Federal

  • May 15, 2024

    Schulte Roth Adds Ex-Kleinberg Kaplan Partner To Tax Group

    Schulte Roth & Zabel LLP added a former Kleinberg Kaplan Wolff & Cohen PC partner with a focus on private investment funds to its tax group in New York.

  • May 15, 2024

    11th Circ. Judge Doubts Defense Of IRS Easement Notice

    An Eleventh Circuit judge was skeptical Wednesday of the government's arguments that the Internal Revenue Service could issue a notice imposing reporting requirements on potentially abusive conservation easements without soliciting public feedback that administrative law requires.

  • May 15, 2024

    3 Key Takeaways From Floated Foreign Trust Reporting Rules

    Proposed rules for reporting transactions with foreign trusts recently issued by the U.S. Treasury Department provide breathing room on disclosure requirements for certain offshore retirement accounts, but leave open some questions about classification. Here, Law360 breaks down three sections of the proposed foreign trust reporting regulations.

  • May 15, 2024

    House Judiciary Chair Seeks Docs On IRS Backdating Probe

    The House Judiciary Committee's Republican chairman asked an IRS watchdog to reveal findings from investigations into allegations of IRS employee misconduct, including in a high-profile $38 million conservation easement deduction case in which the agency admitted to backdating evidence.

  • May 15, 2024

    Senate Finance Panel Schedules Hearing On Tax Accounts

    The Senate Finance Committee will meet next week to discuss investment in tax-advantaged accounts and its impact on children, the committee said Wednesday.

  • May 15, 2024

    Pardoned NJ Atty Suspended Over Tax, Fraud Convictions

    A former Gilmore & Monahan PA partner — who was convicted of failing to pay payroll taxes and lying on a loan application, and was pardoned by then-President Donald Trump — has received a two-year suspension from practicing law in New Jersey, though it will be largely offset by a previous suspension he served, according to a Wednesday order. 

  • May 15, 2024

    IRS Not On Hook For Ohio Woman's Legal Fees, Court Says

    The Internal Revenue Service is not liable to pay nearly $87,000 in legal fees of an Ohio woman because the agency's position was "substantially justified" throughout the woman's pursuit of a refund, the U.S. Tax Court ruled Wednesday.

  • May 15, 2024

    Applicable Federal Interest Rates To Rise In June

    Applicable federal rates for income tax purposes will increase in June, the Internal Revenue Service said Wednesday.

  • May 15, 2024

    IRS Issues Static Mortality Tables For 2025 Defined Plans

    The Internal Revenue Service on Wednesday released the updated static mortality tables used to calculate the funding target and other items for defined benefit pension plans during the 2025 calendar year.

  • May 15, 2024

    Pension Plan Segment Rates Increase In May

    Segment rates for calculating pension plan funding rose in May, the Internal Revenue Service said Wednesday.

  • May 15, 2024

    IRS Working To Prevent Child Support Collection Disruption

    The Internal Revenue Service is working to prevent disruption of federal tax refund offsets — including garnishment for owed child support — affecting Native American tribal governments and other taxpayers, the agency said.

  • May 14, 2024

    Northwestern Settles Tax Law Prof's Age Bias Suit

    Northwestern University agreed to settle a law school professor's age bias suit filed in Illinois federal court claiming he was given smaller raises year-over-year in comparison with his younger colleagues after he cast aside the institution's push for him to retire early.

  • May 14, 2024

    Law Prof Comes To Treasury's Aid In 3M Transfer Pricing Fight

    The U.S. Department of the Treasury did not act arbitrarily when it wrote transfer pricing regulations that allowed the government to disregard foreign legal restrictions on royalty payments when allocating income to 3M from an affiliate, a law professor told the Eighth Circuit on Tuesday.

  • May 14, 2024

    Yellen, Werfel Urged To Make E-Filing Program Permanent

    The Internal Revenue Service's pilot program for free electronic tax return filing should be made permanent and grown, a coalition of groups that endorse the project told IRS Commissioner Daniel Werfel and Treasury Secretary Janet Yellen in a letter Tuesday.

  • May 14, 2024

    Billionaire's Pilot Cops To Tax Count, Avoids Insider Trial

    A pilot from Virginia accused of profiting from stock tips fed to him by British billionaire Joe Lewis on Tuesday copped to dodging taxes on $500,000 of income from Lewis' company, in a plea deal that avoids an insider trading trial.

  • May 14, 2024

    Microsemi Calls IRS' Penalty Approval 'Woefully Inadequate'

    An Internal Revenue Service supervisor's sign-off on a transfer pricing penalty for Microsemi was "woefully inadequate" to meet statutory requirements for penalty approval, the semiconductor manufacturer told the U.S. Tax Court.

  • May 14, 2024

    Ex-Husch Blackwell, Dykema Atty Pleads Guilty To Tax Evasion

    A former Husch Blackwell LLP partner who helped launch Dykema Gossett PLLC's Milwaukee office two years ago has agreed to plead guilty in Wisconsin federal court to willfully evading paying income tax, which could land him in prison for over a year and will force him to pay almost $4 million in restitution to the IRS.

