Federal
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April 18, 2024
$32B More In Tax Yielded In Fiscal '23 Closed Audits, IRS Says
The Internal Revenue Service closed nearly 583,000 tax return audits in fiscal year 2023, resulting in $31.9 billion of recommended additional tax after examination, the agency said Thursday in its annual data book.
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April 18, 2024
Atty In Tax Fraud Must Pay Full $2.5M Per Plea Deal, Feds Say
A former Houston attorney set to be sentenced Friday for his role in an $18 million offshore tax scheme is trying to limit the government's ability to collect $2.5 million in restitution he promised to pay in a plea agreement last year, prosecutors told a Texas federal court Thursday.
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April 18, 2024
IRS Seeks Advisory Council Noms, Creates Fairness Panel
The Internal Revenue Service is seeking nominations for the council that advises the agency's commissioner, the IRS said Thursday, while the council is also launching a new subcommittee on fairness in tax administration.
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April 18, 2024
Transfer Pricing And Dancing: Recalling KPMG's Sean Foley
Sean Foley, who died suddenly in September, was a devoted husband, father, brother and friend and a brilliant colleague. He was one of the world's top experts in an area of international tax known as transfer pricing, where he became the global leader of KPMG's practice.
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April 18, 2024
IRS Adds 2nd Public Hearing Day On Donor-Advised Regs
The Internal Revenue Service has added a second, telephone-only public hearing in May on proposed regulations on excise taxes on certain taxable distributions made from donor-advised funds, the agency announced Thursday.
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April 17, 2024
'I Am Mad': Client Regrets Trusting Atty Accused Of Tax Fraud
Emotions ran high Wednesday in a North Carolina federal courtroom as former clients unwittingly roped into an alleged tax fraud scheme took the stand, one of whom was openly exasperated at learning he'd been misled by the two attorneys and an insurance agent who are on trial.
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April 17, 2024
Damages Still Possible In Lease Tax Reimbursement Row
A Court of Federal Claims judge has ruled that the General Services Administration could unilaterally adjust the real estate tax reimbursement methodology under a lease for the Defense Health Agency's headquarters building, but the building owner may still be owed damages.
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April 17, 2024
EV Tax Credit Restrictions, Trade Bills Advance In House
The House Ways and Means Committee advanced several trade bills Wednesday that would impose more restrictions for new electric vehicles to qualify for a federal tax credit, assert congressional authority in agreements with foreign governments, and renew the country's largest and oldest trade preferences program.
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April 17, 2024
$22B In Earned Income Tax Credits Wrongly Handed Out
The U.S. Treasury Department improperly allowed an estimated $22 billion in earned income tax credits during fiscal year 2023, according to a report made public Wednesday by the Government Accountability Office.
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April 17, 2024
EmblemHealth Pushes IRS To Hand Over $6.7M Tax Refund
Not-for-profit insurance company EmblemHealth asked a New York federal court Wednesday to grant it a nearly $6.7 million tax refund, saying the Internal Revenue Service left a voicemail accepting its refund claim in February but still hasn't delivered the money.
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April 17, 2024
Utility Energy Subsidies Not Eligible For Credits, IRS Says
A taxpayer may not claim certain clean energy credits for the amount of a subsidy provided by a public utility for the purchase or installation of energy conservation measures, the Internal Revenue Service said Wednesday.
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April 17, 2024
Tax Court Rejects NJ Lawyer's Protest Of IRS Collection
The Internal Revenue Service didn't abuse its discretion when it denied a New Jersey lawyer's request for collection alternatives, the U.S. Tax Court ruled Wednesday.
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April 17, 2024
9th Circ. Tosses $3.9M Tax Foreclosure Appeal As Premature
The Ninth Circuit dismissed a man's challenge to a court order that he believed allowed the government to foreclose on his property to pay his son's tax liabilities of more than $3.9 million, saying Wednesday that the appeal was premature because the order wasn't final.
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April 17, 2024
Judge Delays Trial Over $20M Allegedly Hidden From IRS
A Florida federal judge agreed Wednesday to delay the trial of a Brazilian-American businessman accused of hiding $20 million from the Internal Revenue Service by using Swiss bank accounts, but told the defendant the new deadlines are firm.
