Federal

  • March 22, 2024

    LA Atty Who Repped Rodney King Charged With Tax Evasion

    A Los Angeles attorney who represented Rodney King in a civil case against the city of Los Angeles after King was severely beaten by police has been hit with federal tax evasion charges.

  • March 22, 2024

    3rd Circ. Says Tax Court Has Power To Tackle Debt Offset Case

    A woman whose tax refunds were withheld by the Internal Revenue Service for five years to satisfy what the agency said was her underlying tax liability will get another chance to convince the U.S. Tax Court that the government was wrong, the Third Circuit ruled Friday.

  • March 22, 2024

    IRS Pauses Worker Retention Credit Disclosure Program

    The Internal Revenue Service is suspending its voluntary disclosure program for improperly claimed employee retention credits, the agency announced Friday.

  • March 22, 2024

    Married Doctors Owe Feds $2.9M In Taxes

    A Connecticut physician couple must pay $2.9 million in back taxes, interest and penalties plus statutory additions after a federal court ruled they failed to produce enough evidence to challenge the accuracy of the U.S. government's tax assessments against them.

  • March 22, 2024

    Ariz. Says Federal Tax On Rebates Contradicts IRS Guidance

    A decision by the Internal Revenue Service to impose federal income tax on rebates issued last year by Arizona violates the agency's own recent guidance, the state told a federal court, saying a preliminary injunction against the tax would not unduly burden the agency.

  • March 22, 2024

    Holland & Knight Hires Caplin & Drysdale Member In DC

    Holland & Knight LLP has boosted its Washington-based tax team, hiring a Caplin & Drysdale Chtd. member who first joined his former firm 25 years ago from the U.S. Department of the Treasury.

  • March 22, 2024

    US Unlikely To Move On Hungary Tax Treaty, Official Says

    Hungary's low corporate tax rate and other policies will likely prevent the U.S. government from resuming negotiations on a stalled 2010 tax treaty after terminating its existing Hungarian treaty in early 2023, an IRS official said Friday.

  • March 22, 2024

    IRS Steadily Returning To Pre-Covid Levels, TIGTA Says

    Internal Revenue Service initiatives have reduced some — but not all — document processing back to pre-pandemic levels, the Treasury Inspector General for Tax Administration said in a report.

  • March 22, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, which included rules for businesses substituting certain tax forms.

  • March 21, 2024

    Treasury Hoping Pillar 2 Guidance Favors R&D Tax Credits

    The U.S. Treasury Department is looking for future administrative guidance on the international minimum tax agreement known as Pillar Two to give favorable treatment to U.S. research and development tax credits, but it will likely come with guardrails, a Treasury official said Thursday.

  • March 21, 2024

    Tax Court OKs Collection After Man Fails To Provide Records

    A Georgia man cannot challenge a tax collection action after failing to provide financial records proving he cannot pay a liability, the U.S. Tax Court ruled Thursday.

  • March 21, 2024

    GOP Sens. Push Yellen To Commit To TCJA Extension

    Senate Finance Committee Republicans on Thursday pushed Treasury Secretary Janet Yellen to commit to extending provisions in the Tax Cuts and Jobs Act, including the law's child tax credit expansion and the corporate and individual tax cuts.

  • March 21, 2024

    Man Faces Penalty After Debating Job Status, Tax Court Says

    A Georgia man is responsible for a frivolous filing tax penalty after questioning his employment status, the U.S. Tax Court affirmed Thursday.

  • March 21, 2024

    UN Could Enhance Global Tax Agenda Setting, Officials Say

    The United Nations could play an important role in shaping the agenda for global tax negotiations so it better reflects the priorities and concerns of developing countries, a variety of tax officials said Thursday during a conference.

  • March 21, 2024

    7th Circ. Won't Let Admitted Fraudster Ditch $1.3M Restitution

    A woman who admitted to wire fraud in connection with a three-person scheme to file hundreds of false tax returns owes $1.3 million in restitution to the government, the Seventh Circuit ruled Thursday, rejecting the woman's claim that the amount was miscalculated.

  • March 21, 2024

    IRS Proposes Exceptions For 3rd-Party Summons Notices

    The IRS proposed rules Thursday that would allow some exceptions to a requirement that the agency notify taxpayers within 45 days before issuing summonses to third parties in tax assessment and collection cases, including for certain time-sensitive examinations.