  • May 14, 2024

    Big Refund Filings Could Be Improper, IRS Says

    Inaccurate advice from social media, as well as a series of tax scams, has resulted in an increase in questionable, inflated refund claims, the Internal Revenue Service said Tuesday.

  • May 14, 2024

    ER Doc Can't Deduct His Film Co.'s Costs, 5th Circ. Told

    An emergency room doctor with a passion for music was correctly denied business deductions for his unprofitable production company, the IRS told the Ninth Circuit in asking it to uphold a U.S. Tax Court ruling that found the doctor owed more than $59,000 in taxes and penalties.

  • May 14, 2024

    IRS Floats Property Rule Changes On Interest Capitalization

    The Internal Revenue Service floated changes Tuesday to the interest capitalization requirements for improvements constituting property production, including removing the so-called associated property rule that was invalidated by the Federal Circuit.

  • May 14, 2024

    Ex-Whiteford Taylor Business Co-Chair Joins Baker Donelson

    Baker Donelson Bearman Caldwell & Berkowitz PC has welcomed a new shareholder who spent more than a decade with the Internal Revenue Service and previously co-chaired Whiteford Taylor & Preston LLP's business department, the firm announced on Monday.

  • May 14, 2024

    IRS Finalizes Slash Of Preparer ID Fee

    The Internal Revenue Service will reduce the cost to apply for or renew a preparer tax identification number by nearly 50%, the agency said in a final rule released Tuesday.

  • May 13, 2024

    NJ Fraudster Gets More Prison Time, Owes $6M For Tax Evasion

    A New Jersey man who was convicted of dodging taxes on more than $16 million he stole from securities fraud victims was handed a six-year prison sentence — most of which will be served simultaneously with his fraud sentence — and ordered to pay over $6 million in restitution during a Garden State federal court hearing Monday in which he denied the crimes. 

  • May 13, 2024

    Corp. Transparency Act An Overbroad Dragnet, 11th Circ. Told

    Congress exceeded its authority in passing the Corporate Transparency Act, which prompted the U.S. Treasury Department to solicit personal information for law enforcement purposes from those that registered and owned state-registered entities, a small-business group told the Eleventh Circuit on Monday.

  • May 13, 2024

    US Tells DC Circ. Ayahuasca Church's Settlement Inapt

    Federal regulators are telling the D.C. Circuit to ignore a recent settlement that will allow a Phoenix-based church to continue using ayahuasca in its ceremonies, saying it has nothing to do with the Iowa-based ayahuasca church challenging the IRS's refusal to give it tax-exempt status.

Expert Analysis

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.

  • Employers, Prep For Shorter Stock Awards Settlement Cycle

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    Companies that provide equity compensation in the form of publicly traded stock will soon have one less day to complete such transactions under U.S. Securities and Exchange Commission and Nasdaq rules — so employers should implement expedited equity compensation stock settlement and payroll tax deposit procedures now, say attorneys at Morgan Lewis.

  • Demystifying IRS' Claims Of $851B Return On Investment

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    The IRS' recently released analysis, estimating a $851 billion return on the government’s $80 billion investment in the agency, represents a huge increase over its 2022 estimate and that of the Congressional Budget Office and may be best viewed as a best-case scenario, says Joyce Beebe at the Baker Institute.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • A Proposal For Fairer, More Efficient Innocent Spouse Relief

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    Adding a simple election to the current regulatory framework for innocent spouse claims would benefit both taxpayers and the Internal Revenue Service by alleviating the undue burdens placed on those the program was intended to help and improving agency collections in such cases, says Laurie Kazenoff at Kazenoff Tax.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • Proposed Hydrogen Tax Credit Regs May Be Legally Flawed

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    While the recently proposed regulations for the new clean hydrogen production tax credit have been lauded by some in the environmental community, it is unclear whether they are sufficiently grounded in law, result from valid rulemaking processes, or accord with other administrative law principles, say Hunter Johnston and Steven Dixon at Steptoe.

  • Navigating ACA Reporting Nuances As Deadlines Loom

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    Stephanie Lowe at Liebert Cassidy walks employers through need-to-know elements of Affordable Care Act reporting, including two quickly approaching deadlines, the updated affordability threshold, strategies for choosing an affordability safe harbor, and common coding pitfalls.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • Why Biz Groups Disagree On Ending Chevron Deference

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    Two amicus briefs filed in advance of last month's U.S. Supreme Court oral arguments in Loper Bright Enterprises v. Raimondo highlight contrasting views on whether the doctrine of Chevron deference promotes or undermines the stable regulatory environment that businesses require, say Wyatt Kendall and Sydney Brogden at Morris Manning.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Look Ahead For The Electric Vehicle Charging Industry

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    This will likely be an eventful year for the electric vehicle market as government efforts to accelerate their adoption inevitably clash with backlash from supporters of the petroleum industry, say Rue Phillips at SkillFusion and Enid Joffe at Green Paradigm Consulting.

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

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