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April 17, 2024
Loeb & Loeb Adds 2 Corporate Partners From Morrison Cohen
Loeb & Loeb LLP has announced the latest in a string of corporate hires from Morrison Cohen LLP's ranks, touting two new partners with domestic and international experience with strategic transactions.
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April 17, 2024
4th Circ. Affirms No Shield From IRS For Home In Bankruptcy
A North Carolina man who filed for bankruptcy protection and owes federal tax debt cannot shield the house he owns with his wife from the Internal Revenue Service, which is pursuing the asset as a creditor in the proceedings, the Fourth Circuit affirmed Wednesday.
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April 17, 2024
Financial Planner Gets Prison For Tax Shelter Fraud Scheme
A Cleveland financial planner who colluded with a Florida attorney to promote an illegal tax scheme using fake charitable donations to score deductions for his company's high-income clients was sentenced Tuesday to 20 months in prison for his part in the fraud.
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April 17, 2024
IRS Finds Success Against 'Ghost Employers,' TIGTA Says
The Internal Revenue Service has successfully prosecuted 33 cases against employers who issue W-2 forms to workers but fail to remit payroll taxes, the Treasury Inspector General for Tax Administration said Wednesday.
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April 16, 2024
Corp. Transparency Act A Valid Use Of Powers, 11th Circ. Told
The U.S. Department of Treasury told the Eleventh Circuit that a federal district court erred in finding the Corporate Transparency Act unconstitutional, saying the lower court misunderstood the law's scope and relation to efforts to curb financial crime.
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April 16, 2024
Nothing 'Sinister' About Attys, Broker's Tax Plan, NC Jury Told
Two St. Louis attorneys and a North Carolina insurance agent on Tuesday tried to poke holes in an undercover IRS agent's investigation of what the government has characterized as a criminal tax avoidance scheme, which defense counsel sought to paint for the jury as a legal interpretation of federal tax law.
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April 16, 2024
Biden Pushes For Permanent Premium Tax Credit Expansion
President Joe Biden said Tuesday that should he be reelected one of his first actions would be to seek to make permanent the expansions that were made to the health insurance premium tax credit to increase eligibility and lower premiums.
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April 16, 2024
Veteran's Signature On IRS Doc Not Forged, Tax Court Finds
U.S. Air Force veteran and his wife failed to convince the U.S. Tax Court on Tuesday that their signatures were forged on an agreement to pay federal income taxes while working in Australia for defense contractor Raytheon.
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April 16, 2024
GOP Senators Call IRS' E-File Program Too Costly
Senate Republicans continued to criticize the Internal Revenue Service's free tax filing pilot program during a Finance Committee hearing Tuesday, saying the program has not followed best practices and will be costly to implement long term.
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April 16, 2024
IRS Publishes 2024 Average Residence Purchase Price Data
The Internal Revenue Service published data Tuesday on the average purchase price for U.S. residences in different areas, which is used to determine whether bond interest can be excluded from gross income.
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April 16, 2024
IRS Extends Excise Tax Relief For Min. Plan Distribution
Plans that fail to make certain required minimum distributions in 2024 will not be assessed an excise tax under changes made to retirement plan legislation, the Internal Revenue Service said in guidance released Tuesday.
Expert Analysis
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Planning A Defense As IRS Kicks Off Sports Losses Campaign
Sports team owners and partnerships face potential examination under the Internal Revenue Service’s recently announced sports industry losses campaign, and should be preparing to explain what drove their reported losses and assembling documentation to support their tax return positions and accounting methods, say Sheri Dillon and Jennifer Breen at Morgan Lewis.
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What New Calif. Strike Force Means For White Collar Crimes
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.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
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.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
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.
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As Promised, IRS Is Coming For Crypto Tax Evaders
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.
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5 Reasons Associates Shouldn't Take A Job Just For Money
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.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
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.
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Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules
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.
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Employee Experience Strategy Can Boost Law Firm Success
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.
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6 Practice Pointers For Pro Bono Immigration Practice
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.
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Lessons From Country Singer's Personal Service Saga
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.
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7 E-Discovery Predictions For 2024 And Beyond
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.
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5 Litigation Funding Trends To Note In 2024
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.