Federal

  • February 21, 2024

    IRS Seeks Comment On Taxable Substances List Additions

    The Internal Revenue Service asked for feedback Wednesday on the potential addition of two substances to the Internal Revenue Code's list of taxable substances.

  • February 20, 2024

    Media Broker Gets 15 Months For Hiding $19.5M From IRS

    A media broker was sentenced to 15 months in prison Tuesday after admitting she concealed $19.5 million in income from the Internal Revenue Service.

  • February 20, 2024

    Ex-BigLaw Atty Avoids Prison For Ch. 11 Lies

    A former BigLaw partner on Tuesday was spared any prison time for lying to a New York bankruptcy court in his 2022 personal Chapter 11 case, in an attempt to shield his assets from creditors.

  • February 20, 2024

    Philly Woman Asks Justices To Review City's Tax Credit Policy

    Philadelphia's refusal to credit a woman's Delaware state income taxes paid against her city wage tax liabilities unconstitutionally discriminates against interstate commerce, the woman argued Tuesday in asking the U.S. Supreme Court to review a Pennsylvania Supreme Court ruling in the city's favor.

  • February 20, 2024

    Son's $63M Tax Deal Puts Diamond King's Widow In The Clear

    The federal government agreed to stop pursuing the widow of a diamond mogul to recover millions in tax liabilities connected to her husband and his estate after their adult son agreed to pay $63 million, according to a New York federal court order Tuesday.

  • February 20, 2024

    Tax Court Rejects NY Couple's Expense Deductions

    A New York couple is not able to deduct an assortment of expenses after failing to substantiate them, the U.S. Tax Court ruled Tuesday.

  • February 20, 2024

    Tax Court Nixes NYC Site's Eligible-Basis Adjustments By IRS

    Tax-exempt bond issuance costs will not be excluded from a New York City building's eligible basis for the low-income housing credit, the U.S. Tax Court ruled Tuesday.

  • February 20, 2024

    Tax Court's Chief Judge Reelected To 2nd Term

    The U.S. Tax Court's chief judge was reelected to a second two-year term as the head of the court, the Tax Court announced.

  • February 20, 2024

    Third-Party Payers Liable For Employment Tax Shortcomings

    Certain third-party payers that improperly claim employment tax credits for a client are liable for any potential underpayments, the Internal Revenue Service said in a chief counsel memorandum.

  • February 20, 2024

    IRS Issues Fix For Tax Treatment Of Gas Upgrading Equipment

    The Internal Revenue Service issued a correction clarifying the tax treatment of certain gas upgrading equipment under proposed rules related to the energy credit.

  • February 20, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly bulletin, which featured a list of those having their 501(c)(3) status revoked.

  • February 20, 2024

    Justices Won't Review Partnership's $26M Easement Row

    The U.S. Supreme Court declined Tuesday to hear a partnership's bid to keep a $26.5 million deduction for a land conservation easement, letting stand a decision that the case was barred by a law that prohibits suits that restrain the collection of taxes.

  • February 16, 2024

    Ga. Man Hit With Charges Over Unemployment, Tax Fraud

    Georgia federal prosecutors unsealed an indictment on Thursday against an Atlanta man charged with using stolen personal information to secure tens of thousands of dollars in unemployment benefits and tax returns.

  • February 16, 2024

    Manufacturers Back 3M In 8th Circ. Transfer Pricing Case

    The National Association of Manufacturers joined the chorus of business groups supporting 3M, asking the Eighth Circuit to throw out transfer pricing regulations that allow the Internal Revenue Service to reallocate income to U.S. group members even when foreign laws prohibit outbound payments.

  • February 16, 2024

    Medtronic Urges 8th Circ. To Undo Transfer Pricing Ruling

    Medical device company Medtronic asked the Eighth Circuit on Friday to overturn a decision rejecting its pricing method for licensing intellectual property to its Puerto Rican affiliate, saying in the long-running case that Medtronic hadn't used the intercompany arrangement to underreport its income.

  • February 16, 2024

    Low Revenue May Drive US To Rethink Anti-Erosion Tax

    The base erosion and anti-abuse tax has been relatively easy to avoid without significant legal risk, tax professionals told Law360, a result that may prompt lawmakers to consider revising or replacing the provision as other major parts of the Tax Cuts and Jobs Act expire at the end of 2025.

  • February 16, 2024

    Conspirators In $3M IRS Refund Check Theft Get Prison Terms

    Two men will serve lengthy prison terms for their role in conspiring to steal and cash a Houston couple's tax refund check worth nearly $3 million, according to sentencing orders filed in Texas federal court.

