particular, say attorneys at Morgan Lewis.

  • Understanding Discovery Obligations In Era Of Generative AI

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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • An Informed Guide To Mastering Retirement Plan Forfeitures

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    When considering how to allocate departing retirement plan participants’ forfeitures, sponsors should consider recently filed lawsuits that allege Employee Retirement Income Security Act violations for using such funds to offset employer contributions, as well as proposed IRS guidance concerning how and when they must be used, says Eric Gregory at Dickinson Wright.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • IRS Proposal May Help Clarify Donor-Advised Fund Excise Tax

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    Recently proposed regulations provide important clarifications of the Internal Revenue Code's excise tax on donor-advised fund distributions by providing detailed definitions of key terms and addressing some of the open issues related to their operation and administration, say attorneys at Morgan Lewis.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Liability Exposure For Unpaid Payroll Taxes May Surprise You

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    The Ninth Circuit’s recent decision in Richard W. York v. U.S. offers important lessons for business owners and others who may be responsible for a company's checkbook about how someone else's failure to submit payroll taxes can result in their personal liability, says Douglas Charnas at McGlinchey Stafford.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

  • Finding Focus: Strategies For Attorneys With ADHD

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    Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.

  • Unlocking Value In Carve-Out M&A Transactions

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    Some of the largest mergers and acquisitions in 2023 were carve-out transactions, and despite their unique intricacies and challenges, these transactions offer both buyers and sellers the opportunity to generate outsized returns in an otherwise vigorously competitive landscape, when carefully planned and diligently executed, say Kevin Crews and Rami Totari at Kirkland.

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