Federal
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August 15, 2024
Doctor Wants Contempt Fine Dropped In Foreign Asset Case
A doctor who incurred $1.1 million in liabilities for failing to report his foreign bank accounts is asking a Michigan federal court to waive his $20,000 civil contempt fine because the court restricted his only financial assets to paying the liabilities.
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August 15, 2024
Applicable Federal Interest Rates To Drop In September
Applicable federal rates for income tax purposes will decrease in September, the Internal Revenue Service said Thursday, the third month-to-month drop in a row.
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August 15, 2024
IRS Nix Of $52M Easement Deduction Invalid, Donor Says
An Alabama partnership asked the U.S. Tax Court to reverse an Internal Revenue Service adjustment that cut its roughly $52 million deduction for its donation of a conservation easement, saying, among other things, that the IRS defied the Administrative Procedure Act.
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August 15, 2024
Partnership's $47M Easement Deduction Is Fraud, IRS Says
A North Carolina partnership lied and hid details related to a fraudulent conservation easement donation for 2018, the Internal Revenue Service told the U.S. Tax Court, saying the partnership is wrong in claiming the IRS improperly slashed its almost $47 million corresponding tax deduction.
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August 15, 2024
Tax Pros Navigate Chaos, Rewards In Climate Law's 2nd Year
Energy tax attorneys have been knee-deep in project finance deals for the past year since the Inflation Reduction Act of 2022 triggered a flurry of clean energy investments, but the work, they say, has been fulfilling as part of broader efforts to save the environment.
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August 15, 2024
IRS Reopens Improper Retention Credit Disclosure Program
Businesses that think they improperly received COVID-era employee retention credits have another chance to apply for a voluntary disclosure program that could reduce their penalty and allow them to avoid future audits, penalties and interest, the Internal Revenue Service said Thursday.
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August 15, 2024
Ga. Man Accused Of Trying To Steal $1.9M In COVID Funds
A Georgia man was indicted in a scheme to steal $1.9 million in pandemic relief money and accused of wire fraud, submitting fraudulent federal tax returns and stealing dozens of Social Security numbers, the U.S. Department of Justice announced Wednesday.
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August 15, 2024
IRS Corrects Regs For Digital Asset Brokers, Energy Credits
The Internal Revenue Service issued corrections to three sets of final regulations Thursday, including those related to digital asset brokers and two clean energy tax credit provisions.
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August 14, 2024
Disbarred Atty Admits To Tax Evasion Over Mass Tort Fees
A disbarred attorney pled guilty to a single count of tax evasion Wednesday in Pennsylvania federal court stemming from allegations he didn't pay taxes on more than $100 million in legal fees he earned from representing 4,300 plaintiffs in a mass tort case, according to the U.S. Attorney's Office for the Middle District of Pennsylvania.
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August 14, 2024
Tax Court Judge Again Deems CPA's Refund Claim Frivolous
A U.S. Tax Court judge rejected a certified public accountant's calculation that the IRS owed him a nearly $30,000 tax refund, repeating her opinion that the CPA was making frivolous arguments in claiming he owed no taxes on his income.
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August 14, 2024
Medical Device Maker Pleads Guilty To $2.4M Tax Evasion
A man who made millions of dollars on medical devices and sold one purporting to eradicate viruses by using sound waves pled guilty to evading $2.4 million in taxes in a trust scheme involving his girlfriend, according to Florida federal court documents.
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August 14, 2024
DC Tax Relief Can Aid Office Projects, But It's No 'Silver Bullet'
While tax relief programs may help a handful of office conversion projects in Washington, D.C., and make financial sense, much more needs to happen to bring the city's struggling downtown back to life again, real estate experts say.
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August 13, 2024
Hunter Biden Says Corruption Claims Don't Belong In Tax Trial
Hunter Biden has urged a California federal judge to bar a jury weighing his tax charges from hearing any allegations of corruption regarding foreign sources of income for fear it would "insinuate extraneous, politically charged matters" into the trial.
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August 13, 2024
Gov't Seeks To Use Liens To Nab Decades-Old $2.8M Tax Debt
A businessman and his trust face the prospect of losing a New York property as the Internal Revenue Service asked a federal court to set aside conveyances to him of property with IRS tax liens and collect on a $2.8 million tax debt.
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August 13, 2024
Walz Backed Tax Hikes Funding Plans For Children, Families
As Minnesota's governor, Democrat Tim Walz, now the presumed vice presidential nominee of his party, separated himself from most other governors by signing into law numerous tax increases funding progressive priorities such as a paid family leave plan and the nation's largest child tax credit.
