Federal

  • December 04, 2024

    US Drops 9th Circ. Bid To Revive Bad Debt Fraud Penalties

    The federal government agreed to stop challenging a U.S. Tax Court decision that found a businessman didn't owe fraud penalties even though he improperly took a multimillion-dollar bad debt deduction for loans he made to his companies, according to a Ninth Circuit filing.

  • December 04, 2024

    IRS Cancels Hearing On Tax Payments With Cards

    The Internal Revenue Service will not be holding its scheduled meeting Friday on proposed regulations that would allow taxpayers to make payments using credit and debit cards directly with the agency instead of through a third party, it said Wednesday.

  • December 03, 2024

    Hunter Biden's Gun, Tax Cases Axed After Presidential Pardon

    Federal judges in Delaware and California on Tuesday closed the books on Hunter Biden's felony gun and tax evasion cases, just ahead of his sentencing hearings, after President Joe Biden issued a sweeping pardon of his son over the weekend.

  • December 03, 2024

    Texas Judge Blocks 'Quasi-Orwellian' Anti-Laundering Law

    A Texas federal judge on Tuesday halted the Biden administration's roll-out of new reporting requirements aimed at unmasking anonymous shell companies, granting a nationwide preliminary injunction sought by business interests challenging their constitutionality.

  • December 03, 2024

    Ex-Braves Blast Tax Court's 'Disregard' In Easement Fight

    Two former Atlanta Braves players penalized for allegedly overstating the value of a conservation easement donation urged the Eleventh Circuit to toss the costly ruling against them, saying the U.S. Tax Court's decision showed "blatant disregard" for the appeal court's precedent in deciding the matter.

  • December 03, 2024

    Fried Frank Adds Goodwin Procter Tax Pro As Partner In NY

    Fried Frank Harris Shriver & Jacobson LLP announced Tuesday that a Goodwin Procter LLP tax and business law partner has joined the firm and will serve as a partner in Fried Frank's tax department in New York.

  • December 03, 2024

    'Bitcoin Jesus' Calls $48M Tax Dodging Case Unconstitutional

    An early Bitcoin investor known as Bitcoin Jesus asked a California federal judge Tuesday to dismiss charges that he dodged approximately $48 million in taxes by filing false tax returns and concealing how much cryptocurrency he owned, arguing that the charges are unconstitutional.

  • December 03, 2024

    Exelon Asks For Corp. AMT To Account For Repairs Deduction

    Power companies should be allowed to account for an industry-specific tax deduction on repair costs to determine whether they're subject to the corporate alternative minimum tax, utility giant Exelon said in a comment letter to the U.S. Treasury Department released Tuesday.

  • December 03, 2024

    Premium Tax Credit 'Coverage Month' Hearing Canceled

    The Internal Revenue Service and U.S. Treasury Department announced Tuesday that they will not hold a hearing on a proposed expanded definition of a "coverage month" for purposes of computing the health insurance premium tax credit after receiving no interest about the hearing.

  • December 03, 2024

    Comment Deadline Extended For Corp. Alternative Min. Tax

    Treasury and the Internal Revenue Service said Tuesday that they will accept comments on proposed rules for the new 15% corporate alternative minimum tax on corporations with reported profits of $1 billion or more until Jan. 16, a roughly one-month extension from the previous deadline.

  • December 03, 2024

    Tax, Insurance Cos. Owner Gets 3 Years For $1M Tax Evasion

    The owner of a tax business who also ran an insurance company the government says provided fraudulent vehicle registrations for unauthorized immigrants was sentenced to three years in prison for failing to pay more than $1 million in taxes, federal authorities in North Carolina announced Tuesday.

  • December 02, 2024

    Biden's Pardon Is Another Blow To Special Counsel Probes

    President Joe Biden's pardon of his son over the weekend marks the latest example of a special counsel investigation fizzling and raises doubts over the future use of such probes, which can drag on for years and cost taxpayers millions of dollars.

  • December 02, 2024

    Texas Truck Co. Owes Chinese Tire Import Tax, 5th Circ. Says

    A Houston truck company that sold tires made by a Chinese manufacturer is on the hook for excise taxes as the beneficial owner of the tires, the Fifth Circuit decided in an opinion Monday that reversed a ruling freeing the company from its nearly $2 million tax bill.

  • December 02, 2024

    IRS Floats Pooling, Annual Accounting In Offshore Profit Regs

    U.S. multinational companies will be required to create annual shareholder accounts and adhere to new pooling concepts to properly account for previously taxed earnings and profits under proposed rules floated by the U.S. Treasury Department and Internal Revenue Service.

  • December 02, 2024

    A&O Shearman Tax Pro Jumps To Hogan Lovells In DC

    Hogan Lovells said Monday that it has brought on a former Allen Overy Shearman Sterling tax partner who specializes in spinoffs, cross-border deals and other corporate transactions.

  • December 02, 2024

    DEA Asserts Its Role As Proponent Of Pot Rescheduling Plan

    The Drug Enforcement Administration on Monday affirmed it was acting as the proponent of a proposal to loosen federal restrictions on marijuana, and the administrative law judge said supporters of rescheduling would not get an opportunity to cross-examine DEA witnesses.

