Federal

  • January 16, 2025

    Tax Court Denies Late Pass For Identity Theft

    A California couple cannot challenge an Internal Revenue Service decision to levy their state tax refund because they missed the deadline for filing a petition by four years, the U.S. Tax Court said Thursday, rejecting their request for an extension for dealing with identity theft.

  • January 16, 2025

    DOJ Tax Chief Touts Winning Court Record On Appeals

    The U.S. Department of Justice's Tax Division won an overwhelming majority of appeals in tax cases last year by prioritizing strong legal arguments in disputes that had the potential to significantly affect federal tax administration, the head of the division said Thursday.

  • January 16, 2025

    Tax Court Rejects Explanation For Unreported Wages

    A woman owes taxes on nearly $19,000 of unreported income she said she reported on a gift tax return, the U.S. Tax Court ruled Thursday, rejecting her argument that wages reported as gifts would not incur taxes.

  • January 16, 2025

    Tax Court Tosses Some Of Ind. Couple's Deduction Claims

    The U.S. Tax Court had mixed responses Thursday related to an Indiana couple's claimed business deductions tied to a rental property as well as itemized deductions related to the husband's work as an electrician, allowing some while saying others weren't properly substantiated.

  • January 16, 2025

    IRS Explains Changing Elective Payment Accounting Periods

    The IRS provided procedures Thursday for certain entities — including Native American tribes and state governments — that aren't required to file federal income tax returns but have chosen to make elective payments and want to change their taxable years to match their accounting periods.

  • January 16, 2025

    AmEx Inks $230M Deal Over DOJ, Fed Small Biz Sales Claims

    American Express has signed a nonprosecution agreement and said Thursday it will pay about $230 million to end investigations by the Department of Justice and the Federal Reserve into the financial services company's previous sales practices for some small business customers in the U.S.

  • January 16, 2025

    Tax Court's 90-Day Deadline Is Not Fixed, 6th Circ. Told

    A woman who missed the 90-day deadline for challenging her liabilities in the U.S. Tax Court told the Sixth Circuit on Thursday that the Internal Revenue Service has wrongly argued that case law proves the deadline is set in stone.

  • January 16, 2025

    SCOTUSblog Publisher Tom Goldstein Indicted In Tax Case

    Tom Goldstein, a publisher of SCOTUSblog and one of the most experienced U.S. Supreme Court lawyers in the country, was indicted Thursday in Maryland federal court on charges he schemed to evade paying taxes for years and used funds from his boutique law firm to cover gambling debts. 

  • January 16, 2025

    OECD To Release List Of Abusive Transactions Under Pillar 2

    The Organization for Economic Cooperation and Development is putting together a list of intercompany transactions that may raise red flags as attempts to undermine an international minimum tax agreement known as Pillar Two, an OECD official said Thursday.  

  • January 16, 2025

    Morrison Foerster Adds Tax Group Co-Chair From Jones Day

    Morrison Foerster LLP announced it has added a partner from Jones Day to serve as co-chair of the firm's global tax group in its New York office.

  • January 16, 2025

    Atty Gets 5-Year NJ Suspension After Tax Fraud Conviction

    A Philadelphia-based personal injury attorney convicted for not paying income tax on more than $8 million in revenue he earned and for failing to pay almost $60,000 in payroll taxes received a five-year suspension from New Jersey's Supreme Court but will keep his law license in the state.

  • January 16, 2025

    IRS Corrects Simplified Foreign Currency Rules

    The Internal Revenue Service issued corrections Thursday to finalized regulations that aim to simplify aspects of how corporations determine taxable income or loss with respect to certain affiliates that conduct business in a foreign currency.

  • January 16, 2025

    Treasury Updates Bonus Energy Tax Credit Safe Harbors

    The U.S. Treasury Department provided updates Thursday to safe harbors that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing steel and aluminum parts in response to new trade restrictions on solar products from China by President Joe Biden's administration.

  • January 15, 2025

    Tax Court Rejects Brothers' Claims Of Gifted Jewelry

    The U.S. Tax Court on Wednesday upheld $2.5 million in taxes, plus fraud penalties, against brothers who claimed an unreported bank account held nontaxable proceeds from the sale of their mother's gift of 1,600 pieces of jewelry from Israel and Iran.

