Federal

  • May 20, 2024

    Baker McKenzie Ends FOIA Suit Over IRS Partnership Audits

    A Baker McKenzie attorney has dropped a public records lawsuit against the Internal Revenue Service that sought to compel the agency to turn over documents pertaining to its scrutiny of large partnerships.

  • May 20, 2024

    Feds Fight Proposed Delay In Hunter Biden's Tax Trial

    Hunter Biden shouldn't be allowed to delay his criminal tax trial in California just because his lead attorney says the dates run up against Biden's upcoming trial in Delaware on firearms charges, the special counsel's office told a federal court.

  • May 20, 2024

    House Dem Bill Would Let Education Savings Cover Transport

    Students would be able to use tax-advantaged educational savings accounts to cover transportation and parking costs under a bill introduced by a pair of Democrats in the House of Representatives.

  • May 20, 2024

    US, Argentina To Carry Out 1st FATCA Info Exchange

    The Internal Revenue Service approved cybersecurity measures by Argentina in a step that clears the way for the first automatic information exchange under the Foreign Account Tax Compliance Act between the two countries in September, Argentina's revenue service said Monday.

  • May 17, 2024

    Med Device Co. Allowed $160M In Deductions, Tax Court Told

    A tax code provision in place before the 2017 federal tax overhaul changed it allows a medical device manufacturer to claim more than $160 million in deductions for dividends despite the government's attempt to apply the law retroactively, company counsel told the U.S. Tax Court on Friday.

  • May 17, 2024

    Home Distillers Tell Feds Ban Fails Under Spirit Of The Law

    The Hobby Distillers Association said the federal government is exceeding its constitutional powers and treading on states' rights by banning homemade liquor under its taxing authority, as the group laid out its position Friday at the request of a Texas federal judge.

  • May 17, 2024

    Michigan Doctor Seeks Release From Contempt In FBAR Fight

    A Michigan doctor incarcerated for civil contempt in a case in which he was ordered to repay more than $1 million in penalties for failure to report foreign accounts should be freed because he can no longer satisfy the terms of his release, he told a Michigan federal court.

  • May 17, 2024

    Koch-Tied Group Says Transparency Law Offends Federalism

    The Corporate Transparency Act is unconstitutional because it does not regulate interstate commerce yet mandates that state-registered entities disclose personal information, a conservative group affiliated with the billionaire Koch brothers told the Eleventh Circuit on Friday.

  • May 17, 2024

    Feds Want Prison For Kiosk Salesman Who Faked Deductions

    An electronic-sweepstakes kiosk salesman from Chicago should spend more than two years in prison for submitting false tax returns that fabricated more than $400,000 in business expenses and more than $60,000 in church donations, federal prosecutors told an Illinois federal court.

  • May 17, 2024

    New Domestic Content Guidance May Boost Energy Credits

    The U.S. Treasury Department's new guidance on bonus tax credits for clean energy projects that source domestic-made materials and components aims to simplify the process for determining eligibility and spur more development to get those extra incentives.

  • May 17, 2024

    Funding Uncertainty Hasn't Affected Plans, IRS Official Says

    Political uncertainty about the Internal Revenue Service's future funding hasn't affected the agency's operations planning, the agency's deputy commissioner said Friday at a Tax Council Policy Institute conference in Washington, D.C.

  • May 17, 2024

    Transfer Pricing Deal Needed For Pillar 1, OECD Official Says

    It's crucial for countries to agree on transfer pricing policies under an international profit reallocation agreement known as Pillar One as they work toward their end-of-June deadline to sign a related multilateral treaty, an OECD official said Friday.

  • May 17, 2024

    Judge Sets Hearing For Delay In Hunter Biden's Tax Trial

    A California federal judge agreed Friday to consider Hunter Biden's request to push back his $1.4 million criminal tax trial, setting a hearing to address his claim that the dates interfere with his Delaware gun trial and threaten to prevent him from getting a fair shake.

  • May 17, 2024

    Taxation With Representation: Wachtell Lipton, Freshfields

    In this week's Taxation with Representation, Nippon Life acquires Corebridge Financial, Crescent Energy buys SilverBow Resources and Uber purchases Foodpanda.

  • May 17, 2024

    Virgin Islands Silent 2 Years On $1.1M Tax Refund, Court Told

    A man living on the island of St. Thomas claims he requested a tax refund of more than $1.1 million from the U.S. Virgin Islands Bureau of Internal Revenue more than two years ago and still hasn't heard back, according to a complaint in federal court.

  • May 16, 2024

    Pillar 1 Faces Hard June Deadline, Ex-Treasury Official Says

    An international agreement to reallocate certain corporate profits, known as Pillar One, will likely stall if countries miss their deadline to sign a multilateral treaty by the end of June, a former U.S. Treasury official said Thursday.

  • May 16, 2024

    Hubby Liable For Ex-Co. President's $40M Bill, Tax Court Says

    The husband of a former president of InfoSpace can be held jointly liable for a nearly $40 million tax debt the IRS asserted against a return they filed for the 2000 tax year, the U.S. Tax Court ruled Thursday, saying he didn't qualify for so-called innocent spouse relief.

  • May 16, 2024

    P&G Exec Says FDII Uncertainty May Sway Cos.' IP Decisions

    The 2017 tax overhaul's measure for foreign-derived intangible income, a regime that gives tax breaks for domestically held intellectual property, faces uncertainty that could be one factor in keeping some companies from repatriating IP, a tax executive for Procter & Gamble said Thursday.

  • May 16, 2024

    Democrats Prod Justice Thomas on RV Loan, Tax Treatment

    Two Senate Democrats have asked U.S. Supreme Court Justice Clarence Thomas' attorney to respond to what they called a failure to answer their questions about the justice's $267,000 loan from a healthcare industry executive to finance a luxury recreational vehicle, saying the loan treatment could have violated federal tax laws.

  • May 16, 2024

    Eaton Must Give Up Personnel Docs In Transfer Pricing Probe

    Eaton must comply with an Internal Revenue Service summons for the personnel records of its foreign employees in the government's transfer pricing investigation of the multinational power management company, an Ohio federal judge ruled Thursday.

  • May 16, 2024

    House Dems Seek Vote On Disaster Tax Relief Bill

    Two Democrats on the House of Representatives' Ways and Means Committee requested a vote Thursday on legislation that would exclude disaster relief payments from a taxpayer's gross income.

  • May 16, 2024

    TCJA Renewal Tied To Fate Of Senate Bill, Finance Chair Says

    If Senate lawmakers can't pass a bipartisan House bill extending three business provisions and expanding a child tax credit, the hope of a larger deal to renew the 2017 GOP tax overhaul next year seems unlikely, the chair of the Senate Finance Committee said Thursday.

  • May 16, 2024

    House Ways And Means To Discuss Rust Belt Economy

    The House of Representatives' Ways and Means Committee will meet to discuss economic opportunities in the Rust Belt region May 20, the committee said Thursday.

  • May 16, 2024

    Firm Seeks To Force IRS To Process Worker Retention Credits

    A tax advisory firm helping businesses apply for the pandemic-era employee retention credit has asked an Arizona federal court to force the IRS to resume processing claims, saying the moratorium in place since September violates the Administrative Procedure Act.

  • May 16, 2024

    Ex-Minn. Public Defender Gets Probation For Tax Fraud

    A former Minneapolis chief public defender who argued that he should receive a lenient sentence after resigning in disgrace amid accusations that he failed to pay taxes for years on his private law firm was sentenced to three years probation by a Minnesota federal court.

Expert Analysis

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

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    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.

  • 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.

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