Federal

  • May 08, 2024

    TCJA Extension Would Cost $4.6T, CBO Report Says

    Extending the provisions of the Tax Cuts and Jobs Act for 10 years under a proposal from Republicans would increase the U.S. deficit by $4.6 trillion, according to a report issued Wednesday by the Congressional Budget Office after a request from Democratic senators.

  • May 08, 2024

    DOJ Says Man Owes $6.2M After Failing To Report Foreign Biz

    A man owes tax penalties of $6.2 million to the U.S. after failing to disclose his ownership interests in two foreign entities from 1997 to 2004, the government told a California federal court Wednesday.

  • May 08, 2024

    Biz Groups Tell 10th Circ. Economic Substance Doesn't Apply

    The economic substance doctrine doesn't apply when a business considers tax in making a choice between two legally permissible alternatives, two organizations told the Tenth Circuit in their briefs supporting Liberty Global's position in its $109 million tax refund bid.

  • May 08, 2024

    4th Circ. Asks If High Court Ruling Bars Credit Suisse Tipster

    A Fourth Circuit panel questioned Wednesday whether a U.S. Supreme Court ruling prevented it from reviving a whistleblower case by a former Credit Suisse employee alleging the bank helped U.S. citizens evade taxes after paying a $2.6 billion criminal penalty.

  • May 08, 2024

    Auto Cos. Brace For EV Battery Compliance Hurdles

    New federal regulations aimed at shoring up the domestic electric vehicle manufacturing supply chain give automakers a much-needed two-year cushion to navigate a compliance minefield, and to figure out how to reinvigorate the recent waning consumer demand for electric vehicles.

  • May 08, 2024

    Minn. Man Sentenced To Prison For Role In $6.7M Fraud

    A Minnesota man was sentenced in federal court to 108 months in prison and told to pay more than $4.7 million in restitution for running a scheme that led to the filing of false tax returns that caused roughly $6.7 million in tax losses, the U.S. Department of Justice said.

  • May 08, 2024

    Ambulance Co.'s Former Owner Gets 6 Years For Tax Evasion

    The former owner of an ambulance company was sentenced to more than six years in federal prison for failing to pay employment taxes to the federal government and obstructing the Internal Revenue Service as it tried to collect, according to Virginia federal court documents.

  • May 08, 2024

    A Foley Hoag Co-Chair Joins Litigation Firm As Name Partner

    Litigation and dispute resolution firm Elliott Kwok Levine & Jaroslaw LLP will operate under a new name after welcoming as its newest name partner a former federal prosecutor who most recently co-chaired Foley Hoag LLP's white-collar crime and government investigations practice.

  • May 08, 2024

    DOD Trucking Contractor Owner Indicted On $1M Tax Evasion

    The owner of a trucking company that hauled military supplies for the U.S. Department of Defense tried to evade more than $1 million in taxes partly by using a nominee company headed by her former dispatcher, according to an indictment by a federal grand jury in Ohio.

  • May 08, 2024

    Offshore Drilling Co. Demands $70M Refund From IRS

    The IRS wrongfully withheld $69.7 million in tax refunds to an offshore drilling company, despite acknowledging that the refunds are justified by net operating loss carrybacks authorized by a pandemic law and then promising to pay, the company said in Texas federal court.

  • May 07, 2024

    Biz Orgs. Ask 10th Circ. To Toss Economic Substance Ruling

    The Tenth Circuit must not uphold a Colorado federal court's ruling that it didn't need to determine whether economic substance doctrine was relevant before disallowing an intercompany transaction by Liberty Global Inc., three business groups told the Tenth Circuit in briefs Tuesday.

  • May 07, 2024

    Tax Software Co. Still Can't Trim Rival's Trade Secrets Suit

    A corporate-focused tax preparation software company still can't pare back a suit alleging that it poached workers from its rival's recently acquired company, a Pennsylvania federal judge ruled Tuesday.

  • May 07, 2024

    IRS Urged To Limit Scope Of Donor Fund Rules

    Proposed IRS regulations on donor-advised funds should be changed to limit their scope so they don't subject other types of funds to taxes and reporting requirements, stakeholders said Tuesday during a second day of a hearing on the proposal.

  • May 07, 2024

    6th Circ. Considers Rebooting Crypto Reporting Challenge

    Sixth Circuit judges seemed unsure of whether a group of cryptocurrency users can challenge a pending mandate to report large crypto transactions, as the judges grappled Tuesday with whether the plaintiffs have shown they are harmed by the forthcoming rule and whether the challenge is premature.   

  • May 07, 2024

    Think Tank Projects Broad Tax Hikes If TCJA Expires

    Most U.S. taxpayers would see substantially increased tax bills if the individual provisions of the Tax Cuts and Jobs Act are allowed to expire at the end of 2025, the Tax Foundation said Tuesday.

  • May 07, 2024

    Industry Groups Suggest Changes To Aussie Reporting Rules

    A coalition of global fund industry associations asked Australia to further amend its proposal for public country-by-country tax data reporting by including, among other measures, a provision that would allow companies to withhold sensitive information, according to a letter released Tuesday by the U.S. Treasury Department.

  • 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.

Expert Analysis

  • Tips For Litigating Against Pro Se Parties In Complex Disputes

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    Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.

  • 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.

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