Federal
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July 23, 2024
House Delays Vote On FY25 IRS Budget Legislation
The House delayed an expected vote Tuesday on the Internal Revenue Service's budget for fiscal 2025, casting doubt on whether GOP lawmakers will meet their goal of passing the funding bill before Congress' annual August recess begins next week.
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July 23, 2024
Newell Says IRS Misapplied Pricing Law In $124M Dispute
Newell Brands told the U.S. Tax Court the Internal Revenue Service misapplied transfer pricing law to levy almost $124 million in additional taxes and penalties.
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July 23, 2024
White House Taps VA Official To Helm Tax Watchdog
President Joe Biden has nominated a U.S. Department of Veterans Affairs investigator to serve as Treasury inspector general for tax administration, the Internal Revenue Service's federal watchdog, the White House announced Tuesday.
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July 23, 2024
Feds Urge 6th Circ. To Affirm Pharma Owner's Fraud Sentence
The Sixth Circuit should affirm a district court's fraud convictions, nearly five-year sentence and $7 million restitution order against an Ohio pharmaceutical salesman who underreported his income to reduce his tax liability in a multimillion-dollar scheme involving bogus insurance billings, the federal government said.
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July 23, 2024
Farm Owner Must Boost Taxable Income, 8th Circ. Told
An Arkansas company that leases farmland must raise its reported income by $230,000 because it failed to get permission from the IRS to change its accounting method, the U.S. told the Eighth Circuit on Tuesday in asking it to uphold a U.S. Tax Court ruling.
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July 23, 2024
IRS Notice Signals Direction On Corp. AMT Regs, Official Says
An Internal Revenue Service notice regarding the U.S. corporate alternative minimum tax can be read as a signal about how the agency will more broadly address the measure's potential for counting offshore income twice, an IRS official said Tuesday.
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July 23, 2024
Winston & Strawn Adds MoFo Tax Pro As Partner In NY
Winston & Strawn LLP has added a transactional tax specialist from Morrison Foerster LLP as a partner with the firm's transactions department and tax practice in New York.
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July 23, 2024
Former Doctor To Be Released From Jail In FBAR Fight
A former doctor will be released from U.S. custody after a Michigan federal court lifted Tuesday an order of civil contempt against him for failure to pay about $1 million in foreign account reporting penalties.
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July 23, 2024
Orrick Hires Ex-Winston & Strawn Tax Partner In Chicago
Orrick Herrington & Sutcliffe LLP announced the hiring of a former partner at Winston & Strawn LLP for its renewables tax equity and tax credit team.
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July 23, 2024
11th Circ. Should Uphold Tax Court Protection, IRS Says
The Eleventh Circuit should uphold a U.S. Tax Court ruling that denied a widow tax relief and also rejected her claim that Tax Court judges have unconstitutional job protection, the Internal Revenue Service told the circuit court.
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July 23, 2024
5-Hour Energy Partner Owes No Tax On Sale, DC Circ. Says
The D.C. Circuit found Tuesday that a Canadian citizen's $6.5 million in gains from her sale of a U.S. partnership interest in a company that sold 5-hour Energy drinks was not federally taxable as inventory income, reversing a U.S. Tax Court ruling.
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July 23, 2024
IRS Makes Corrections To 2 Proposed Regulations
The Internal Revenue Service issued a handful of corrections Tuesday to two notices of proposed rulemaking, one regarding certain partnership related-party basis adjustment transactions and the other interest capitalization requirements for improvements to designated property.
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July 22, 2024
3 Policies Tax Pros Want Congress To Pass This Year
As momentum around the House-passed tax break bill has fizzled and election season ramps up, tax experts hope lawmakers use what little time they have left to extend expired research tax breaks, approve the Taiwanese tax agreement and pass disaster relief before the end of the year. Here are three policy changes tax professionals think Congress should make before the end of the year.
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July 22, 2024
CPAs Back Bill To Apply Mailbox Rule To Electronic Returns
The American Institute of Certified Public Accountants said Monday that it endorsed a congressional proposal that would apply what is known as the mailbox rule to electronically submitted tax returns and shift the deadlines for estimated tax payments to intervals that are actually quarterly.
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July 22, 2024
US Treasury Working To Extend Pillar 1 DST Compromise
As OECD-led negotiations continue on a taxing rights overhaul known as Pillar One after a missed June deadline, the U.S. Treasury Department is working to extend the political agreement between it and several countries to nullify their digital services taxes once the rights overhaul is implemented.
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July 22, 2024
Pension Plans Slam Biz Docs In $2B Danish Tax Fraud Case
Denmark's tax agency has produced experts who are relying on unauthenticated documents in litigation accusing U.S. pension plans of participating in a $2.1 billion fraud scheme, the pension plans claimed in urging a New York federal court to exclude the testimony.
