Federal
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January 22, 2025
Captive Insurance Co. Head Seeks Tax-Shelter Fine Refund
A tax attorney who heads a business that creates captive insurance companies said the IRS wrongly accused him of promoting an abusive tax shelter, telling an Ohio federal court the agency owes him a refund of penalties he handed over.
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January 21, 2025
Tax Court Slashes $33M Easement Deduction
The U.S. Tax Court reduced a partnership's claimed $33 million tax deduction for a donation of a Georgia conservation easement Tuesday, saying the easement was only worth $4.7 million, partly because the partnership overestimated its development potential in a rural area.
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January 21, 2025
IRS Office Can't Verify Low-Income Aid Meets Requirements
The Internal Revenue Service office in charge of a program that provides assistance to low-income people dealing with tax disputes can't access information that would allow it to make sure grant recipients meet requirements, potentially harming the program's effectiveness, the Treasury Inspector General for Tax Administration said Tuesday.
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January 21, 2025
Expat Facing $6.9M In FBAR Penalties, Interest
An American woman living in Switzerland faces $6.9 million in penalties, interest and late fees because she did not report her accounts that were held at a Swiss bank, the U.S. government told a D.C. federal court.
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January 21, 2025
Union Calls For Block To Trump's Federal Workers Order
President Donald Trump must halt efforts to enforce his executive order easing the process to fire certain federal employees, the National Treasury Employees Union argued in a lawsuit, claiming thousands of workers could be at risk of termination "for any reason including political agenda."
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January 21, 2025
Co. Seeks IRS Refund In $2.7M Captive Insurance Case
A Delaware federal court should refund tax penalties a company paid on a $2.7 bill from the IRS for activities related to captive insurance companies and promoting abusive tax shelters, the company argued Tuesday, saying the government provided no proof it did anything wrong.
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January 21, 2025
Tribal Tax Status Regs Leave Energy Credit Access Up In Air
While recently proposed regulations would provide long-awaited clarity that enterprises wholly owned by Native American tribes are exempt from federal taxes, the rules leave glaring questions open about whether tribes can access clean energy tax credits through business structures like joint ventures.
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January 21, 2025
Senate Finance Committee Approves Trump's Treasury Pick
The Senate Finance Committee on Tuesday approved Scott Bessent, President Donald Trump's nominee for treasury secretary, sending his nomination to the full Senate for a vote.
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January 21, 2025
Trump Order Places IRS Under Indefinite Hiring Freeze
President Donald Trump said a hiring freeze that he ordered at federal government agencies will be harsher at the Internal Revenue Service, with the agency requiring an extra layer of review, with no specified end date, before hiring can restart.
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January 17, 2025
Law360 Names Practice Groups Of The Year
Law360 would like to congratulate the winners of its Practice Groups of the Year awards for 2024, which honor the attorney teams behind litigation wins and significant transaction work that resonated throughout the legal industry this past year.
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January 17, 2025
Law360 Names Firms Of The Year
Eight law firms have earned spots as Law360's Firms of the Year, with 54 Practice Group of the Year awards among them, steering some of the largest deals of 2024 and securing high-profile litigation wins, including at the U.S. Supreme Court.
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January 17, 2025
Par Funding's Fraud Caused $288M In Losses, Pa. Judge Says
Par Funding caused $288 million in losses stemming from a scheme to defraud investors who poured money into its cash advance business, a Pennsylvania federal judge said Friday, days after holding an evidentiary hearing where the government and the defendants sparred over dueling loss amounts.
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January 17, 2025
Feds Say Pa. Investment Adviser Stole $20M From Clients
A Pennsylvania investment adviser's alleged misappropriation of more than $20 million worth of client funds has landed him criminal charges and civil enforcement action from U.S. Securities and Exchange Commission.
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January 17, 2025
US Guidance On Amount B Carries Potential For Disputes
Recent IRS guidance on a simplified and streamlined transfer pricing method for certain cross-border transactions, known as Amount B, suggests rulemakers want feedback on how it would work if it were made mandatory, but that approach could lead to controversy without global cooperation.
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January 17, 2025
Bill Aims To Extend Biogas Investment Credit Through 2025
A bill in the U.S. House of Representatives would extend the clean energy investment tax credit available for certain biogas facilities' equipment through the end of 2025 instead of at the end of 2024, the bill's sponsors said Friday.
