Federal

  • May 21, 2024

    Valero Brings $37M Refund Claim Over Fuel Credit, Crude Tax

    Energy company Valero is seeking $37 million in tax refunds for biomass fuel mixtures it said should've qualified for the alternative fuel tax credit and for claimed overpayments of crude tax, according to a complaint in Texas federal court.

  • May 21, 2024

    IRS Audit Selection Process May Introduce Bias, GAO Says

    The Internal Revenue Service's process for auditing returns claiming refundable tax credits uses a measurement that may introduce unintentional bias against Black and low-income people into its automated selection system, according to a Government Accountability Office report made public Tuesday.

  • May 21, 2024

    Strategic Hiring Was The New Normal For BigLaw In 2023

    The 400 largest law firms by headcount in the U.S. grew more slowly in 2023 than in the previous two years, while Kirkland & Ellis LLP surpassed the 3,000-attorney threshold, according to the latest Law360 ranking.

  • May 21, 2024

    The Law360 400: Tracking The Largest US Law Firms

    The legal market expanded more tentatively in 2023 than in previous years amid a slowdown in demand for legal services, especially in transactions, an area that has been sluggish but is expected to quicken in the latter half of the coming year.

  • May 20, 2024

    Ex-IRS Agent, Five Others Sentenced In COVID Fraud Scheme

    A former Internal Revenue Service agent, his brother and four other defendants have pled guilty to participating in a scheme that netted more than $3 million in fraudulent COVID-19 pandemic relief loans.

  • May 20, 2024

    Opportunity Zones Helped Restore Pa. City, House Panel Told

    The Tax Cuts and Jobs Act's provisions, especially the law's opportunity zones aimed at boosting economic investment in distressed communities, have been integral in the economic restoration of Erie, Pennsylvania, panelists told the House Ways and Means Committee's tax policy subcommittee Monday.

  • May 20, 2024

    Lawmakers Ask IRS For Broader, Permanent Free E-File Plan

    More than 135 Democratic and Independent members of Congress urged Internal Revenue Commissioner Daniel Werfel and Treasury Secretary Janet Yellen in a letter to expand the IRS' pilot program for free electronic tax return filing and make it permanent.

  • May 20, 2024

    2 House GOP Chairs Seek Study Of Premium Tax Credit Plan

    The Republican chairmen of the House Ways and Means and Budget committees want the Congressional Budget Office and Joint Committee on Taxation to study the impact of making the expanded Affordable Care Act premium tax credits permanent.

  • May 20, 2024

    IRS Guidance Plan Should Cover Corp. AMT, AICPA Says

    The Internal Revenue Service should provide guidance on the definitions and applications of the 15% corporate alternative minimum tax, among other topics, the American Institute of Certified Public Accountants said in comments published by the agency Monday.

  • May 20, 2024

    Domino's Franchisee Gets Year In Prison In $2.5M Tax Case

    The owner of dozens of Domino's Pizza restaurants was sentenced to a year in prison Monday and ordered to pay $2.5 million to the Internal Revenue Service after having admitted he filed false tax returns, the U.S. Department of Justice said.

  • May 20, 2024

    Baker McKenzie Ends FOIA Suit Over IRS Partnership Audits

    A Baker McKenzie attorney has dropped a public records lawsuit against the Internal Revenue Service that sought to compel the agency to turn over documents pertaining to its scrutiny of large partnerships.

  • May 20, 2024

    Feds Fight Proposed Delay In Hunter Biden's Tax Trial

    Hunter Biden shouldn't be allowed to delay his criminal tax trial in California just because his lead attorney says the dates run up against Biden's upcoming trial in Delaware on firearms charges, the special counsel's office told a federal court.

  • May 20, 2024

    House Dem Bill Would Let Education Savings Cover Transport

    Students would be able to use tax-advantaged educational savings accounts to cover transportation and parking costs under a bill introduced by a pair of Democrats in the House of Representatives.

  • May 20, 2024

    US, Argentina To Carry Out 1st FATCA Info Exchange

    The Internal Revenue Service approved cybersecurity measures by Argentina in a step that clears the way for the first automatic information exchange under the Foreign Account Tax Compliance Act between the two countries in September, Argentina's revenue service said Monday.

  • May 17, 2024

    Med Device Co. Allowed $160M In Deductions, Tax Court Told

    A tax code provision in place before the 2017 federal tax overhaul changed it allows a medical device manufacturer to claim more than $160 million in deductions for dividends despite the government's attempt to apply the law retroactively, company counsel told the U.S. Tax Court on Friday.

