Federal

  • September 05, 2024

    Liberty Global Urges 10th Circ. To Grant $248M Tax Credit

    The U.S. Tax Court improperly applied an Internal Revenue Code provision to some of the $2.8 billion gain from Liberty Global's sale of a Japanese entity, the telecommunications company said in urging the Tenth Circuit to overturn the resulting rejection of a $248 million tax credit.

  • September 05, 2024

    Holland & Knight Appoints Former Perkins Coie Tax Partner

    Holland & Knight LLP appointed a partner to its Portland, Oregon, office who previously served as a partner in energy tax law for Perkins Coie LLP, the firm announced.

  • September 05, 2024

    $70M Bill Came Too Late, Tax Court Says In Tossing IRS Claim

    Partners in a subscription business don't owe around $70 million in taxes as the IRS claimed because the agency notified them too late and couldn't extend the deadline by proving the partners had filed fraudulent returns, the U.S. Tax Court said in rulings Thursday.

  • September 05, 2024

    Sen. Finance Panel To Hold Hearing On Tax Policy, Avoidance

    The Senate Finance Committee will hold a hearing Sept. 12 covering the 2025 tax policy debate and tax avoidance strategies, it announced Thursday.

  • September 05, 2024

    CPAs Seek Guidance On Business Interest Expense Deduction

    The American Institute of Certified Public Accountants requested Thursday that the Internal Revenue Service and U.S. Treasury Department issue guidance clarifying that new limits on business interest expenses included in the 2017 federal tax overhaul apply after an election to capitalize interest expenses.

  • September 05, 2024

    Two Sentenced To Prison In $111M Tax Fraud Scheme

    Two members of a crime ring who admitted to participating in a $111 million tax fraud scheme involving stealing the identities of accountants and taxpayers were sentenced to prison, according to Texas federal court documents.

  • September 05, 2024

    IRS Seeks Input On Treasury Retirement Match Contributions

    The Internal Revenue Service said Thursday it is looking for comments regarding two portions of the Secure 2.0 Act of 2022 related to matching contributions paid by the U.S. Treasury Department to certain retirement savings vehicles for eligible people who make qualified contributions.

  • September 05, 2024

    Hunter Biden Pleads Guilty To Tax Charges In Surprise Move

    Hunter Biden entered a surprise guilty plea to nine criminal tax charges in California federal court on Thursday, bringing a dramatic conclusion to the case following a dizzying series of events on what was set to be the first day of his trial.

  • September 04, 2024

    Judge Chides IRS, Preparers Over $167M Refund For ID Fees

    A D.C. federal judge has declined to approve the IRS' roughly $167 million refund proposal for a putative class of tax-return preparers for charging them excessive fees for special identification numbers, saying the agency failed to address problems the preparers raised with its calculations.

  • September 04, 2024

    IRS' Economic Substance Authority Has Limits, Tax Court Told

    The U.S. Tax Court and other federal courts have the authority to conduct an initial analysis of a transaction in cases where the Internal Revenue Service is challenging the economic substance of the transaction, a manufacturers advocacy group said Wednesday in an amicus brief.

  • September 04, 2024

    Harris Floats Capital Gains Tax Hike To 28% For High Earners

    The tax on long-term capital gains would increase to 28% from 20% for taxpayers who earn $1 million or more under a proposal unveiled Wednesday by Vice President and Democratic presidential nominee Kamala Harris ahead of a campaign rally in New Hampshire.

  • September 04, 2024

    Woman Owes Taxes On Share Of Sold Biz, Tax Court Says

    A woman whose ex-husband told a bankruptcy court that he was the sole owner of a business they had started together was actually a 50% shareholder when it was sold and is liable for capital gains, the U.S. Tax Court ruled Wednesday.

  • September 04, 2024

    Tax Court OKs $465K Gambling Losses Deduction Amount

    An Indiana woman adequately proved she had more than $465,000 in substantiated gambling losses over six years, the U.S. Tax Court said Wednesday, though she failed to substantiate her claimed business losses.

  • September 04, 2024

    Warren Urges IRS To Look At Possible REIT Tax Break Abuse

    The Internal Revenue Service should increase its scrutiny of real estate investment trusts to determine whether companies are benefiting from REIT tax benefits while flouting rules, including those that limit the level of a REIT's ownership in a company, Sen. Elizabeth Warren told the agency's commissioner.

  • September 04, 2024

    Maryland Joining IRS Direct File Next Year

    Maryland will join the IRS' free electronic tax filing program known as Direct File in 2025, the U.S. Department of the Treasury and the Internal Revenue Service announced Wednesday.

  • September 04, 2024

    Ex-Mass. Pol 'A Little Sloppy' But Not Criminal, Jurors Told

    Former Massachusetts state Sen. Dean A. Tran denied charges Wednesday that he stole pandemic unemployment assistance and cheated on his taxes, with his attorney telling a jury that Tran simply made a series of paperwork "mistakes."

