Federal

  • August 13, 2024

    Gov't Seeks To Use Liens To Nab Decades-Old $2.8M Tax Debt

    A businessman and his trust face the prospect of losing a New York property as the Internal Revenue Service asked a federal court to set aside conveyances to him of property with IRS tax liens and collect on a $2.8 million tax debt.

  • August 13, 2024

    Walz Backed Tax Hikes Funding Plans For Children, Families

    As Minnesota's governor, Democrat Tim Walz, now the presumed vice presidential nominee of his party, separated himself from most other governors by signing into law numerous tax increases funding progressive priorities such as a paid family leave plan and the nation's largest child tax credit.

  • August 13, 2024

    Treasury's Loss Rules Take Broad Approach To Min. Tax Deal

    The U.S. Treasury Department recently dashed the hopes of multinational corporations seeking regulations that would have carved out an international minimum tax agreement from interacting with long-standing domestic rules aimed at preventing companies from using the same economic loss twice.

  • August 13, 2024

    Partnerships' Easement Fight Ends As Gov't Drops IRS Notice

    An Alabama federal judge dismissed a complaint by dozens of partnerships claiming they shouldn't have to comply with an IRS notice regarding conservation easement transactions, following an Eleventh Circuit ruling upholding the notice as invalid and the government's agreement not to enforce it.

  • August 13, 2024

    IRS Delays Tax Deadlines In Vermont After Hurricane Debby

    Taxpayers in Vermont will be given until Feb. 3 to file individual and business tax returns and make payments after the state was hit by Hurricane Debby, the Internal Revenue Service said Tuesday.

  • August 13, 2024

    Tax Court Nixes Loss Deduction, But Owners Owe No Penalty

    The Internal Revenue Service was right to determine a business created to provide guidance to real estate owners and investors couldn't claim loss deductions because its business had not actually started, the Tax Court said Tuesday, but the owners are not liable for an accuracy-related penalty.

  • August 13, 2024

    IRS Wrongly Denied Tomato Cos. Deductions, 9th Circ. Told

    Two companies that supply 40% of the United States' tomato paste and diced tomatoes told the Ninth Circuit that the U.S. Tax Court erred in keeping the companies from deducting the costs of restoring their production facilities before the actual restoration occurs.

  • August 13, 2024

    Firm Asks Court To Reconsider $1.5M Freeze In Tax Dispute

    A Baltimore law firm that sued the IRS for freezing $1.5 million in its operating account to satisfy a client's tax debts told a Maryland federal court it was "dead wrong" in denying the firm's request to release the money without going to trial.

  • August 13, 2024

    Tax Court Design Violates US Law, Widow Tells 11th Circ.

    The widow of a grocery store butcher fighting a tax liability upheld by the U.S. Tax Court has told the Eleventh Circuit that the decision should be sent back for reconsideration, arguing that a provision restricting the president's power to remove Tax Court judges is unconstitutional.

  • August 13, 2024

    IRS Announces Sept. Meeting On Advisory Council Report

    The Internal Revenue Service's Advisory Council will hold a public meeting on Sept. 5 to discuss a future report from the council, the agency announced Tuesday.

  • August 12, 2024

    Accused Accounting Prof Is No Tax Expert, NJ Jury Told

    New Jersey federal jurors were urged Monday to keep one word at the front of their minds as they listen to the government present its case against an accounting professor accused of failing to report $3.3 million in income from a pharmacy he co-owned with his wife: willful.

  • August 12, 2024

    Tax Court Tosses Deficiency Challenge Over Validity

    The U.S. Tax Court cannot rule on a man's challenge to an Internal Revenue Service deficiency notice because the agency failed to show it correctly mailed the notice, rendering it invalid, and the case must be dismissed, the court said Monday. 

  • August 12, 2024

    UN Eyes Two Early Changes For Tax Pact In Latest Draft

    Diplomats would draft two legally binding protocols under the United Nations framework convention on international tax cooperation while creating the convention itself under the latest draft guidance for negotiators after they select from a shortlist of possible topics, including the digital economy and wealth taxation.

  • August 12, 2024

    IRS Lacks Broad Plan To Replace Old IT Systems, TIGTA Says

    The Internal Revenue Service lacks an agency-wide program to identify and then update, replace or retire legacy information technology systems, the Treasury Inspector General for Tax Administration reported Monday.

