Federal
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August 02, 2024
St. Louis Attys Can't Get Acquittal In $4M Tax Avoidance Case
Two Missouri-based attorneys, a father and daughter duo found guilty of participating in a $4 million tax avoidance scheme, will not be granted a new trial or an acquittal, despite their assertions that a number of errors tainted their trial, a North Carolina federal judge ruled Friday.
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August 02, 2024
Ex-Loeb Tax Atty Latest Addition To Kilpatrick's NY Team
A former Loeb & Loeb LLP attorney is bringing his experience in U.S. federal tax matters and real estate transactions to Kilpatrick Townsend & Stockton LLP, the firm announced Thursday.
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August 02, 2024
Sister-In-Law Ordered To Testify In Hunter Biden Tax Case
A California federal judge ordered Hunter Biden's sister-in-law, with whom he was romantically involved, and her sister to testify at his upcoming criminal trial in which he is accused of scheming to avoid paying $1.4 million in taxes.
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August 02, 2024
Calls To Taxpayer Advocates Go To Voicemail, TIGTA Says
The Treasury Inspector General for Tax Administration called all 76 local Taxpayer Advocate Service phone lines to test their availability and only had calls answered twice, it said Friday, calling on the service to improve its monitoring of the lines.
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August 02, 2024
Treasury Faces Complicated Path For Amount B Pricing Rules
The U.S. Treasury Department signaled it is considering how to enact the OECD's routine pricing plan known as Amount B, but U.S. tax attorneys expect a complicated compliance exercise if rulemakers establish the new transfer pricing approach.
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August 02, 2024
Coca-Cola Poised To Appeal $2.7B Tax Bill With 11th Circ.
The U.S. Tax Court signed off Friday on Coca-Cola's $2.7 billion tax bill, setting the stage for the beverage giant to appeal the liabilities and related rulings in its long-running dispute over the IRS' reallocation of the company's foreign income.
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August 02, 2024
IRS Tells Tax Court AbbVie's $1.6B Break Fee Is A Capital Loss
The Internal Revenue Service correctly reclassified AbbVie's $1.6 billion break fee to an Irish biotechnology company as a capital loss, the agency told the U.S. Tax Court, arguing that the failed merger is tantamount to disposing of property.
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August 02, 2024
Taxation With Representation: Sullivan, Dechert, Kirkland
In this week's Taxation With Representation, BNP Parabis SA acquires an investment management subsidiary for €5.1 billion, Cleveland accounting firm CBIZ merges with competitor Marcum for $2.3 billion, and Arcosa Inc. inks a deal with a family-owned construction materials business for $1.2 billion.
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August 02, 2024
Liberty Global's $110M Tax Refund Kosher, 10th Circ. Told
The IRS is trying to block Liberty Global's bid for a $110 million tax refund by improperly using a legal doctrine requiring transactions to have economic substance, the telecommunications giant told the Tenth Circuit, arguing it was allowed to make tax-driven choices in the transactions at issue.
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August 02, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, includes finalized regulations that govern the quarterly reporting of a new excise tax that pharmaceutical companies, suppliers and importers must pay when they do not negotiate with Medicare over drug prices.
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August 01, 2024
Feds Want Full Sentence Kept In Fla. Illegal Employment Case
The U.S. urged a Florida federal court on Thursday to uphold the three-year prison sentence of a labor staffing company operator convicted in a conspiracy to hire migrants not authorized to work in the U.S., saying he's ineligible for a reduction because of his admitted role in the scheme.
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August 01, 2024
Divided Tax Court Says Treaty Bars Collections Hearing
A divided U.S. Tax Court ruled Thursday that it lacked authority to review an Internal Revenue Service decision preventing a woman from challenging a federal tax lien the agency issued on behalf of the Canadian government to secure her tax debt to that country.
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August 01, 2024
TIGTA Says IRS Cybersecurity Program Still Not Fully Effective
The Internal Revenue Service's cybersecurity program continues to not meet federal standards, potentially leaving taxpayer data vulnerable to inappropriate and undetected use, modification or disclosure, the Treasury Inspector General for Tax Administration said Thursday.
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August 01, 2024
Coca-Cola, IRS Enter $2.7B Tax Bill In Transfer Pricing Dispute
Coca-Cola and the IRS submitted tax liability calculations totaling $2.73 billion to the U.S. Tax Court, reflecting the latest step in the company's long-running transfer pricing dispute over the agency's reallocation of the company's foreign affiliate income.
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August 01, 2024
Calif. Couple Ordered To Pay $1.5M Tax Bill
A California couple must pay more than $1.5 million for three years' worth of unpaid tax liabilities, plus interest and any other additions, a federal district court ruled Thursday.
