Federal
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March 12, 2024
US, Turkey Extend Digital Services Tax Deal
Turkey will continue to apply its digital services tax as negotiations over the Pillar One international profit reallocation agreement continue, the country said Tuesday in a joint statement with the U.S. government
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March 11, 2024
'I Made A Huge Mistake,' Software Exec Says In Tax Fraud Trial
Two former software executives in North Carolina took the stand Monday in the government's tax fraud trial against them, where they portrayed a company in extreme distress as hundreds of thousands of dollars in employment taxes went unpaid and their personal lives crumbled.
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March 11, 2024
FedEx Says Gov't Can't Redo $85M Foreign Tax Credit Case
The U.S. government is trying to relitigate a Tennessee federal court's decision that sided with FedEx in a foreign tax credit dispute, the company said in asking the court to rule that it's entitled to a refund of nearly $85 million.
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March 11, 2024
Electronics Co. Disputes $187M Income Tax Bill From IRS
The Internal Revenue Service erroneously increased the income tax liability of an audio electronics company by $187 million, the business argued in a U.S. Tax Court petition.
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March 11, 2024
Biden Proposes Increased Wealth Taxes In $7.3T Budget Plan
The White House unveiled its $7.3 trillion budget plan for fiscal 2025 on Monday, proposing higher taxes on wealthy corporations and individuals, expanding tax relief for Americans making under $400,000 per year and cutting the federal deficit by $3 trillion over the next decade.
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March 11, 2024
US Appeals Corporate Transparency Act Ruling To 11th Circ.
The U.S. Department of the Treasury is moving quickly to appeal an Alabama federal judge's ruling that the Corporate Transparency Act is unconstitutional, filing a notice of appeal to the Eleventh Circuit on Monday.
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March 11, 2024
Tax Court Turns Down Late-Filed Spousal Petition
The U.S. Tax Court ruled Monday that it lacked authority to hear a man's case for innocent spouse relief because he failed to file a petition within the 90-day deadline, holding that Congress clearly stated the deadline is jurisdictional.
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March 11, 2024
DC Circ. Mulls Tax-Exempt Status For Ayahuasca Church
A D.C. Circuit panel on Monday pushed counsel for an Iowa church that uses the psychedelic substance ayahuasca in its ceremonies to explain why the Internal Revenue Service erred in denying it tax-exempt status.
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March 11, 2024
Chippewa Lawyer Owes Taxes Despite Treaty, 8th Circ. Told
An attorney who belongs to the Minnesota Chippewa Tribe is not exempt from federal self-employment taxes under an 1837 treaty allowing Native Americans to earn money from hunting and gathering on their traditional lands, the U.S. government told the Eighth Circuit.
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March 11, 2024
CPAs Call For Broad Guidance On Excess Business Losses
The Internal Revenue Service is past due for issuing guidance clarifying the limitation on excess business losses of noncorporate taxpayers, the American Institute of Certified Public Accountants said in a letter made public Monday.
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March 11, 2024
Tax Court Cuts Majority Of Ohio Tax Preparer's Biz Deductions
An Ohio tax preparer will receive less than half of the $18,000 in deductions she claimed on her personal income taxes after failing to substantiate a portion of them as business expenses, the U.S. Tax Court ruled Monday.
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March 11, 2024
Fla. Tax Law Firm Fights Class Cert. In Wisconsin Fraud Row
A Florida-based tax law firm has asked a Wisconsin federal judge to trim a proposed class action fraud suit launched by former customers claiming the firm solicited fees without performing work.
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March 11, 2024
Senate Finance Panel To Meet Tuesday On Manufacturing
The Senate Finance Committee is scheduled to meet Tuesday to discuss congressional efforts for encouraging progress and investment in domestic manufacturing, according to a notice Monday.
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March 08, 2024
IRS Leaker Should Be Deposed Without All Docs, Judge Says
Attorneys for a hedge fund executive should question the former IRS contractor who admitted to stealing the tax returns of him and others, even though the IRS hasn't finished producing evidence in the case seeking to hold the agency responsible for the leak, a Florida federal judge said Friday.