  • December 02, 2024

    Justices On Fence In Tax Clawback Case For Defunct Utah Co.

    U.S. Supreme Court justices seemed divided during oral arguments Monday over whether the Tenth Circuit was correct to allow the bankruptcy trustee of a defunct Utah company to use state law to claw back $145,000 in federal taxes after the two-year deadline, a ruling that has created a 3-1 circuit split.

  • December 02, 2024

    Calif. Biz Owner Can't Deduct Car Expenses, Tax Court Says

    A California business owner failed to prove he is entitled to deductions related to car and truck expenses, the U.S. Tax Court said in a decision released Monday.

  • December 02, 2024

    IRS Finalizes Partnership Liability Regs After 11 Years

    The Internal Revenue Service unveiled final regulations governing the allocation of partnership liabilities 11 years after releasing the proposed rules, saying no subsequent legislative and regulatory changes had taken place to compel the agency to otherwise renew the rulemaking process.

  • December 02, 2024

    IRS Regs Would Broaden Exception For Unmarked Vehicles

    Unmarked vehicles used by firefighters or members of a rescue squad or ambulance crew would be considered a new type of qualified nonpersonal use vehicle that is exempted from substantiation requirements under regulations proposed Monday by the Internal Revenue Service.

  • December 02, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's latest weekly bulletin included updates to tax interest and applicable federal rates as well as the corporate bond monthly yield curve.

  • November 27, 2024

    Georgia Couple Asks Full DC Circ. To Review Tax Case

    A Georgia couple whose challenge of a 2019 tax collection was denied by both the U.S. Tax Court and a D.C. Circuit panel is asking for the full appellate court to reconsider its ruling.

  • November 27, 2024

    US Says Prof's 8th Amendment Argument Fails In FBAR Case

    An 86-year-old former professor cannot claim that his $545,000 penalty for failing to report foreign bank accounts violates the Eighth Amendment, the U.S. told a federal court, saying the penalty is neither excessive nor a fine, and that he never raised the argument before.

  • November 27, 2024

    Up Next At The High Court: Transgender Care, Holocaust Art

    The U.S. Supreme Court will return to the bench Monday for its December arguments session, which will include blockbuster questions about the constitutionality of state laws banning gender-affirming care for transgender minors and whether Hungary can be held liable for property stolen during World War II.

  • November 27, 2024

    US Seeks FBAR Penalties Over $1.7M In Foreign Accounts

    A Texas woman should face penalties for willfully failing to disclose foreign bank accounts from 2011 through 2013, which held balances exceeding $1.7 million, the U.S. government told a federal court Wednesday.

Expert Analysis

  • Lead Like 'Ted Lasso' By Embracing Cognitive Diversity

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    The Apple TV+ series “Ted Lasso” aptly illustrates how embracing cognitive diversity can be a winning strategy for teams, providing a useful lesson for law firms, which can benefit significantly from fresh, diverse perspectives and collaborative problem-solving, says Paul Manuele at PR Manuele Consulting.

  • Class Actions At The Circuit Courts: July Lessons

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    In this month's review of class action appeals, Mitchell Engel at Shook Hardy considers cases touching on pre- and post-conviction detainment conditions, communications with class representatives, when the American Pipe tolling doctrine stops applying to modified classes, and more.

  • Now More Than Ever, Lawyers Must Exhibit Professionalism

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    As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.

  • Reading Between The Lines Of Justices' Moore Ruling

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    The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.

  • A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates

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    Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.

  • States Should Loosen Law Firm Ownership Restrictions

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    Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.

  • After Chevron: Uniform Tax Law Interpretation Not Guaranteed

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    The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.

  • Texas Ethics Opinion Flags Hazards Of Unauthorized Practice

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    The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • How High Court Approached Time Limit On Reg Challenges

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    The U.S. Supreme Court's decision in Corner Post v. Federal Reserve Board effectively gives new entities their own personal statute of limitations to challenge rules and regulations, and Justice Brett Kavanaugh's concurrence may portend the court's view that those entities do not need to be directly regulated, say attorneys at Snell & Wilmer.

  • How To Clean Up Your Generative AI-Produced Legal Drafts

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    As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.

  • A Tale Of 2 Trump Cases: The Rule Of Law Is A Live Issue

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    The U.S. Supreme Court’s decision this week in Trump v. U.S., holding that former President Donald Trump has broad immunity from prosecution, undercuts the rule of law, while the former president’s New York hush money conviction vindicates it in eight key ways, says David Postel at Henein Hutchison.

  • Industry Self-Regulation Will Shine Post-Chevron

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    The U.S. Supreme Court's Loper decision will shape the contours of industry self-regulation in the years to come, providing opportunities for this often-misunderstood practice, says Eric Reicin at BBB National Programs.

  • 3 Ways Agencies Will Keep Making Law After Chevron

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    The U.S. Supreme Court clearly thinks it has done something big in overturning the Chevron precedent that had given deference to agencies' statutory interpretations, but regulated parties have to consider how agencies retain significant power to shape the law and its meaning, say attorneys at K&L Gates.

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