Federal

  • May 07, 2024

    IRS To Release Self-Employment Tax Regs

    The Internal Revenue Service plans to release self-employment tax regulations, an agency official said during the Practising Law Institute webcast Tuesday.

  • May 07, 2024

    Employment Agency Owner Admits Hiding $10M In Income

    The owner of a temporary employment agency pled guilty to filing false federal business tax returns to conceal more than $10 million in corporate income, the U.S. Department of Justice announced Tuesday.

  • May 07, 2024

    Electric Groups Say PIN Rule May Hurt Energy Credit Process

    While three groups representing electric equipment manufacturers are supportive of the energy efficient home improvement credit, they say its product identification number, or PIN, requirement could harm the process, according to a letter released Tuesday by the U.S. Department of the Treasury.

  • May 07, 2024

    Treasury Floats Foreign Trust Reporting Rules

    The U.S. Treasury Department proposed regulations Tuesday that provide guidance on the requirements for individuals to report their transactions with foreign trusts to the Internal Revenue Service, including the receipt of large gifts.

  • May 06, 2024

    10th Circ. Urged To Alter Substance Finding In Liberty Global

    To preserve the stability of federal tax law, the Tenth Circuit should reverse a lower court's finding that it needn't determine the economic substance doctrine is relevant before disallowing a transaction's tax benefits, the National Foreign Trade Council said Monday, supporting telecommunications firm Liberty Global.

  • May 06, 2024

    IRS Urged To Drop Investment Advisers From Donor Rules

    The IRS should change regulations on donor-advised funds so that personal investment advisers wouldn't be considered donor-advisers, stakeholders told the agency at a hearing Monday, saying failure to do so could chill charitable giving and would exceed regulatory authority.

  • May 06, 2024

    Man's FBAR Filing Makes Challenge Moot, 7th Circ. Says

    The Seventh Circuit upheld Monday the dismissal of a man's challenge to the constitutionality of filing reports of foreign accounts because after filing the suit, the man reported his bank account, making the case moot.

  • May 06, 2024

    Texas Health Coordinator Urges Nonprofit Status At 5th Circ.

    A Texas company that coordinates healthcare for chronically ill patients should not be barred from claiming tax-exempt status, it told the Fifth Circuit on Monday, arguing that the U.S. Tax Court applied an incorrect legal standard when it revoked the group's status.

  • May 06, 2024

    Engineering Co. Can't Claim Research Credits, 8th Circ. Says

    The Eighth Circuit declined Monday to revive an engineering company's bid for research tax credits for its work on several building projects, finding the credits are limited to endeavors where funding is contingent on the success of the research.

  • May 06, 2024

    Missouri CPA Barred From Promoting Annuity Trusts

    A Missouri certified public accountant accused of operating a charitable trust scheme that cost the government $8 million in tax was permanently barred from marketing tax arrangements involving charitable remainder annuity trusts, the U.S. Department of Justice said Monday.

  • May 06, 2024

    Marcum Expands Into Mich. By Adding Croskey Lanni

    Accounting and advisory firm Marcum LLP acquired Detroit-based Croskey Lanni PC, adding six partners and more than 50 associates, Marcum announced Monday.

  • May 06, 2024

    Clifford Chance Continues 2024 Growth In New York, Houston

    Clifford Chance continued its recent aggressive expansion by growing its Houston and New York offices with two attorneys specializing in energy, taxation and mergers and acquisitions, bringing the firm's lateral hires up to 10 attorneys in 2024.

  • May 06, 2024

    Trump Media Hires Auditor To Replace Firm Accused Of Fraud

    Trump Media and Technology Group Corp. has hired a new auditor, replacing its predecessor firm, which was permanently suspended by securities regulators Friday for alleged "massive fraud" regarding its work with hundreds of clients, according to a filing Monday.

  • May 04, 2024

    IRS Seeks More Info On Purpose Test In Buyback Tax Regs

    The IRS is seeking more information on fine-tuning a test in proposed rules on the stock buyback tax meant to assess whether the principal purpose of a U.S. subsidiary's funding purchase of its foreign parent's stock is to avoid the tax, an agency attorney said Saturday.  

  • May 03, 2024

    Gannett Can't Dodge Tax Firm's Defamation Case

    Gannett Co. can't escape a defamation case accusing it of writing misleading articles saying Ryan LLC, a tax services and technology firm, engaged in shady business practices, a Texas appeals court ruled, finding the media giant isn't shielded from the claims by the Lone Star State's anti-SLAPP law.

