Federal

  • November 04, 2024

    Justices Let Stand Bar On Late-Filed Returns In Bankruptcy

    The U.S. Supreme Court said Monday it would let stand a Ninth Circuit decision finding late-filed returns prevented a taxpayer from discharging his federal tax debt in bankruptcy, rejecting the taxpayer's request to resolve what he described as a significant circuit split.

  • November 04, 2024

    IRS Finalizes Seized Property Rules To Include Online Sales

    The Internal Revenue Service issued final rules Monday meant to modernize regulations governing the seizure of property by levy, including facilitating the online sale of a property and the agency's ability to maximize sale proceeds for the property owner's benefit.

  • November 01, 2024

    Previously Taxed Profit Rules Due By Year's End, Official Says

    The Internal Revenue Service will publish the first tranche of long-awaited regulations on offshore earnings and profits previously taxed in the U.S. before the end of the year, an agency counsel said Thursday.

  • November 01, 2024

    NOL Rules May Retain Favorable Approach, IRS Counsel Says

    New proposed regulations governing business net operating losses that could retain a popular provision allowing some businesses expanded use of those losses are a priority to be published next year, a top Internal Revenue Service lawyer said.

  • November 01, 2024

    Brazil Should Adopt Latest Pillar 2 Safe Harbor, NFTC Says

    Brazil should include the latest updates to globally agreed-upon safe harbors in its legislation to enact an international minimum tax agreement known as Pillar Two, according to the National Foreign Trade Council, which said these measures help prevent double taxation.

  • November 01, 2024

    Couple Tries To Block IRS Summons Issued For Spain

    A couple asked a California federal court to block an IRS summons for their financial information issued on behalf of Spain, saying the demand is tantamount to a fishing expedition meant to help the foreign government prosecute them.

  • November 01, 2024

    Taxation With Representation: Kirkland, Davis Polk, Wachtell

    In this week's Taxation with Representation, BC Partners sells its majority equity interest in GardaWorld, Lone Star Funds sells specialty chemicals company AOC to Nippon Paint Holdings, Crescent Biopharma takes GlycoMimetics private, and Francisco Partners buys AdvancedMD from Global Payments.

  • November 01, 2024

    Danish Tax Agency To Settle With Atty In $2.1B Tax Fraud Suit

    Denmark's tax authority has agreed to settle with an attorney whom it has accused of helping clients claim fraudulent tax refunds in a sprawling $2.1 billion case, according to a letter by its attorney in New York federal court.

  • November 01, 2024

    GOP Gains Could Prompt Push For Endowment Tax Hike

    If Republicans make significant gains in the upcoming elections, it could clear the way for GOP lawmakers to push to boost taxes on the endowments of some private colleges and universities.

  • November 01, 2024

    IRS Ups Contribution Limit For 401(k), Other Plans

    The annual amount that employees can contribute to various retirement plans has been increased to $23,500 from $23,000 as part of cost-of-living adjustments released Friday by the IRS.

  • November 01, 2024

    CFC Dividend Tax Issue Brewing In Exams, IRS Official Says

    A memorandum from the IRS chief counsel explaining why a controlled foreign corporation cannot claim a 100% deduction for certain foreign-based earnings was necessary to inform field agents dealing with the issue in the exam process, an agency official said Thursday.

  • November 01, 2024

    Accountant Gets 1 Year For Failing To Report Stolen Income

    An accountant for a manufacturing company who embezzled more than $800,000 and failed to report it on his tax returns was sentenced to just over a year in prison and ordered to pay $1 million in restitution, according to New Jersey federal court documents.

  • November 01, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included the annual inflation adjustments to over 60 tax provisions.

  • October 31, 2024

    Man Didn't Justify His Claims He Couldn't Pay, Tax Court Says

    The Internal Revenue Service didn't abuse its discretion when it upheld levies to collect over $58,000 in outstanding tax liabilities, including penalties and interest, after a man failed to substantiate his claims of medical hardship, the U.S. Tax Court said Thursday.

  • October 31, 2024

    Treasury Using Help To Clear Pillar 1 'Logjam,' Official Says

    Other executive agencies in President Joe Biden's administration have backed the U.S. Treasury Department in urging negotiators at the Organization for Economic Cooperation and Development to reach a final deal on the international taxing rights overhaul known as Pillar One, a top Treasury official said Thursday.

  • October 31, 2024

    Exxon Entitled To Interest Deduction On Qatar Deal

    Exxon Mobil is entitled to an interest expense deduction on payments to Qatar under a natural gas deal, a Texas federal judge ruled, rejecting the U.S. government's classification of an underlying transaction as a royalty rather than a loan.