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August 01, 2024
Direct File Will Be Available In New Mexico, IRS Announces
New Mexico will participate in the Internal Revenue Service's free electronic tax return filing program known as Direct File in the 2025 tax filing season, the agency and the U.S. Department of the Treasury announced Thursday.
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August 01, 2024
Airbnb's $1.3B Bill From IRS Overvalues IP, Tax Court Told
Airbnb is challenging a $1.3 billion tax bill tied to income the IRS allocated from overseas, telling the U.S. Tax Court the agency overvalued intellectual property the home-rental giant licensed to its Irish affiliate before going public.
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August 01, 2024
Senate GOP Blocks House-Passed Tax Break Bill
Republicans on Thursday blocked the Senate from considering a bipartisan tax bill negotiated by the chairmen of the House and Senate's tax-writing committees that would extend the full tax break for research and development costs and expand the child tax credit for multiple years.
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August 01, 2024
Court Won't Stop FTC Judges In H&R Block False Ad Fight
The Federal Trade Commission can proceed with its hearing against H&R Block accusing the tax preparation firm of false advertising, a Missouri federal judge ruled Thursday, rejecting the company's argument that the agency's administrative law judges lack constitutional authority to preside.
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August 01, 2024
Senate Panel OKs Maintaining IRS Funding At $12.3B
The Internal Revenue Service would receive $12.3 billion for the third straight year under legislation sent Thursday by the Senate Appropriations Committee to the full chamber for consideration.
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August 01, 2024
3rd Circ. Affirms Nix Of Discovery Ask On GM In Brazil Case
A Delaware federal court didn't abuse its discretion by declining to begin discovery on General Motors to aid ongoing litigation in Brazil for a group that is entitled to receive dozens of car dealerships' tax credits from the early 1990s, the Third Circuit found.
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August 01, 2024
IRS Not Required To Disclose Summonses, 5th Circ. Affirms
The Internal Revenue Service was not required to tell a Texas man with unpaid tax liabilities that it had demanded his financial information from third parties, the Fifth Circuit ruled, upholding a lower court's decision to toss his suit.
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August 01, 2024
Chiropractor Evaded $2.4M In Taxes, Fed. Indictment Says
An Alabama chiropractor evaded $2.4 million in self-reported taxes, filed false tax returns and obstructed the Internal Revenue Service, according to a federal indictment.
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July 31, 2024
Treasury's New 'Killer B' Rules May Revive Controversies
Recent U.S. Treasury Department regulations centered on contentious 2011 guidance aimed at so-called Killer B transactions have revived long-standing questions about how much authority rule writers have to target what they perceive as corporate tax avoidance in these maneuvers.
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July 31, 2024
Cos. Insist Chevron Ruling Doesn't Change Deduction Claims
A medical device company and a food services firm that are each challenging Internal Revenue Service denials of dividend deduction claims told the U.S. Tax Court that the recent U.S. Supreme Court decision overturning Chevron deference doesn't change the validity of their arguments.
Expert Analysis
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4 Ways To Motivate Junior Attorneys To Bring Their Best
As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.
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How IRA Unlocks Green Energy Investments For Tribes
An Inflation Reduction Act provision going into effect May 10 represents a critical juncture for Native American tribes, offering promising economic opportunity in green energy investment, but requiring a proactive and informed approach when taking advantage of newly available tax incentives, say attorneys at Lewis Brisbois.
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Former Minn. Chief Justice Instructs On Writing Better Briefs
Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.
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What To Know About IRS' New Jet Use Audit Campaign
The Internal Revenue Service recently announced plans to open several dozen audits scrutinizing executive use of company jets, so companies should be prepared to show the business reasons for travel, and how items like imputed income and deduction disallowance were calculated, say attorneys at Morgan Lewis.
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Stay Interviews Are Key To Retaining Legal Talent
Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.
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Judicial Independence Is Imperative This Election Year
As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.
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Spartan Arbitration Tactics Against Well-Funded Opponents
Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.
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What Recent Study Shows About AI's Promise For Legal Tasks
Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.
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How FinCEN Proposal Expands RE Transaction Obligations
Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.
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What To Know About Employee Retention Credit Disclosures
Employers that filed potentially erroneous employee retention credit claims should take certain steps to determine whether the IRS’ voluntary disclosure program is a good fit and, if so, prepare a strong application before the window closes on March 22, say attorneys at Dentons.
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Litigation Inspiration: A Source Of Untapped Fulfillment
As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.
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Unpacking FinCEN's Proposed Real Estate Transaction Rule
Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.
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Think Like A Lawyer: Forget Everything You Know About IRAC
The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.