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January 17, 2025
11th Circ. Urged To Reject Biz Owners' Tax Penalty Challenge
The owners of an electronic parts company who asked the Eleventh Circuit to reverse a tax penalty and find that Tax Court judges have unconstitutional job protections failed to link the two and are not entitled to tax relief, the U.S. government said Friday.
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January 17, 2025
LA Crypto 'Godfather' Admits To $36M Meta Hacking Fraud
A Los Angeles-based cryptocurrency founder who called himself "The Godfather" will plead guilty to earning $36 million through the sale of hacked Meta Platforms advertising accounts and evading taxes on the fraudulent profits, according to federal court documents unsealed Friday,
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January 17, 2025
IRS Rewrites Residential Green Energy Credit FAQ
The Internal Revenue Service made substantial changes Friday to its fact sheet for the energy efficient home improvement and residential clean energy property tax credits.
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January 17, 2025
Meet The Key Players In Tom Goldstein's Tax-Crimes Case
The tax-evasion indictment of U.S. Supreme Court expert lawyer and SCOTUSblog publisher Tom Goldstein features an eclectic cast of characters linked to his purported side career as a high-stakes poker player, including law firm partners, professional gamblers, a Texas billionaire, a movie producer and an actor.
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January 17, 2025
Taxation With Representation: Simpson Thacher, Covington
In this week's Taxation With Representation, Eli Lilly and Co. buys a precision breast cancer program, Applied Digital Corp. enters a financing agreement for its high-performance computing business, Clearwater Analytics buys Enfusion, and Lantheus Holdings Inc. buys Life Molecular Imaging Ltd.
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January 17, 2025
Ex-Pol's Atty Chided For Early Morning Sentencing Memo
The lawyer for a former Massachusetts state senator convicted of tax and pandemic aid fraud was scolded by a federal judge on Friday for filing a sentencing memo at 3:30 a.m. on the day of the hearing, then showing up late to court, forcing a postponement.
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January 17, 2025
Co. Suggests 4 Chemicals For Taxable Substances List
The Internal Revenue Service is seeking comments on proposals from Occidental Chemical Corp. to add four chemicals to the Internal Revenue Code's list of taxable substances, the agency said Friday.
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January 17, 2025
IRS Commissioner To Step Down As Trump Takes Office
Internal Revenue Commissioner Daniel Werfel is stepping down from his position in light of President-elect Donald Trump's intent to nominate former Rep. Billy Long to replace him, Werfel said in a message to the agency's employees Friday.
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January 17, 2025
Vanguard To Pay SEC, States $106M Over Surprise Tax Bills
The U.S. Securities and Exchange Commission was joined by dozens of state regulators Friday in announcing a $106.4 million settlement with The Vanguard Group Inc. over claims that the company misled investors about the heightened capital gains taxes they would have to pay on certain retirement savings accounts.
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January 17, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included revised rules for companies that file consolidated federal income tax returns to modernize previous rules' terminology, including removing gender-specific pronouns.
Expert Analysis
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US-Chile Tax Treaty May Encourage Cross-Border Investment
Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.
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A Look Ahead For The Electric Vehicle Charging Industry
This will likely be an eventful year for the electric vehicle market as government efforts to accelerate their adoption inevitably clash with backlash from supporters of the petroleum industry, say Rue Phillips at SkillFusion and Enid Joffe at Green Paradigm Consulting.
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A Post-Mortem Analysis Of Stroock's Demise
After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.
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SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
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Planning A Defense As IRS Kicks Off Sports Losses Campaign
Sports team owners and partnerships face potential examination under the Internal Revenue Service’s recently announced sports industry losses campaign, and should be preparing to explain what drove their reported losses and assembling documentation to support their tax return positions and accounting methods, say Sheri Dillon and Jennifer Breen at Morgan Lewis.
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What New Calif. Strike Force Means For White Collar Crimes
The recently announced Central District of California strike force targeting complex corporate and securities fraud — following the Northern District of California's model — combines experienced prosecutorial leadership and partnerships with federal agencies like the IRS and FBI, and could result in an uptick in the number of cases and speed of proceedings, say attorneys at MoFo.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.
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As Promised, IRS Is Coming For Crypto Tax Evaders
The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.
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5 Reasons Associates Shouldn't Take A Job Just For Money
As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.
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Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules
Regulations recently proposed by the IRS and the U.S. Department of the Treasury concerning two types of tax credits for clean hydrogen production facilities should resolve many of the most pressing questions around qualification for the credits — albeit in a relatively stringent manner, say attorneys at Morgan Lewis.
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Employee Experience Strategy Can Boost Law Firm Success
Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.