Federal

  • June 07, 2024

    IRS Delays Deadlines In W.Va., Ky. Counties Hit By Tornadoes

    Certain West Virginia and Kentucky taxpayers impacted by tornadoes and other major weather events that hit the area April 2 now have until Nov. 1 to file various individual and business tax returns and make payments, the Internal Revenue Service said Friday.

  • June 07, 2024

    No Loss On Terminated Rate Agreements, Chief Counsel Says

    A company that executed forward-rate agreements cannot claim a loss in connection with the termination of the agreements because its adjusted basis in the agreements was zero, according to a memo released Friday by the IRS Office of Chief Counsel.

  • June 07, 2024

    IRS Updates EV Battery Reporting Guide For Tax Credits

    The Internal Revenue Service provided updated guidance Friday for automakers planning to provide a report on meeting the battery sourcing requirements that can qualify their new electric vehicle models for the consumer tax credit of up to $7,500.

  • June 07, 2024

    6th Circ. Finds Ethical Lapses Justify Bar On Firm's Outreach

    The Sixth Circuit said Thursday a Michigan federal judge shouldn't have faulted a law firm for attacking a proposed tax foreclosure class-action settlement in solicitation letters, but nevertheless upheld the judge's order barring contact with certain class members because of the firm's actual ethical lapses.

  • June 07, 2024

    Subsidiary Won't Lose Status Before Dissolving, IRS Says

    A court-ordered liquidation of an insurance company won't cause it to lose its status as a corporation before it completes its final dissolution, the Internal Revenue Service said in a private letter ruling released Friday.

  • June 07, 2024

    Dentons Adds Pair Of Husch Blackwell Tax Attys

    Two South Carolina tax attorneys have joined Dentons' corporate, tax and private client practice as partners after moving from Husch Blackwell LLP, the firm announced on Thursday.

  • June 07, 2024

    IRS Scrutinizing Hospitals' Tax Exemptions, Official Says

    The Internal Revenue Service's Tax-Exempt & Government Entities Division has started auditing tax-exempt hospitals to ensure they're complying with exemption requirements, an agency official said Friday.

  • June 07, 2024

    Halliburton Wrongly Denied $11.3M Deduction, Court Told

    The Internal Revenue Service is arbitrarily and wrongfully refusing to refund Halliburton over $11.3 million in tax deductions taken for a payment to a foreign government to secure the safety of the company's employees, Halliburton told a federal court.

  • June 07, 2024

    Fed. Circ. Panel Doubts Bid To Nix Actavis' $12M Deduction

    A Federal Circuit panel seemed skeptical of the government's bid to overturn a decision allowing drugmaker Actavis to deduct $12 million it spent fending off lawsuits as it secured approval to sell generics, raising the question during oral arguments Friday whether the company was being uniquely targeted.

  • June 07, 2024

    Taxation With Representation: Vinson, Latham, Ropes & Gray

    In this Week's Taxation with Representation, Waste Management buys Stericycle, Becton Dickinson pays $4.2 billion for Edwards Lifesciences' critical care products unit, Aquiline Capital Partners raises over $3.4 billion in fund capital, and Bain Capital buys PowerSchool Holdings.

  • June 07, 2024

    IRS Lists Shuttered Coal Areas For Energy Bonus Credits

    The Internal Revenue Service on Friday issued updated lists of areas, including closed coal mines and factories, where developers can qualify for additional tax credits for building their clean energy projects.

  • June 07, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, which included proposed foreign trust transaction reporting requirements.

  • June 06, 2024

    Medtronic Urges 8th Circ. To Back Its Transfer Pricing Method

    Medical device maker Medtronic reiterated Thursday its bid for the Eighth Circuit to revive its method for pricing intangible property that was licensed to a Puerto Rican affiliate, arguing the government's concessions show why the company's approach is more reliable.

  • June 06, 2024

    9th Circ. Denies Trust Refund Of Money Forfeited To IRS

    A trust lost its ownership claims to property when an Idaho federal court determined the property had been transferred to the trust fraudulently, the Ninth Circuit said Thursday, affirming a decision to deny a $225,000 tax refund.

  • June 06, 2024

    Estate Entitled To Deduct Payouts To Stepkids, 11th Circ. Told

    The U.S. Tax Court wrongly denied deductions to a former attorney's $81 million estate for million-dollar payouts it made to his stepchildren after they sued, the estate told the Eleventh Circuit, saying the payments satisfied legitimate claims against the estate and were therefore deductible.

