Federal

  • 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.

  • May 03, 2024

    Medical Testing Co. Not In Health Field For Taxes, IRS Says

    A company that fills medical testing orders for its customers is nonetheless not a business involved in performing services in the health field for certain tax purposes, the Internal Revenue Service said in a private letter ruling released Friday.

  • May 03, 2024

    IRS May Again Extend Corp. AMT Penalty Relief, Official Says

    The Internal Revenue Service could again extend the penalty waiver for companies that fail to make estimated quarterly payments of the corporate alternative minimum tax, an agency official said Friday.

  • May 03, 2024

    US Trade Position Seen Contradicting Stance In Pillar 1 Talks

    The U.S. trade representative's withdrawal of support for digital trade proposals has caused tax policy observers to worry that the U.S. position on trade is undermining that of U.S. Treasury Department officials negotiating a taxing rights overhaul at the OECD known as Pillar One.

  • May 03, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, which included updated rates for foreign insurance company equations and an extension on excise tax relief for minimum plan distributions.

  • May 03, 2024

    Taxation With Representation: Skadden, Wachtell, Davis Polk

    In this week's Taxation With Representation, L'Occitane International said its executive director and chair is leading an offer to buy the company's shares he doesn't already own, UMB Financial agreed to purchase Heartland Financial USA, Medline said it agreed to acquire Ecolab's global surgical solutions business and The Mosaic Co. said it agreed to sell its stake in a phosphate production joint venture.

  • May 03, 2024

    IRS Can Assess Foreign Info Disclosure Penalty, DC Circ. Says

    The D.C. Circuit on Friday overturned a major U.S. Tax Court ruling that had struck down the Internal Revenue Service's authority to assess and administratively collect penalties from taxpayers for failing to file an information return on their interests in a foreign corporation.

  • May 03, 2024

    Final EV Tax Credit Regs Add New Battery Tracing Test

    The U.S. Treasury Department unveiled final regulations Friday for the up to $7,500 electric vehicle tax credit that include a more detailed process for automakers to trace the battery supply chain to qualify for the credit's domestic content requirements.

Expert Analysis

  • What New Calif. Strike Force Means For White Collar Crimes

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    The recently announced Central District of California strike force targeting complex corporate and securities fraud — following the Northern District of California's model — combines experienced prosecutorial leadership and partnerships with federal agencies like the IRS and FBI, and could result in an uptick in the number of cases and speed of proceedings, say attorneys at MoFo.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.

  • Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules

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    Regulations recently proposed by the IRS and the U.S. Department of the Treasury concerning two types of tax credits for clean hydrogen production facilities should resolve many of the most pressing questions around qualification for the credits — albeit in a relatively stringent manner, say attorneys at Morgan Lewis.

  • Employee Experience Strategy Can Boost Law Firm Success

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    Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.

  • Lessons From Country Singer's Personal Service Saga

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    Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.

  • 5 Litigation Funding Trends To Note In 2024

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    Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.

  • Tech CEO Tax Ruling A Warning For Forward Contracts

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    In McKelvey v. Commissioner, the U.S. Tax Court decided that deceased Monster.com founder Andrew McKelvey terminated his underlying obligations when he extended variable prepaid forward contracts, demonstrating why startup founders, early employees and investors should think carefully before amending derivative agreements, say Daren Shaver and Trent Tanzi at Hanson Bridgett.

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