  • May 03, 2024

    US Resisting More Scoping On Amount B, Economist Says

    In negotiations over the streamlined transfer pricing approach for baseline marketing and distribution functions known as Amount B, the U.S. has resisted calls for additional scoping criteria that would exclude more companies from the safe harbor, a former U.S. Treasury economist said Friday.

  • May 03, 2024

    Sidley Liable For Ex-Partner's Tax Sheltering, Ga. Judge Told

    Counsel for a family of business magnates who say they were duped into an illegal tax shelter scheme over 25 years ago by Sidley Austin urged a Georgia federal judge Friday to let their suit against the firm continue, arguing its defense that the suit is time-barred should be done away with.

  • May 03, 2024

    Dems, GOP Favor Extending Pass-Through Break, Staff Says

    Democrats and Republicans are both interested in extending the 2017 tax law's pass-through deduction, which expires at the end of 2025, though Democrats would like to limit its availability to upper-income earners, a pair of congressional staffers said Friday.

  • May 03, 2024

    No Climate Law Corrections Bill Expected, Senate Staffer Says

    Congress is unlikely to pass a so-called technical corrections bill that would change noncontroversial and revenue-neutral tax provisions in the 2022 climate law known as the Inflation Reduction Act, a Senate Finance Committee Democratic staffer said Friday.

  • May 03, 2024

    Feds Can Introduce Prior Guilty Plea In Tax Fraud Case

    Federal prosecutors can introduce a man's prior admissions of tax evasion in a trial over separate tax crime charges because it could show his willingness and knowledge to commit the crime, a Pennsylvania federal judge ruled.

  • May 03, 2024

    Foreign Trust Reporting Rules Coming Soon, IRS Official Says

    The Internal Revenue Service is about to issue proposed regulations that will provide guidance on the reporting obligations for individuals who have transactions with foreign trusts, an agency official said Friday.

  • May 03, 2024

    IRS Details Penalty-Free Retirement Withdrawals For Disasters

    The Internal Revenue Service detailed procedures Friday for taking penalty-free withdrawals of up to $22,000 from Internal Revenue Code Section 401(k) retirement accounts and other retirement plans under the permanent disaster tax relief granted in the Secure 2.0 Act.

  • May 03, 2024

    HMRC Director Rejoins KPMG To Boost Tax Dispute Offering

    A former deputy director at HM Revenue & Customs has returned to KPMG as director of KPMG Law's tax disputes teams, the firm has announced.

  • May 03, 2024

    IRS Expects Updates To Hydrogen Credit Emissions Model

    The Internal Revenue Service expects the U.S. Department of Energy to update a model used to determine eligibility for the new clean hydrogen production tax credit under recently proposed rules, an IRS attorney said Friday.

  • May 03, 2024

    IRS Program In Miss. Delta Struggling, TIGTA Says

    Attempts by the Internal Revenue Service to expand operations to economically distressed areas in the Mississippi Delta have fallen well short of a goal of hiring 160 employees by the end of fiscal 2024, the Treasury Inspector General for Tax Administration said in a report.

Expert Analysis

  • Anticipating Intensified Partnership Enforcement From IRS

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    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

  • Newman Suspension Shows Need For Judicial Reform

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    The recent suspension of U.S. Circuit Judge Pauline Newman following her alleged refusal to participate in a disability inquiry reveals the need for judicial misconduct reforms to ensure that judges step down when they can no longer serve effectively, says Aliza Shatzman at The Legal Accountability Project.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

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    Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • How Law Firms Can Use Account-Based Marketing Strategies

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    Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.

  • While Risks Exist, AI Could Transform IRS Enforcement

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    The Internal Revenue Service's recently announced use of artificial intelligence could revolutionize the agency's enforcement efforts, and transparency about its use and a forum for challenging AI findings could help mitigate fears that the technology will increase bias, say attorneys at Lewis Brisbois.

  • Strategic Succession Planning At Law Firms Is Crucial

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    Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.

  • Maximizing Law Firm Profitability In Uncertain Times

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    As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • How Gov't Agencies Will Fare In The Event Of A Shutdown

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    With a federal shutdown potentially set to begin at the end of this month, it may be useful to consider the approximate timelines that agencies such as the Federal Trade Commission and IRS have announced for curtailing operations, and potential strategies for mitigating challenges that may arise while agency functions are limited, say attorneys at Cleary.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

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