Federal

  • June 07, 2024

    Fed. Circ. Panel Doubts Bid To Nix Actavis' $12M Deduction

    A Federal Circuit panel seemed skeptical of the government's bid to overturn a decision allowing drugmaker Actavis to deduct $12 million it spent fending off lawsuits as it secured approval to sell generics, raising the question during oral arguments Friday whether the company was being uniquely targeted.

  • June 07, 2024

    Taxation With Representation: Vinson, Latham, Ropes & Gray

    In this Week's Taxation with Representation, Waste Management buys Stericycle, Becton Dickinson pays $4.2 billion for Edwards Lifesciences' critical care products unit, Aquiline Capital Partners raises over $3.4 billion in fund capital, and Bain Capital buys PowerSchool Holdings.

  • June 07, 2024

    IRS Lists Shuttered Coal Areas For Energy Bonus Credits

    The Internal Revenue Service on Friday issued updated lists of areas, including closed coal mines and factories, where developers can qualify for additional tax credits for building their clean energy projects.

  • June 07, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, which included proposed foreign trust transaction reporting requirements.

  • June 06, 2024

    Medtronic Urges 8th Circ. To Back Its Transfer Pricing Method

    Medical device maker Medtronic reiterated Thursday its bid for the Eighth Circuit to revive its method for pricing intangible property that was licensed to a Puerto Rican affiliate, arguing the government's concessions show why the company's approach is more reliable.

  • June 06, 2024

    9th Circ. Denies Trust Refund Of Money Forfeited To IRS

    A trust lost its ownership claims to property when an Idaho federal court determined the property had been transferred to the trust fraudulently, the Ninth Circuit said Thursday, affirming a decision to deny a $225,000 tax refund.

  • June 06, 2024

    Estate Entitled To Deduct Payouts To Stepkids, 11th Circ. Told

    The U.S. Tax Court wrongly denied deductions to a former attorney's $81 million estate for million-dollar payouts it made to his stepchildren after they sued, the estate told the Eleventh Circuit, saying the payments satisfied legitimate claims against the estate and were therefore deductible.

  • June 06, 2024

    Tax Court Upholds Rejection Of Man's Biz Deductions

    A Floridian failed to adequately back up certain business loss deduction claims made on his tax return, the U.S. Tax Court said Thursday, backing the IRS' rejection of the claims and imposition of an accuracy-related penalty.

  • June 06, 2024

    'Brothel' Manager Violated Bail After $5.7M Sting, Feds Say

    A manager and bookkeeper facing federal charges connected to a COVID-19 grant and tax fraud scheme at a Connecticut strip club violated his bail conditions by showing up at the facility and "hanging out" with a potential witness, federal probation authorities have alleged.

  • June 06, 2024

    9th Circ. Won't Revive Org's Push To Restore Nonprofit Status

    The U.S. Tax Court's dismissal of an attempt to reinstate nonprofit status for a California organization that said its officers fell victim to a Ponzi scheme did not breach the group's constitutional rights, the Ninth Circuit said.

  • June 06, 2024

    Ex-IRS Worker Indicted In $2M Exxon Credit Theft Scheme

    A former Internal Revenue Service employee used his account management job at the agency to steal more than $2 million worth of tax credits from Exxon Mobil and pocket the money, according to a Utah federal grand jury indictment.

  • June 06, 2024

    Fox Rothschild Brings On Tax Pro From Atlanta Boutique

    Fox Rothschild LLP has added an attorney in Atlanta from tax law boutique Wiggam Law to strengthen the firm's taxation and wealth planning department.

  • June 06, 2024

    IRS Needs Strategy For 2.6M Tax Doc Backlog, TIGTA Says

    Not only does the Internal Revenue Service have a document backlog exceeding 2.6 million source documents that need to be associated with a specific form, but it also has been making significant mistakes in reporting closures, the Treasury Inspector General for Tax Administration said in a report released Thursday.

  • June 06, 2024

    Justices Affirm Taxing Of Estate On Insurance Payout

    The U.S. Supreme Court affirmed on Thursday a decision denying a tax refund to the estate of an owner of a building materials company that used a payout from his $3.5 million life insurance policy to purchase his shares in the business.

  • June 05, 2024

    CohnReznick Scores Quick Exit In Tax Scheme Suit

    A New York federal judge agreed to toss a housing partnership's suit accusing accounting firm CohnReznick LLP of professional negligence and fraud, finding that the district court doesn't have jurisdiction over the dispute.

