Federal

  • September 24, 2024

    IRS Wary Of Adding Complexity In Min. Tax Regs, Official Says

    The IRS opted to use existing tax rules in proposed guidance to address risks that the U.S. corporate alternative minimum tax could count offshore income twice, an agency official said Tuesday, noting a more precise method would increase complexity.

  • September 24, 2024

    Treasury To Allow 3 AMT Transition Methods, Official Says

    Final rules on the new corporate alternative minimum tax are expected to adopt the proposed regulations' three ways for companies to transition to the regime, and the U.S. Treasury Department is open to other ways as well, a department official said Tuesday.

  • September 24, 2024

    Insurer Wants Quick Appeal At 8th Circ. In DOL Tax Fight

    A health insurer will seek the Eighth Circuit's review after a federal judge refused to toss a suit from the U.S. Department of Labor claiming the company unlawfully took at least $66.8 million in Minnesota state tax liability from plans it administered to pay in-network providers.

  • September 24, 2024

    Exxon Claims It Beat Weak Defense In $1.8B Tax Trial

    Exxon Mobil urged a Texas federal judge to find that it defeated what it called a scattered defense by the U.S. government during a five-day bench trial in April when the company argued for a $1.8 billion tax refund on its natural gas deal with Qatar, according to newly released filings.

  • September 24, 2024

    Applications For Low-Income Energy Tax Breaks Due In Oct.

    With more than 50,000 applications for the low-income communities clean energy bonus credit program submitted, three U.S. government agencies announced Tuesday that they will be accepting applications on a rolling basis for most categories through Oct. 10 to make sure they are timely processed.

  • September 24, 2024

    Tax Data Consent Practices Need Shoring Up, TIGTA Says

    The Internal Revenue Service must take steps to make sure any tax software companies that collect taxpayer information include consent statements that are clear about the intended purpose of the disclosure of that information and the specific recipients of it, the Treasury Inspector General for Tax Administration said.

  • September 24, 2024

    Miller & Chevalier Adds Federal Tax Expert From White & Case

    Miller & Chevalier Chtd. announced that it added a former partner at White & Case LLP to its tax controversy and litigation practice.

  • September 23, 2024

    Clean Energy Safe Harbor Applies To Direct Pay, Official Says

    The safe harbor for the bonus clean energy tax credits' domestic content rules applies to all applicable project owners, including tax-exempt entities that are eligible to get a direct cash payment of the credits, a U.S. Treasury Department attorney said Monday.

  • September 23, 2024

    Energy Bonus Credit Penalty Guidance Coming, Atty Says

    The U.S. Treasury Department will soon release additional guidance on penalties for clean energy developers that initially failed to meet the prevailing wage requirements tied to claiming bonus tax credits on their development projects, a Treasury attorney said Monday.

  • September 23, 2024

    Some Former IRS Contractors Not Purged From Systems

    An analysis of over 1,800 former Internal Revenue Service contractors who were incorrectly listed as active found a number of them still possessed network permissions, IRS hardware or identification cards giving them access to agency facilities, the Treasury Inspector General for Tax Administration said Monday.

  • September 23, 2024

    3 IRS Divisions Not Heeding Customer Surveys, TIGTA Says

    The Internal Revenue Service's Wage and Investment, Small Business/Self-Employed and Tax Exempt and Government Entities divisions are generally not using the results of their customer service surveys to make improvements to their operations, the Treasury Inspector General for Tax Administration said Monday.

  • September 23, 2024

    Couple Didn't Report Business Income, Tax Court Says

    A couple whose mortgage company managed two LLCs failed to report income received from the company, the U.S. Tax Court ruled Monday in upholding most of the roughly $1.3 million in deficiency notices for 2009 and 2010 issued by the Internal Revenue Service.

  • September 23, 2024

    The Tax Angle: Corporate Inversions, SALT Cap

    From a look at criticisms that the 2017 federal tax law failed to stop corporations from moving overseas to GOP efforts to navigate the SALT cap ahead of the November elections, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • September 23, 2024

    Sysco Allowed $324M Dividend Deduction After Varian Ruling

    Sysco Corp. can deduct $324 million in foreign dividends after agreeing with the Internal Revenue Service that a decision in a similar case brought by Varian Medical Systems resolved their dispute, the U.S. Tax Court said in an order.

