Federal

  • 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.

  • September 20, 2024

    8th Circ. To Hear Args In 3M's $24M Tax Case Next Month

    The Eighth Circuit said Friday that it will hear oral arguments next month in 3M's transfer pricing appeal, in which the multinational conglomerate is challenging the Internal Revenue Service's authority to reallocate to the company $24 million from a Brazilian affiliate.

  • September 20, 2024

    IRS Updates Per-Diem Deduction Rates For Business Travel

    The per-diem rates used to compute business travel expense tax deductions will be $319 for travel to high-cost areas and $225 for travel to low-cost areas starting in October, the Internal Revenue Service said Friday.

  • September 20, 2024

    Divestiture Counts As Reorganization, IRS Says

    A domestic corporation with some foreign shareholders that is required to divest itself of one of its businesses by using a newly created corporation as an intermediary for the distribution qualifies as a tax-free reorganization, the IRS said in a private letter ruling released Friday.

  • September 20, 2024

    IRS Special Trial Attorney Joins Hochman Salkin In California

    When Hochman Salkin Toscher Perez PC's newest principal, Sebastian Voth, was studying at Emory University School of Law, a former chief counsel for the Internal Revenue Service told students that the IRS was a great place to start their careers. After 15 years as an IRS attorney, Voth found that the agency was also a great place to work, he told Law360 Pulse in an interview Friday.

  • September 20, 2024

    IRS Not Meeting Disclosure Requirements For Joint Returns

    The Internal Revenue Service did not uniformly follow joint return disclosure requirements on collection information requests, burdening taxpayers with additional delays resolving their tax matters and possibly violating their privacy rights, the Treasury Inspector General for Tax Administration said Friday.

  • September 20, 2024

    Tribe's Stateless Status Undoes $1.9M Construction Suit

    A Massachusetts federal judge on Thursday tossed a New York construction company's $1.9 million lawsuit against the Mashpee Wampanoag Tribe, finding the tribe's stateless position leaves the court with no jurisdiction to decide the case.

  • September 20, 2024

    Taxation With Representation: Gibson Dunn, Holland & Knight

    In this week's Taxation With Representation, CACI International buys Azure Summit Technology, Hotel Engine lands a valuation led by Permira, and Knowles Corp. sells its microphone business to Syntiant Corp.

  • September 20, 2024

    IRS Must Credit Overpayments, Couple Tell 5th Circ.

    A couple claiming they should be allowed to sue the IRS for a roughly $500,000 tax refund in federal court because they overpaid their taxes told the Fifth Circuit that the agency is out of time to challenge their overpayments and must credit their account.

  • September 20, 2024

    IRS Corrects Proposed Clean Electricity Bonus Credit Regs

    The Internal Revenue Service issued corrections Friday to proposed regulations that would broaden the types of power facilities that could be eligible for clean electricity low-income community bonus credit amounts starting in 2025.

  • September 20, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included proposed regulations that would adjust the timing for when companies could opt to use the so-called mark-to-market accounting method for gains or losses that arise from foreign currency transactions.

  • September 19, 2024

    Ch. 7 Trustee Urges Justices To Uphold Return Of Taxes

    The bankruptcy trustee of a defunct Utah transportation company warned the U.S. Supreme Court on Thursday that overturning a decision forcing the IRS to return tax payments made by company directors to cover their personal debts would encourage shareholder fraud.

  • September 19, 2024

    Convicted Drexel Professor Won't Get New Tax Evasion Trial

    A Drexel University accounting professor was denied a new trial after being convicted on tax evasion charges for failing to report $3.3 million in income from a Trenton pharmacy, a New Jersey federal judge has ruled, reasoning that the professor's case was not prejudiced by keeping accounting records related to his tax returns from the jury.

  • September 19, 2024

    House Bill Proposes Tax Incentives For Military Housing

    A bill introduced in the U.S. House of Representatives would seek to increase the availability and affordability of housing for service members in part by excluding the military's basic housing allowance from the income calculation for the low-income housing tax credit.

  • September 19, 2024

    Calif. Says FDIC's $20M Tax Refund Bid Must Wait

    A California tax collection agency asked a New York federal court to throw out Federal Deposit Insurance Corp. claims seeking a more than $20 million tax refund on behalf of the shuttered Signature Bank, saying the agency is entitled to wait for a potential IRS audit to end. 