  • June 05, 2024

    IRS Must Better Log AI Use In Tax Gap Estimates, GAO Says

    The Internal Revenue Service needs to complete documentation on its use of artificial intelligence models as part of a plan to improve its tax gap estimates, the Government Accountability Office said Wednesday.

  • June 05, 2024

    Californian Failed To Report Missing Income, Tax Court Says

    A California woman's contention that she should not be accountable for a deficiency in her 2021 tax filing due to what she said was an error by her accountant doesn't stand up under scrutiny, the U.S. Tax Court said Wednesday.

  • June 05, 2024

    Some Payments After Train Derailed Aren't Taxable, IRS Says

    Certain payments from Norfolk Southern Corp. to victims of its freight train derailment and toxic chemical spill in East Palestine, Ohio, are considered disaster relief payments and are therefore not taxable, the Internal Revenue Service said Wednesday.

  • June 05, 2024

    House Panel Tees Up $2B In IRS Cuts For Full Committee Vote

    A House Appropriations subcommittee approved legislation Wednesday that would reduce Internal Revenue Service funding for fiscal 2025 by over $2 billion and prohibit money from going to the agency's free online tax-filing program without congressional approval.

  • June 05, 2024

    Win May Embolden IRS Use Of Economic Substance Doctrine

    The IRS' successful wielding of the economic substance doctrine to characterize multinational telecommunications corporation Liberty Global's sophisticated set of intercompany deals as an abusive tax shelter could encourage the agency to apply similar analysis to even the most basic tax transactions.

  • June 05, 2024

    IRS Presses Justices To Weigh In On Tax Challenge Deadline

    The IRS urged the U.S. Supreme Court to overturn a Third Circuit decision finding the U.S. Tax Court's 90-day deadline for challenging tax bills is not set in stone, arguing the couple defending the ruling are wrongly relying on a 2022 high court decision.

  • June 05, 2024

    Billionaire's 'Naive' Stock-Trading Pilot Asks For No Prison

    A private pilot for U.K. billionaire Joe Lewis is asking for no prison time after pleading guilty to insider trading on stock tips provided by his boss, arguing that he has otherwise lived a law-abiding life and is less culpable than many white-collar defendants who've come through the Manhattan federal court.

  • June 05, 2024

    Taxpayer Advocacy Committee Meeting Moved Up

    The Internal Revenue Service moved up an open meeting of the Taxpayer Advocacy Panel's Notices and Correspondence Project Committee to June 18, it said Wednesday.

  • June 04, 2024

    Full DC Circ. Asked To Weigh Foreign Info Disclosure Penalties

    A D.C. Circuit panel made questionable assumptions about congressional intent when it revived the IRS' authority to assess and administratively collect penalties related to undisclosed foreign corporations, a businessman said Tuesday in asking the full appellate court to hear his case.

  • June 04, 2024

    Sen. Leaders Press Biden's Tax Court Nominees On Fairness

    Senate Finance Committee leaders pressed President Joe Biden's three new judicial nominees for the U.S. Tax Court to explain Tuesday how they would extend fair treatment to taxpayers if they are confirmed.

Expert Analysis

  • 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.

  • Think Like A Lawyer: Forget Everything You Know About IRAC

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    The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.

  • The Corporate Transparency Act Isn't Dead Yet

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    After an Alabama federal court's ruling last week rendering the Corporate Transparency Act unconstitutional, changes to the law may ultimately be required, but ongoing compliance is still the best course of action for most, says George Singer at Holland & Hart.

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.

  • Employers, Prep For Shorter Stock Awards Settlement Cycle

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    Companies that provide equity compensation in the form of publicly traded stock will soon have one less day to complete such transactions under U.S. Securities and Exchange Commission and Nasdaq rules — so employers should implement expedited equity compensation stock settlement and payroll tax deposit procedures now, say attorneys at Morgan Lewis.

  • Demystifying IRS' Claims Of $851B Return On Investment

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    The IRS' recently released analysis, estimating a $851 billion return on the government’s $80 billion investment in the agency, represents a huge increase over its 2022 estimate and that of the Congressional Budget Office and may be best viewed as a best-case scenario, says Joyce Beebe at the Baker Institute.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

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