  • October 31, 2024

    Treasury Official Previews M&A Details For Corp. AMT Rules

    U.S. rulemakers plan to further address how the country's corporate alternative minimum tax applies to transactions including spinoffs and deals that involve a member of a tax consolidated group, a U.S. Treasury Department official said Thursday.

  • October 31, 2024

    4 Ways Congress Could Try To Close The Tax Gap

    The gap between federal taxes owed and paid — recently estimated at $696 billion for 2022 — could be addressed in several ways, including increasing information reporting or simplifying the tax code, experts told Law360.

  • October 31, 2024

    Pro Baller Avoids Prison Over Tax, Child Support Scam

    A professional basketball player was sentenced to three years of probation in Ohio federal court after being charged with conspiracy and wire fraud for allegedly attempting to avoid paying child support and taxes for several years.

  • October 31, 2024

    6th Circ. Wary Of Bid To Overturn $500M Win For Truck Co.

    Sixth Circuit judges seemed skeptical Thursday of the government's $500 million bid to overturn a Tennessee jury's decision that a company's refurbished trucks qualified for a safe harbor from excise taxes, saying the government's reading of a tax provision was unclear.

  • October 31, 2024

    The 2024 Law360 Pulse Leaderboard

    Check out the Law360 Pulse Leaderboard to see which firms made the list of leaders in all-around excellence this year.

  • October 31, 2024

    Firms' Hiring Strategies Are Evolving In Fight For Top Spot

    Competition for top talent among elite law firms shows no signs of slowing down, even amid economic uncertainty, with financially strong firms deploying aggressive strategies to attract and retain skilled professionals to solidify their market position.

  • October 31, 2024

    11th Circ. Nixes ERISA Claim To John Hancock's $100M Credit

    John Hancock Life Insurance Co. had no fiduciary duty to pass on to retirement plans $100 million in foreign tax credits that it had taken from taxes paid on foreign investments, a three-judge panel of the Eleventh Circuit said in upholding a lower court ruling.

  • October 30, 2024

    FinCEN Extends BOI Report Deadline For Hurricane Victims

    The U.S. Department of the Treasury's Financial Crimes Enforcement Network has extended deadlines for submitting beneficial ownership information for victims of recent hurricanes, offering an additional six months to file or update reports, or to correct prior reports.

  • October 30, 2024

    Jury Finds Importer Didn't Report $17M On Tax Returns

    A Los Angeles jury found an importer of Chinese clothing guilty of skirting more than $8 million in customs duties and failing to report more than $17 million in cash transactions on tax returns, federal prosecutors in California announced Wednesday.

Expert Analysis

  • Why Attorneys Should Consider Community Leadership Roles

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    Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.

  • Firms Must Offer A Trifecta Of Services In Post-Chevron World

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    After the U.S. Supreme Court’s Loper Bright Enterprises v. Raimondo decision overturning Chevron deference, law firms will need to integrate litigation, lobbying and communications functions to keep up with the ramifications of the ruling and provide adequate counsel quickly, says Neil Hare at Dentons.

  • 5 Tips To Succeed In A Master Of Laws Program And Beyond

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    As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.

  • Pros, Cons Of Disclosing Improper Employee Retention Credit

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    Employers considering the Internal Revenue Service’s second voluntary disclosure program, which allows companies to avoid penalties for erroneously claiming employee retention credits for the 2021 tax year by repaying the credits and naming the tax advisers who encouraged these abusive practices, should carefully weigh the program’s benefits against its potential drawbacks, say attorneys at Winston & Strawn.

  • How Law Firms Can Avoid 'Collaboration Drag'

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    Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.

  • Litigation Funding Disclosure Key To Open, Impartial Process

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    Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.

  • Whistleblowers Must Note 5 Key Differences Of DOJ Program

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    The U.S. Department of Justice’s recently unveiled whistleblower awards program diverges in key ways from similar programs at other agencies, and individuals must weigh these differences and look first to programs with stronger, proven protections before blowing the whistle, say Stephen Kohn and Geoff Schweller at Kohn Kohn.

  • What NFL Draft Picks Have In Common With Lateral Law Hires

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    Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.

  • Replacing The Stigma Of Menopause With Law Firm Support

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    A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.

  • Planning Law Firm Content Calendars: What, When, Where

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    During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.

  • Brownfield Questions Surround IRS Tax Credit Bonus

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    Though the IRS has published guidance regarding the Inflation Reduction Act's 10% adder for tax credits generated by renewable energy projects constructed on brownfield sites, considerable guesswork remains as potential implications seem contrary to IRS intentions, say Megan Caldwell and Jon Micah Goeller at Husch Blackwell.

  • Law Firms Should Move From Reactive To Proactive Marketing

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    Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.

  • The Big Issues A BigLaw Associates' Union Could Address

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    A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.

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