  • February 16, 2024

    Trump Owes $355M For Fraud That 'Shocks The Conscience'

    A New York state judge on Friday found Donald Trump, his adult sons, his companies and longtime executives liable for a decadelong valuation fraud conspiracy, ordering the defendants to disgorge $364 million in ill-gotten gains to the state, plus interest, with the former president on the hook for the lion's share.

  • February 16, 2024

    Taxation With Representation: Paul Weiss, Kirkland

    In this week's Taxation With Representation, Diamondback buys Endeavor, KKR & Co. acquires a stake in Cotiviti, and Gilead Sciences Inc. purchases CymaBay Therapeutics Inc.

  • February 15, 2024

    Chamber, Others Back 3M In Transfer Pricing Appeal

    The Eighth Circuit should set aside transfer pricing regulations from the U.S. Treasury Department that reallocated $23 million of income from 3M's Brazilian affiliate to the parent company, three trade associations told the court in amicus briefs.

  • February 15, 2024

    Werfel Defends Delay Of $600 Payment Reporting Rule

    Internal Revenue Commissioner Daniel Werfel defended Thursday his decision to delay implementation of a law requiring peer-to-peer payment platforms such as Venmo and PayPal to report aggregate payments of $600 or more, saying the decision was informed by stakeholders.

  • February 15, 2024

    US Extends Deal On Existing Digital Taxes With 5 Countries

    Austria, France, Italy, Spain and the U.K. will continue applying their digital services taxes in light of the extended timeline to implement the Pillar One international profit reallocation agreement, the countries said Thursday in a joint statement with the U.S.

  • February 15, 2024

    Tax On Tribune's Cubs Sale Troubling, 7th Circ. Judge Says

    A Seventh Circuit judge said Thursday he was troubled by an IRS push to tax Tribune Media Co. on some gains from its sale of the Chicago Cubs that stemmed from a $425 million debt transaction, saying the agency seemed to ignore the relevant legal test.

  • February 15, 2024

    Ga. Jury Convicts PPP Fraudsters In $11M Case

    A Georgia federal jury found a man and woman guilty on Thursday of involvement in a sprawling Paycheck Protection Program loan fraud scheme that defrauded the government of more than $11 million.

  • February 15, 2024

    CPAs Call For Limiting Currency Recomputation Rules

    The IRS should exclude smaller taxpayers from requirements in proposed regulations for companies to recompute foreign currency gains or losses and income or losses into their parent entities' currencies annually, the American Institute of Certified Public Accountants said in a letter.

Expert Analysis

  • Breaking Down High Court's New Code Of Conduct

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    The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.

  • IRA Monetization Energizes Clean Power Tax Credit Market

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    Recent large sales of clean energy production tax credits reflect an environment in which the Inflation Reduction Act's provisions for monetizing such credits via direct transfer — bypassing slow, costly tax equity transactions — offer opportunities for both developers and investors, says Andrew Eastman at Husch Blackwell.

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • Unpacking Long-Awaited Clean Energy Tax Credit Guidance

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    Recently proposed Internal Revenue Service regulations provide welcome confirmatory guidance on the application of investment tax credits as reworked by 2022's Inflation Reduction Act, prevailing wage and apprenticeship rules that are largely consistent with market expectations, and broader eligibility criteria that should please the wind power industry in particular, say attorneys at Morgan Lewis.

  • Understanding Discovery Obligations In Era Of Generative AI

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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • An Informed Guide To Mastering Retirement Plan Forfeitures

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    When considering how to allocate departing retirement plan participants’ forfeitures, sponsors should consider recently filed lawsuits that allege Employee Retirement Income Security Act violations for using such funds to offset employer contributions, as well as proposed IRS guidance concerning how and when they must be used, says Eric Gregory at Dickinson Wright.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • IRS Proposal May Help Clarify Donor-Advised Fund Excise Tax

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    Recently proposed regulations provide important clarifications of the Internal Revenue Code's excise tax on donor-advised fund distributions by providing detailed definitions of key terms and addressing some of the open issues related to their operation and administration, say attorneys at Morgan Lewis.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Liability Exposure For Unpaid Payroll Taxes May Surprise You

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    The Ninth Circuit’s recent decision in Richard W. York v. U.S. offers important lessons for business owners and others who may be responsible for a company's checkbook about how someone else's failure to submit payroll taxes can result in their personal liability, says Douglas Charnas at McGlinchey Stafford.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

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