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March 08, 2024
Hunter Biden's Trump Conspiracy Theory Baseless, US Says
Hunter Biden's claim that former President Donald Trump is improperly driving his criminal prosecution on nine counts of tax violations is nothing more than a baseless conspiracy theory, the U.S. government told a California federal court Friday, arguing against Biden's efforts to get the case tossed.
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March 08, 2024
Certain Tax Policy Can Improve Taxpayer Incentives, JCT Says
Tax policy affecting marginal tax rates can enhance taxpayers' incentives to work, save and invest their earnings, the Joint Committee on Taxation said in a report published Friday.
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March 08, 2024
Taxation With Representation: Fried Frank, Latham
In this week's Taxation with Representation, Viavi acquires Spirent, Cadence Design Systems purchases Beta Cae Systems International, and United Rentals buys Yak.
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March 08, 2024
Direct Pay Regs Would Lift Major Barrier For Energy Projects
A U.S. Treasury Department proposal to give partnerships access to direct payments of tax credits for green energy projects would lift a significant barrier that has prevented tribes, municipalities, schools and nonprofits from capitalizing on joint ownership arrangements.
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March 08, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service issued its weekly bulletin, which included information on the tax treatment of certain lead pipe replacement projects.
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March 07, 2024
Don't Let Pillar 1 Die, Policy Experts Tell House Tax Panel
Tax policy experts encouraged a U.S. House subcommittee Thursday to continue negotiations at the Organization for Economic Cooperation and Development over the taxing rights overhaul known as Pillar One and advocate for stronger double taxation relief and tougher language eliminating digital service taxes.
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March 07, 2024
Ex-Mass. Senator's Aide Gets Short Prison Term For Tax Fraud
The former chief of staff to a Massachusetts state senator was sentenced Wednesday in federal court to 30 days in prison for failing to report income she was receiving from a business she owned and other jobs while collecting her state salary.
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March 07, 2024
Jailed Reality Star Slammed For Raising 'Irrelevant' Evidence
Less than a month ahead of trial, a Georgia Department of Revenue employee suing imprisoned former reality television star Michael "Todd" Chrisley has asked a Georgia federal judge to stop Chrisley from bringing in evidence she says is "irrelevant" to the defamation case she brought against him.
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March 07, 2024
Nonprofits Can E-File 2023 Extensions Later This Month
Tax-exempt organizations will be able to electronically file applications for extensions on returns including Form 990 starting March 17, when an Internal Revenue Service delay that impeded the filings ends, an agency official said Thursday.
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March 07, 2024
Disability Payments Are Gross Income, Tax Court Rules
More than $1,500 in disability payments received by a Texas couple must be included in their gross income, the U.S. Tax Court ruled Thursday.
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March 07, 2024
Tax Tipster Who Reported Family Loses DC Circ. Award Fight
A man who reported his siblings for tax fraud and received a whistleblower award wasn't entitled to more money, the D.C. Circuit ruled, saying the IRS was correct in reducing the amount after concluding the man, a manager in the family business, likely participated in the fraud.
Expert Analysis
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Attorneys, Law Schools Must Adapt To New Era Of Evidence
Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.
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1st Tax Easement Convictions Will Likely Embolden DOJ, IRS
After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.
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Tips For Litigating Against Pro Se Parties In Complex Disputes
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.
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Anticipating Intensified Partnership Enforcement From IRS
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.
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Pro Bono Work Is Powerful Self-Help For Attorneys
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.
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The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'
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.
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Newman Suspension Shows Need For Judicial Reform
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.
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How And Why Your Firm Should Implement Fixed-Fee Billing
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.
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How Law Firms Can Use Account-Based Marketing Strategies
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.
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While Risks Exist, AI Could Transform IRS Enforcement
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.
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Strategic Succession Planning At Law Firms Is Crucial
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.
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Maximizing Law Firm Profitability In Uncertain Times
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.
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Enforcement Of International Tax Reporting Is Heating Up
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.