  • September 23, 2024

    More Needed On Energy Tax Credit Monetization, TIGTA Says

    The Internal Revenue Service has taken steps to facilitate the sale or transfer of the Inflation Reduction Act's clean energy tax credits, but it must develop more processes to accommodate the credits, the Treasury Inspector General for Tax Administration reported.

  • September 23, 2024

    Senate Confirms 3rd Tax Court Judge In 2 Months

    The U.S. Senate approved one of President Joe Biden's nominees to serve on the U.S. Tax Court on Monday, marking the third time the chamber has confirmed a judge to the court in the past two months.

  • September 23, 2024

    Tax Court Allows Woman's Gambling Loss Deduction

    A California woman made good-faith attempts to substantiate her gambling losses and therefore may claim a roughly $62,000 tax deduction, but she is still liable for an accuracy-related penalty for the year in question, the U.S. Tax Court said Monday.

  • September 23, 2024

    DOJ Seeing Deluge Of Attacks In Tax Cases After Loper Bright

    The U.S. Department of Justice's Tax Division is seeing its casework flooded with taxpayer arguments citing the U.S. Supreme Court's decision in Loper Bright overturning the Chevron doctrine, and that's not likely to change soon, a division chief said Monday.

  • September 23, 2024

    Vanguard Agrees To Settle Investors' Tax Liability Suit

    Vanguard agreed to settle a proposed class action by investors who accused the company of violating its fiduciary duties when it triggered a sell-off of assets that left them with massive tax bills, according to a Pennsylvania federal court order Monday.

  • September 23, 2024

    Profs, Retired Judges Ask Justices To Uphold Return Of Taxes

    Two former bankruptcy judges and a group of law professors threw their support behind the bankruptcy trustee of a Utah transportation company seeking to convince the U.S. Supreme Court that the IRS, like any other creditor, should have to return payments deemed fraudulent under state law.

  • September 23, 2024

    IRS Finalizing Pricing Pact Guidance, Official Says

    The Internal Revenue Service is in the final stages of updating revenue procedures to help multinational corporations pursue advance pricing agreements and resolve tax treaty disputes, and it will release the guidance soon, an agency official said Monday.

  • September 23, 2024

    IRS Names Chief Of Appeals Office

    The Internal Revenue Service elevated the acting chief of its Independent Office of Appeals to the position permanently, the agency announced Monday.

  • September 23, 2024

    Squire Patton Tax Ace Joins Winston & Strawn In Dallas

    Winston & Strawn LLP announced Monday it has expanded its tax offerings with the addition of an experienced attorney from Squire Patton Boggs LLP in Texas.

  • September 23, 2024

    Julie Chrisley Fights For Sentence Cut After 11th Circ. Ruling

    Former reality TV star Julie Chrisley asked a Georgia federal judge on Friday to resentence her to no more than five years for her role in a $36 million tax evasion and fraud scheme, arguing against prosecutors' insistence that the seven-year sentence she was previously given be kept intact.

  • September 20, 2024

    Family Owes $81M Taxes On 'Son-Of-Boss' Scheme, DOJ Says

    Former shareholders of a family-owned holding company owe the IRS nearly $81 million for participating in what is known as a Son-of-Boss arrangement, which generated fake capital losses in the 2022 sale of company stock, the U.S. Department of Justice told a New York federal court.

Expert Analysis

  • Lessons From Country Singer's Personal Service Saga

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    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.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    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.

  • 5 Litigation Funding Trends To Note In 2024

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    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.

  • Tech CEO Tax Ruling A Warning For Forward Contracts

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    In McKelvey v. Commissioner, the U.S. Tax Court decided that deceased Monster.com founder Andrew McKelvey terminated his underlying obligations when he extended variable prepaid forward contracts, demonstrating why startup founders, early employees and investors should think carefully before amending derivative agreements, say Daren Shaver and Trent Tanzi at Hanson Bridgett.

  • 4 Legal Ethics Considerations For The New Year

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    As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.

  • What The Law Firm Of The Future Will Look Like

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    As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • 4 PR Pointers When Your Case Is In The News

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    Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Charting The Course For Digital Assets In 2024

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    Although 2023 was a tough year for the digital asset industry, upcoming court decisions, legislation and regulatory action will bring clarity, allowing the industry to expand and evolve, and the government will decide what innovation it will allow without challenge, says Joshua Smeltzer at Gray Reed.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

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