  • June 06, 2024

    Tax Court Upholds Rejection Of Man's Biz Deductions

    A Floridian failed to adequately back up certain business loss deduction claims made on his tax return, the U.S. Tax Court said Thursday, backing the IRS' rejection of the claims and imposition of an accuracy-related penalty.

  • June 06, 2024

    'Brothel' Manager Violated Bail After $5.7M Sting, Feds Say

    A manager and bookkeeper facing federal charges connected to a COVID-19 grant and tax fraud scheme at a Connecticut strip club violated his bail conditions by showing up at the facility and "hanging out" with a potential witness, federal probation authorities have alleged.

  • June 06, 2024

    9th Circ. Won't Revive Org's Push To Restore Nonprofit Status

    The U.S. Tax Court's dismissal of an attempt to reinstate nonprofit status for a California organization that said its officers fell victim to a Ponzi scheme did not breach the group's constitutional rights, the Ninth Circuit said.

  • June 06, 2024

    Ex-IRS Worker Indicted In $2M Exxon Credit Theft Scheme

    A former Internal Revenue Service employee used his account management job at the agency to steal more than $2 million worth of tax credits from Exxon Mobil and pocket the money, according to a Utah federal grand jury indictment.

  • June 06, 2024

    Fox Rothschild Brings On Tax Pro From Atlanta Boutique

    Fox Rothschild LLP has added an attorney in Atlanta from tax law boutique Wiggam Law to strengthen the firm's taxation and wealth planning department.

  • June 06, 2024

    IRS Needs Strategy For 2.6M Tax Doc Backlog, TIGTA Says

    Not only does the Internal Revenue Service have a document backlog exceeding 2.6 million source documents that need to be associated with a specific form, but it also has been making significant mistakes in reporting closures, the Treasury Inspector General for Tax Administration said in a report released Thursday.

  • June 06, 2024

    Justices Affirm Taxing Of Estate On Insurance Payout

    The U.S. Supreme Court affirmed on Thursday a decision denying a tax refund to the estate of an owner of a building materials company that used a payout from his $3.5 million life insurance policy to purchase his shares in the business.

  • June 05, 2024

    CohnReznick Scores Quick Exit In Tax Scheme Suit

    A New York federal judge agreed to toss a housing partnership's suit accusing accounting firm CohnReznick LLP of professional negligence and fraud, finding that the district court doesn't have jurisdiction over the dispute.

  • June 05, 2024

    IRS Must Better Log AI Use In Tax Gap Estimates, GAO Says

    The Internal Revenue Service needs to complete documentation on its use of artificial intelligence models as part of a plan to improve its tax gap estimates, the Government Accountability Office said Wednesday.

  • June 05, 2024

    Californian Failed To Report Missing Income, Tax Court Says

    A California woman's contention that she should not be accountable for a deficiency in her 2021 tax filing due to what she said was an error by her accountant doesn't stand up under scrutiny, the U.S. Tax Court said Wednesday.

Expert Analysis

  • Don't Use The Same Template For Every Client Alert

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    As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

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    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

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    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.

  • Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks

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    Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

  • IRS Sings New Tune: Whistleblower Form Update Is Welcome

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    In a significant reform at the Internal Revenue Service's Whistleblower Office, the recently introduced revisions to the Form 211 whistleblower award application use new technology and a more intuitive approach to streamline the process of reporting allegations of tax fraud committed by wealthy individuals and companies, says Benjamin Calitri at Kohn Kohn.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.

  • Energy Community Tax Credit Boost Will Benefit Wind Sector

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    Recent Internal Revenue Service guidance broadening tax credit eligibility to more parts of offshore wind facilities in so-called energy communities is a win for the industry, which stands to see more projects qualify for a particularly valuable bonus in the investment tax credit context due to the capital-intensive nature of offshore wind projects, say attorneys at Troutman Pepper.

  • Weisselberg's Perjury At Trial Spotlights Atty Ethics Issues

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    Former Trump Organization executive Allen Weisselberg’s recent guilty plea for perjury in the New York attorney general's civil fraud trial should serve as a reminder to attorneys of their ethical duties when they know a client has lied or plans to lie in court, and the potential penalties for not fulfilling those obligations, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • Practicing Law With Parkinson's Disease

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    This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.

  • Why Supreme Court Should Allow Repatriation Tax To Stand

    If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.

  • Trump's NY Civil Fraud Trial Spotlights Long-Criticized Law

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    A New York court’s recent decision holding former President Donald Trump liable for fraud brought old criticisms of the state law used against him back into the limelight — including its strikingly broad scope and its major departures from the traditional elements of common law fraud, say Mark Kelley and Lois Ahn at MoloLamken.

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