  • March 21, 2024

    Wyden Probes Swiss Bank's Ties To Billionaire Under Scrutiny

    The Senate Finance Committee's Democratic majority launched an inquiry into Swiss bank Pictet Group's involvement with a U.S. billionaire under criminal investigation, raising questions about the bank's deferred prosecution agreement and $123 million fine by the U.S. Justice Department, committee Chairman Ron Wyden announced Thursday.

  • March 21, 2024

    Quintairos Prieto Taps Atlanta Atty To Lead New Tax Group

    Quintairos Prieto Wood & Boyer PA said it had created a tax division that will be led by an Atlanta-based partner who has guided clients on civil and criminal tax law, reinforcing its national expertise in litigation, regulatory and corporate law matters.

  • March 21, 2024

    H&R Block Challenges FTC Judges In False Ad Battle

    H&R Block asked a Missouri federal court to stop administrative law judges from overseeing a Federal Trade Commission proceeding that accuses the tax preparation company of deceptive advertising, claiming the judges have job protections that unconstitutionally shield them from presidential oversight.

  • March 21, 2024

    Senate Bill Seeks To End Tax-Free Merger Treatment

    A bill introduced Thursday in the U.S. Senate would end manipulation of the Internal Revenue Code that allows certain corporate mergers to be tax-free.

  • March 21, 2024

    IRS Tweaks Proposed Partnership Treatment Rules

    The Internal Revenue Service issued a correction notice Thursday fixing a reference in proposed regulations about the treatment of related people within partnerships.

  • March 21, 2024

    IRS Issues Fixes In Safe Harbor Regulations

    The Internal Revenue Service issued two correction notices Thursday to amend final regulations focused on certain safe harbor exceptions.

  • March 20, 2024

    Endo Plan To Trim $5B In Debt Confirmed By NY Judge

    Drugmaker Endo International got a New York bankruptcy judge's approval for its Chapter 11 plan that aims to cut more than $5 billion in debt and hand over ownership to its lenders, roughly a month after it finalized a $465 million deal to resolve criminal and civil opioid claims.

  • March 20, 2024

    Wyden Bill Would Target Abuse Of Annuity Trusts

    A bill introduced Wednesday by the Senate Finance Committee chairman, Sen. Ron Wyden, D-Ore., would attempt to limit the abuse of a type of annuity trusts by the wealthy, in part by imposing a requirement that the instruments have a minimum term of at least 15 years.

  • March 20, 2024

    IRS Releases Foreign Housing Expense Limits For 2024

    The Internal Revenue Service released adjustments to the limitation on foreign housing expense deductions and exclusions for 2024 on Wednesday.

Expert Analysis

  • 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.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

  • Kentucky Tax Talk: Taking Up The Dormant Commerce Clause

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    Attorneys at Frost Brown examine whether the U.S. Supreme Court is likely to review Foresight Coal Sales v. Kent Chandler to consider whether a Kentucky utility rate law discriminates against interstate commerce, and how the decision may affect dormant commerce clause jurisprudence.

  • Prevailing Wage Rules Complicate Inflation Act Tax Incentives

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    Nicole Elliott and Timothy Taylor at Holland & Knight discuss the intersection between tax and labor newly created by the Inflation Reduction Act, and focus on aspects of recent U.S. Department of Labor and U.S. Department of the Treasury rules that may catch tax-incentive seekers off guard.

  • Payroll Tax Evasion Notice Suggests FinCEN's New Focus

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    The Financial Crimes Enforcement Network’s recent notice advising U.S. financial institutions to report payroll tax evasion and workers' compensation schemes in the construction industry suggests a growing interest in tax enforcement and IRS collaboration, as well as increased scrutiny in the construction sector, say Andrew Weiner and Jay Nanavati at Kostelanetz.

  • How Taxpayers Can Prep As Justices Weigh Repatriation Tax

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    The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.

  • IRS Foreign Tax Credit Pause Is Welcome Course Correction

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    A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.

  • If Justices End Chevron Deference, Auer Could Be Next Target

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    If the U.S. Supreme Court decides next term to overrule its Chevron v. NRDC decision, it may open the door for a similar review of the Auer deference — the principle that a government agency can interpret, through application, ambiguous agency regulations, says Sohan Dasgupta at Taft Stettinius.

  • Tax Court Ruling Provides Helpful Profits Interest Guidance

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    A recent U.S. Tax Court decision holding that a partnership may exclude interests in a company that it indirectly received sheds light on related IRS guidance, including the proper valuation method for such interests, though the court's application of the method to the facts of this case appears flawed, say attorneys at Kramer Levin.

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