  • August 12, 2024

    Past Tax Ideas Offer Insight Into A Harris-Walz Presidency

    An analysis of tax proposals previously put forth by Vice President Kamala Harris and Minnesota Gov. Tim Walz, the Democrats' presumptive nominees for president and vice president, indicates they could pursue a tax agenda geared toward providing tax relief to middle- and lower-income Americans.

  • August 12, 2024

    FedEx Misreads Chevron Ruling In $85M Tax Dispute, US Says

    FedEx wrongly believes the recent U.S. Supreme Court decision overturning the Chevron doctrine precludes the U.S. Treasury Department from promulgating regulations to stop tax cheats and prevent FedEx from claiming $84.6 million in tax credits, the U.S. government told a Tennessee federal court.

  • August 12, 2024

    Judge OKs IRS To Review Bank Docs Of Exec In Bitcoin Probe

    The Internal Revenue Service can review the sequestered bank records of a cryptocurrency executive charged in a 2020 bitcoin fraud investigation, a Texas federal judge ruled, finding the agency had properly notified the executive and his company of summonses it had issued to their banks.

  • August 12, 2024

    Transparency Act Snowball Fears A 'Mirage,' Treasury Says

    The U.S. Department of the Treasury is seeking to quell fears that the Corporate Transparency Act's disclosure requirements could set the stage for more invasive government data collection in a brief asking a Michigan federal judge to uphold the law as constitutional.

  • August 12, 2024

    IRS Extends Tax Deadlines For Minn. Storm Victims

    Minnesota taxpayers affected by severe storms and flooding have until February to file tax returns and make payments, the Internal Revenue Service said Monday.

  • August 12, 2024

    2 Experts OK'd For Danish Tax Agency In $2.1B Fraud Case

    Two experts will be allowed to testify in support of a suit by Denmark's tax agency accusing U.S. pension plans of participating in a $2.1 billion tax refund fraud scheme, a New York federal district court said, overruling the pension plans' objections.

  • August 12, 2024

    'Survivor' Winner Is True Owner In Property Dispute, US Says

    The winner of the first "Survivor" television season is the true owner of disputed property that should be sold to pay down his $3.3 million in tax liabilities, the government told a Rhode Island federal court, rejecting claims that his sister is the owner.

  • August 10, 2024

    Kyocera Targets Treasury TCJA Reg, Seeking $7M Tax Refund

    The Treasury Department acted outside its bounds by issuing a regulation changing the effective date of the 2017 tax overhaul, electronics maker Kyocera argued as it urged a South Carolina federal court to void the regulation and approve the company's claim for $7 million tax refund.

  • August 09, 2024

    6th Circ. Partially Revives Crypto IRS Reporting Challenge

    The Sixth Circuit issued a mixed ruling Friday in a suit brought by a group of cryptocurrency users challenging the IRS' pending mandate to report large crypto transactions, reversing the dismissal of the suit's Fourth and First Amendment violation claims but affirming that some of the case's claims are not ripe.

  • August 09, 2024

    Partnership Clarity Expected In First Offshore Profits Rules

    Tax attorneys anticipate answers to several questions about how partnerships should properly track, report and attribute foreign income previously taxed in the U.S. when the first round of long-awaited proposed rules is published.

  • August 09, 2024

    3rd Circ. Kicks $1M Case To Tax Court Over IRS Violation

    The Third Circuit sent a man's protest of a lien seeking over $1 million in unpaid employee payroll taxes back to the U.S. Tax Court on Friday because the IRS violated an automatic stay on the proceedings triggered by a bankruptcy proceeding.

Expert Analysis

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    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.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    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.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    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.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    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.

  • Parsing Treasury's Proposed Clean Hydrogen Tax Credit Rules

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    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.

  • Employee Experience Strategy Can Boost Law Firm Success

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    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.

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.

  • Lessons From Country Singer's Personal Service Saga

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    Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.

  • 5 Litigation Funding Trends To Note In 2024

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    Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.

  • Tech CEO Tax Ruling A Warning For Forward Contracts

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    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.

  • 4 Legal Ethics Considerations For The New Year

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    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.

  • What The Law Firm Of The Future Will Look Like

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    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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