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July 22, 2024
11th Circ. Denies Rehearing On Social Security Garnishment
The Eleventh Circuit on Monday turned down a Florida woman's request to reconsider its rejection of her challenge to the Internal Revenue Service's garnishment of her Social Security payments.
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July 22, 2024
Werfel Wants IRS to Help Eligible EITC Nonclaimaints
The Internal Revenue Service needs to do more to help people who are eligible for the earned income tax credit but don't claim it, Daniel Werfel, the agency's commissioner, said Monday.
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July 22, 2024
IRS Delays Tax Deadlines For Texans Affected By Hurricane
Certain Texas taxpayers affected by Hurricane Beryl, which hit the state this month, will have until a delayed deadline of Feb. 3 to file individual and business tax returns and make payments, the Internal Revenue Service said Monday.
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July 22, 2024
Kyocera Failed To Back R&D Credits With Records, US Says
Multinational electronics maker Kyocera AVX Components Corp. failed to back up its claim to research tax credits with the required paperwork, the U.S. government told a South Carolina federal court in asking it to stop part of the company's nearly $9 million refund suit from going to trial.
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July 19, 2024
House Panel To Weigh EV Credit Restrictions, IRS' Use Of AI
The House Rules Committee will consider amendments Monday to a fiscal 2025 funding bill that would give the IRS $10.1 billion, sorting through divergent priorities of lawmakers from integrating artificial intelligence into agency operations to restricting tax credits for electric vehicles and helping seniors file tax returns.
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July 19, 2024
Partnership Protests IRS' Reasons For $84M Deduction Denial
The Internal Revenue Service wrongly denied a partnership's charitable contribution deduction of nearly $84 million for a donated conservation easement for reasons including the partnership failing to demonstrate it made the contribution, the partnership's representative told the U.S. Tax Court.
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July 19, 2024
Cox Owner's Estate Claims IRS Miscalculated $46M Tax Bill
The estate of an owner of the Cox Enterprises media empire challenged a $46 million tax bill from the Internal Revenue Service, telling the U.S. Tax Court that the agency erroneously calculated the tax by inflating the value of the company's stock by about $20 per share.
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July 19, 2024
Attorney Denied Separate Trial In $2.1B Danish Tax Fraud
An attorney facing trial alongside his clients for alleged ties to a $2.1 billion Danish tax fraud has been denied a separate hearing by a New York federal court, which remained unconvinced that his co-workers' advice to the clients could rebound on him prejudicially in a joint trial.
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July 19, 2024
Taxation With Representation: A&O Shearman, Gibson Dunn
In this week's Taxation With Representation, Cleveland-Cliffs Inc. buys Stelco Holdings Inc., KBR acquires LinQuest Corp., Blue Owl Capital Inc. purchases Atalaya Capital Management LP, and Amphenol Corp. buys two mobile networks units from CommScope.
Expert Analysis
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Tech CEO Tax Ruling A Warning For Forward Contracts
In McKelvey v. Commissioner, the U.S. Tax Court decided that deceased Monster.com founder Andrew McKelvey terminated his underlying obligations when he extended variable prepaid forward contracts, demonstrating why startup founders, early employees and investors should think carefully before amending derivative agreements, say Daren Shaver and Trent Tanzi at Hanson Bridgett.
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4 Legal Ethics Considerations For The New Year
As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.
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What The Law Firm Of The Future Will Look Like
As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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4 PR Pointers When Your Case Is In The News
Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.
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Unpacking The Proposed Production Tax Credit Regulations
Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.
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10 Considerations For Litigating A New York Tax Case
While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.
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Charting The Course For Digital Assets In 2024
Although 2023 was a tough year for the digital asset industry, upcoming court decisions, legislation and regulatory action will bring clarity, allowing the industry to expand and evolve, and the government will decide what innovation it will allow without challenge, says Joshua Smeltzer at Gray Reed.
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Law Firm Strategies For Successfully Navigating 2024 Trends
Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.
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Attorneys' Busiest Times Can Be Business Opportunities
Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.
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How Attorneys Can Be More Efficient This Holiday Season
Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.
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Giving The Gov't Drug Patent March-In Authority Is Bad Policy
The Biden administration's recent proposal to allow government seizure of certain taxpayer-funded drug patents is a terrible idea that would negate the benefits of government-funded research, to the detriment of patients and the wider economy, says Wayne Winegarden at Pacific Research Institute.
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How Clients May Use AI To Monitor Attorneys
Excerpt from Practical Guidance
Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.
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The Pop Culture Docket: Judge D'Emic On Moby Grape
The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.