  • January 15, 2025

    Dems, GOP Willing To Work On Certain Tax Issues, Aides Say

    Democrats are willing to work with Republicans on bipartisan issues, such as providing certain treaty-like benefits to Taiwanese residents, retirement issues, and tax administration issues, Democratic and GOP aides for the House Ways and Means and Senate Finance committees said Wednesday.

  • January 15, 2025

    More IRS Partnership 'Soft Letters' Coming, Official Says

    The Internal Revenue Service will keep using an educational compliance tool called soft letters to prod taxpayers to comply with a centralized partnership audit regime that has recently turned its focus to larger and more complicated entities, an agency official said Wednesday.

  • January 15, 2025

    Former IRS Litigator Joins Jones Day In Boston

    Jones Day announced it added an experienced IRS litigator to its Boston office who will work as of counsel in the firm's tax practice.

  • January 15, 2025

    Legislators Say Transparency Act Defies First Amendment

    The Corporate Transparency Act is an unnecessary intrusion into the First Amendment rights of Americans, U.S. Sen. Thom Tillis, R-N.C., and 13 House members told the Supreme Court in seeking to maintain an injunction issued in December.

  • January 15, 2025

    IRS Establishes Clean Vehicle Credit Valuation Safe Harbors

    The Internal Revenue Service provided two safe harbors Wednesday for calculating the value of the commercial clean vehicle tax credit using either modeled incremental costs or retail-price equivalents.

  • January 15, 2025

    House Clears US-Taiwan Double Tax Relief Bill

    The U.S. House of Representatives overwhelmingly approved legislation Wednesday that would provide Taiwanese businesses in the United States with tax-treaty-like benefits and authorize the White House to negotiate a tax agreement with Taiwan.

  • January 15, 2025

    9th Circ. Won't Review Nixed Deductions For Disbarred Atty

    The Ninth Circuit on Wednesday rejected a disbarred California attorney's requests to review its December decision to uphold a U.S. Tax Court ruling denying his bid to take business deductions for the cost of challenging his disbarment and a court's declaration that he is a "vexatious litigant."

  • January 15, 2025

    IRS Pilots Aim To Broaden Fast-Track Settlement Program

    The Internal Revenue Service announced Wednesday that it would test changes to its settlement procedures through pilot programs that aim to allow more businesses and self-employed people to keep their disputes with the agency out of court. 

  • January 15, 2025

    IRS Lists Facility Types Eligible For Clean Energy Credits

    The Internal Revenue Service on Wednesday released the first annual table showing the types of facilities that have been deemed to not produce greenhouse gas emissions and are therefore eligible for the clean energy production and investment tax credits.

  • January 15, 2025

    IRS Mulling Widened Early Application Of Offshore Profit Regs

    The Internal Revenue Service is considering expanding the early application option for proposed regulations designed to help U.S. multinational corporations properly account for previously taxed earnings and profits, an agency official said Wednesday.

  • January 15, 2025

    Booz Allen Must Pay For Harm Of Tax Info Leaks, Court Told

    A proposed class action in Maryland federal court blames IRS contractor Booz Allen Hamilton over the thousands of tax returns that were stolen by an employee who took financial information about President-elect Donald Trump and others while on the job and leaked it to the media.

Expert Analysis

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

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    A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

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    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.

  • How IRA Unlocks Green Energy Investments For Tribes

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    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.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

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    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.

  • What To Know About IRS' New Jet Use Audit Campaign

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    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.

  • Stay Interviews Are Key To Retaining Legal Talent

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    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.

  • Judicial Independence Is Imperative This Election Year

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    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.

  • Spartan Arbitration Tactics Against Well-Funded Opponents

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    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.

  • What Recent Study Shows About AI's Promise For Legal Tasks

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    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.

  • How FinCEN Proposal Expands RE Transaction Obligations

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    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.

  • What To Know About Employee Retention Credit Disclosures

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    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.

  • Litigation Inspiration: A Source Of Untapped Fulfillment

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    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.

  • Unpacking FinCEN's Proposed Real Estate Transaction Rule

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    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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