  • September 19, 2024

    Death Doesn't Preclude FBAR Penalties, Judge Says

    The death of a U.S. citizen who failed to file reports of foreign bank and financial accounts doesn't stop the U.S. government from enforcing penalties against his estate, a New York federal judge ruled.

  • September 19, 2024

    Senate Tees Up Vote On Tax Court Nominee

    The U.S. Senate set the stage Thursday to proceed with a vote on one of President Joe Biden's picks to fill an open seat on the U.S. Tax Court.

  • September 19, 2024

    GAO Says IRS Can Be Better Prepped For Reporting Changes

    While the Internal Revenue Service could collect billions thanks to recent reporting requirement changes, particularly those related to cryptocurrency, the agency needs to take further steps to be prepared for the changes, the Government Accountability Office said Thursday.

  • September 19, 2024

    H&R Block Again Asks 8th Circ. To Remove ALJs In Ad Suit

    H&R Block asked the Eighth Circuit to reconsider its denial of the company's request to stop administrative law judges from presiding over its coming false-advertising hearing before the Federal Trade Commission, saying the court's one-sentence ruling lacked any explanation despite the significant constitutional issues involved.

  • September 19, 2024

    IRS Warns Taxpayers Of Offer-In-Compromise 'Mills'

    The IRS urged taxpayers to be careful about working with promoters that claim to provide necessary services in order to comply with the agency's offer-in-compromise program, saying Thursday that these "mills" only bring "empty promises and steep costs."

  • September 18, 2024

    Tax Chiefs Eye Crypto Payment Cos., OTC Traders, IRS Says

    Tax investigators in the U.S., U.K., Canada, Australia and the Netherlands are preparing guidance on red flags for cryptocurrency payment providers and over-the-counter trading desks following a joint operation this week, a special agent with the Internal Revenue Service said Wednesday.

  • September 18, 2024

    IRS Publishes Guidance For Issuers Of Tax-Exempt Bonds

    The Internal Revenue Service published guidance Wednesday for issuers of tax-exempt and other tax-advantaged bonds in terms of procedures for filing claims for recovery of overpayments of rebate payments and other processes.

  • September 18, 2024

    Dems Block Bill Targeting Foreign Funding Of Campaign Gifts

    Democrats blocked the House of Representatives from sending legislation to the Senate that would restrict contributions to political committees by tax-exempt entities that receive foreign funds.

  • September 18, 2024

    Tax Court Wrongly Denied Premium Deduction, 5th Circ. Told

    A Texas couple asked the Fifth Circuit on Wednesday to reverse a U.S. Tax Court decision denying their bid to deduct more than $1 million in premiums paid to insurance companies they owned, arguing the Tax Court misclassified underlying insurance arrangements.

Expert Analysis

  • How Associates Can Build A Professional Image

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    As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.

  • Navigating New Safe Harbor For Domestic Content Tax Credits

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    The U.S. Department of the Treasury’s recent notice simplifying domestic content calculations for certain solar, onshore wind and battery storage projects, which directly acknowledges the difficulty for taxpayers in gathering data to support a domestic content analysis, should make it easier to qualify additional domestic content bonus tax credits, say attorneys at A&O Shearman.

  • Firms Must Rethink How They Train New Lawyers In AI Age

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    As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.

  • 'Energy Communities' Update May Clarify Tax Credit Eligibility

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    A recent IRS notice that includes updated lists of locations where clean energy projects can qualify for additional tax credits — based 2023 unemployment data and placed-in-service dates — should help provide clarity regarding project eligibility that sponsors and developers need, say attorneys at Troutman Pepper.

  • Think Like A Lawyer: Always Be Closing

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    When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.

  • How Cannabis Rescheduling May Alter Paraphernalia Imports

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    The Biden administration's recent proposal to loosen federal restrictions on marijuana use raises questions about how U.S. Customs and Border Protection enforcement policies may shift when it comes to enforcing a separate federal ban on marijuana accessory imports, says R. Kevin Williams at Clark Hill.

  • NCAA Settlement May End The NIL Model As We Know It

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    The recent House v. NCAA settlement in California federal court, in which the NCAA agreed to allow schools to directly pay March Madness television revenue to their athletes, may send outside name, image and likeness collectives in-house, says Mike Ingersoll at Womble Bond.

  • Fishing Makes Me A Better Lawyer

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    Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.

  • A Healthier Legal Industry Starts With Emotional Intelligence

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    The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.

  • To Make Your Legal Writing Clear, Emulate A Master Chef

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    To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.

  • Circuit Judge Writes An Opinion, AI Helps: What Now?

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    Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.

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