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August 13, 2024
Treasury's Loss Rules Take Broad Approach To Min. Tax Deal
The U.S. Treasury Department recently dashed the hopes of multinational corporations seeking regulations that would have carved out an international minimum tax agreement from interacting with long-standing domestic rules aimed at preventing companies from using the same economic loss twice.
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August 13, 2024
Partnerships' Easement Fight Ends As Gov't Drops IRS Notice
An Alabama federal judge dismissed a complaint by dozens of partnerships claiming they shouldn't have to comply with an IRS notice regarding conservation easement transactions, following an Eleventh Circuit ruling upholding the notice as invalid and the government's agreement not to enforce it.
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August 13, 2024
IRS Delays Tax Deadlines In Vermont After Hurricane Debby
Taxpayers in Vermont will be given until Feb. 3 to file individual and business tax returns and make payments after the state was hit by Hurricane Debby, the Internal Revenue Service said Tuesday.
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August 13, 2024
Tax Court Nixes Loss Deduction, But Owners Owe No Penalty
The Internal Revenue Service was right to determine a business created to provide guidance to real estate owners and investors couldn't claim loss deductions because its business had not actually started, the Tax Court said Tuesday, but the owners are not liable for an accuracy-related penalty.
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August 13, 2024
IRS Wrongly Denied Tomato Cos. Deductions, 9th Circ. Told
Two companies that supply 40% of the United States' tomato paste and diced tomatoes told the Ninth Circuit that the U.S. Tax Court erred in keeping the companies from deducting the costs of restoring their production facilities before the actual restoration occurs.
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August 13, 2024
Firm Asks Court To Reconsider $1.5M Freeze In Tax Dispute
A Baltimore law firm that sued the IRS for freezing $1.5 million in its operating account to satisfy a client's tax debts told a Maryland federal court it was "dead wrong" in denying the firm's request to release the money without going to trial.
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August 13, 2024
Tax Court Design Violates US Law, Widow Tells 11th Circ.
The widow of a grocery store butcher fighting a tax liability upheld by the U.S. Tax Court has told the Eleventh Circuit that the decision should be sent back for reconsideration, arguing that a provision restricting the president's power to remove Tax Court judges is unconstitutional.
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August 13, 2024
IRS Announces Sept. Meeting On Advisory Council Report
The Internal Revenue Service's Advisory Council will hold a public meeting on Sept. 5 to discuss a future report from the council, the agency announced Tuesday.
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August 12, 2024
Accused Accounting Prof Is No Tax Expert, NJ Jury Told
New Jersey federal jurors were urged Monday to keep one word at the front of their minds as they listen to the government present its case against an accounting professor accused of failing to report $3.3 million in income from a pharmacy he co-owned with his wife: willful.
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August 12, 2024
Tax Court Tosses Deficiency Challenge Over Validity
The U.S. Tax Court cannot rule on a man's challenge to an Internal Revenue Service deficiency notice because the agency failed to show it correctly mailed the notice, rendering it invalid, and the case must be dismissed, the court said Monday.
Expert Analysis
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Takeaways From Justices' Redemption Insurance Decision
The U.S. Supreme Court’s recent decision in Connelly v. U.S. examines how to determine the fair market value of shares in a closely held company for estate tax purposes, and clarifies how life insurance held by the company to enable redemption of a decedent’s shares affects that calculation, says Evelyn Haralampu at Burns & Levinson.
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6 Tips For Maximizing After-Tax Returns In Private M&A Deals
With potential tax legislation likely to spur a surge in private business sales, sellers can make the most of after-tax proceeds with strategies that include price allocation and qualified investment options, say Isaac Grossman and Daniel Studin at Morrison Cohen.
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After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1
The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.
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Recruitment Trends In Emerging Law Firm Frontiers
BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.
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What DOL Fiduciary Rule Means For Private Fund Managers
Attorneys at Ropes & Gray discuss how the U.S. Department of Labor's recently released final fiduciary rule, which revises the agency's 1975 regulation, could potentially cause private fund managers' current marketing practices and communications to be considered fiduciary advice, and therefore subject them to strict prohibitions.
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Money, Money, Money: Limiting White Collar Wealth Evidence
As courts increasingly recognize that allowing unfettered evidence of wealth could prejudice a jury against a defendant, white collar defense counsel should consider several avenues for excluding visual evidence of a lavish lifestyle at trial, says Jonathan Porter at Husch Blackwell.
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How Associates Can Build A Professional Image
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.
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Navigating New Safe Harbor For Domestic Content Tax Credits
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.
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Firms Must Rethink How They Train New Lawyers In AI Age
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.
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'Energy Communities' Update May Clarify Tax Credit Eligibility
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.
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Think Like A Lawyer: Always Be Closing
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.
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
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.
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Lean Into The 'Great Restoration' To Retain Legal Talent
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.