  • September 04, 2024

    Chippewa Lawyer Asks 8th Circ. To Reconsider Tax Exemption

    An attorney who contends that Congress never expressly allowed the federal government to tax Native Americans asked the Eighth Circuit to reconsider denying him a tax exemption on his self-employment income, saying the ruling conflicts with recent U.S. Supreme Court decisions.

  • September 04, 2024

    IRS Reopens Comment Period For Tax Payment Regs

    The Internal Revenue Service announced Wednesday that it had reopened the comment period for proposed regulations that would allow taxpayers to make payments using credit and debit cards directly with the agency instead of through a third party.

  • September 04, 2024

    IRS Announces 4 Tax Court Sessions Added To Calendar

    The Internal Revenue Service announced four U.S. Tax Court sessions in December and named calendar administrators for the sessions in a notice released Wednesday.

  • September 03, 2024

    11th Circ. Trims $12.6M FBAR Fine In 8th Amendment Split

    Some of the $12.6 million in penalties the IRS on imposed a man for willfully failing to report foreign bank accounts were in violation of the Eighth Amendment's bar on excessive fines, the Eleventh Circuit ruled, creating an apparent circuit split.

  • September 03, 2024

    5th Circ. Rejects 4 Arguments Against $6K Tax Bill

    The U.S. Tax Court correctly determined a man owed over $5,000 in tax deficiencies as well as more than $1,000 in penalties plus interest, the Fifth Circuit ruled Tuesday, finding none of the taxpayer's four arguments persuasive.

  • September 03, 2024

    IRS Should Be Bound By $2M Bankruptcy Deal, Justices Told

    An Alabama real estate developer who sought bankruptcy protection and agreed to settle his tax debts for $2 million asked the U.S. Supreme Court to review a decision allowing the IRS to demand additional taxes from him, saying the agency shouldn't be allowed to back out of the deal.

  • September 03, 2024

    Ex-Defense Contractor Arrested In $350M Tax Evasion Case

    A former defense contractor who, with his wife, is facing a 30-count indictment alleging they were involved in a decades-long scheme to defraud the U.S. government and avoid taxes on more than $350 million in income was arrested Tuesday.

  • September 03, 2024

    9th Circ. Rejects Tax Lien Pro Rata Share In Bankruptcy Sale

    The bankruptcy court is not authorized to use the pro rata method to allocate proceeds between the IRS and an estate with a tax lien for unpaid taxes and penalties, the Ninth Circuit ruled Tuesday, saying there is nothing in bankruptcy law that explicitly allows this approach.

  • September 03, 2024

    Debtor's Late-Filing Case Should Be Reviewed, Justices Told

    Tax experts urged the U.S. Supreme Court to review a Ninth Circuit decision that found late-filed returns prevented a taxpayer from discharging his federal tax debt in bankruptcy, saying the case reflects a decades-long debate that has split the circuits three ways.

Expert Analysis

  • Understanding The IRC's Excessive Refund Claim Penalty

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    Taxpayers considering protective refund claims pending resolution of major questions in tax cases like Moore v. U.S., which is pending before the U.S. Supreme Court, should understand how doing so may also leave them vulnerable to an excessive refund claim penalty under Internal Revenue Code Section 6676, say attorneys at McDermott.

  • Don't Use The Same Template For Every Client Alert

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    As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

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    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

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    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.

  • Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks

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    Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

  • IRS Sings New Tune: Whistleblower Form Update Is Welcome

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    In a significant reform at the Internal Revenue Service's Whistleblower Office, the recently introduced revisions to the Form 211 whistleblower award application use new technology and a more intuitive approach to streamline the process of reporting allegations of tax fraud committed by wealthy individuals and companies, says Benjamin Calitri at Kohn Kohn.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.

  • Energy Community Tax Credit Boost Will Benefit Wind Sector

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    Recent Internal Revenue Service guidance broadening tax credit eligibility to more parts of offshore wind facilities in so-called energy communities is a win for the industry, which stands to see more projects qualify for a particularly valuable bonus in the investment tax credit context due to the capital-intensive nature of offshore wind projects, say attorneys at Troutman Pepper.

  • Weisselberg's Perjury At Trial Spotlights Atty Ethics Issues

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    Former Trump Organization executive Allen Weisselberg’s recent guilty plea for perjury in the New York attorney general's civil fraud trial should serve as a reminder to attorneys of their ethical duties when they know a client has lied or plans to lie in court, and the potential penalties for not fulfilling those obligations, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • Practicing Law With Parkinson's Disease

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    This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.

  • Why Supreme Court Should Allow Repatriation Tax To Stand

    If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.

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