  • May 17, 2024

    Home Distillers Tell Feds Ban Fails Under Spirit Of The Law

    The Hobby Distillers Association said the federal government is exceeding its constitutional powers and treading on states' rights by banning homemade liquor under its taxing authority, as the group laid out its position Friday at the request of a Texas federal judge.

  • May 17, 2024

    Michigan Doctor Seeks Release From Contempt In FBAR Fight

    A Michigan doctor incarcerated for civil contempt in a case in which he was ordered to repay more than $1 million in penalties for failure to report foreign accounts should be freed because he can no longer satisfy the terms of his release, he told a Michigan federal court.

  • May 17, 2024

    Koch-Tied Group Says Transparency Law Offends Federalism

    The Corporate Transparency Act is unconstitutional because it does not regulate interstate commerce yet mandates that state-registered entities disclose personal information, a conservative group affiliated with the billionaire Koch brothers told the Eleventh Circuit on Friday.

  • May 17, 2024

    Feds Want Prison For Kiosk Salesman Who Faked Deductions

    An electronic-sweepstakes kiosk salesman from Chicago should spend more than two years in prison for submitting false tax returns that fabricated more than $400,000 in business expenses and more than $60,000 in church donations, federal prosecutors told an Illinois federal court.

  • May 17, 2024

    Funding Uncertainty Hasn't Affected Plans, IRS Official Says

    Political uncertainty about the Internal Revenue Service's future funding hasn't affected the agency's operations planning, the agency's deputy commissioner said Friday at a Tax Council Policy Institute conference in Washington, D.C.

  • May 17, 2024

    Transfer Pricing Deal Needed For Pillar 1, OECD Official Says

    It's crucial for countries to agree on transfer pricing policies under an international profit reallocation agreement known as Pillar One as they work toward their end-of-June deadline to sign a related multilateral treaty, an OECD official said Friday.

  • May 17, 2024

    Judge Sets Hearing For Delay In Hunter Biden's Tax Trial

    A California federal judge agreed Friday to consider Hunter Biden's request to push back his $1.4 million criminal tax trial, setting a hearing to address his claim that the dates interfere with his Delaware gun trial and threaten to prevent him from getting a fair shake.

  • May 17, 2024

    Taxation With Representation: Wachtell Lipton, Freshfields

    In this week's Taxation with Representation, Nippon Life acquires Corebridge Financial, Crescent Energy buys SilverBow Resources and Uber purchases Foodpanda.

  • May 17, 2024

    Virgin Islands Silent 2 Years On $1.1M Tax Refund, Court Told

    A man living on the island of St. Thomas claims he requested a tax refund of more than $1.1 million from the U.S. Virgin Islands Bureau of Internal Revenue more than two years ago and still hasn't heard back, according to a complaint in federal court.

  • May 16, 2024

    Pillar 1 Faces Hard June Deadline, Ex-Treasury Official Says

    An international agreement to reallocate certain corporate profits, known as Pillar One, will likely stall if countries miss their deadline to sign a multilateral treaty by the end of June, a former U.S. Treasury official said Thursday.

Featured Stories

  • New Domestic Content Guidance May Boost Energy Credits

    Kat Lucero

    The U.S. Treasury Department's new guidance on bonus tax credits for clean energy projects that source domestic-made materials and components aims to simplify the process for determining eligibility and spur more development to get those extra incentives.

  • No Relief For Struggling SPACs Under Buyback Tax Proposal

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    Special-purpose acquisition companies won't get sought-after relief from a new 1% tax on stock buybacks under a recent Treasury Department proposal that otherwise provides helpful clarity on the tax's implications for the subdued SPAC market, lawyers say.

  • 3 Key Takeaways From Floated Foreign Trust Reporting Rules

    Natalie Olivo

    Proposed rules for reporting transactions with foreign trusts recently issued by the U.S. Treasury Department provide breathing room on disclosure requirements for certain offshore retirement accounts, but leave open some questions about classification. Here, Law360 breaks down three sections of the proposed foreign trust reporting regulations.

Expert Analysis

  • Geothermal Energy Has Growing Potential In The US

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    Bipartisan support for the geothermal industry shows that geothermal energy can be an elegant solution toward global decarbonization efforts because of its small footprint, low supply chain risk, and potential to draw on the skills of existing highly specialized oil and gas workers and renewable specialists, say attorneys at Weil.

  • Exploring An Alternative Model Of Litigation Finance

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    A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.

  • Trump Hush Money Case Offers Master Class In Trial Strategy

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    The New York criminal hush money trial of former President Donald Trump typifies some of the greatest challenges that lawyers face in crafting persuasive presentations, providing lessons on how to handle bad facts, craft a simple story that withstands attack, and cross-examine with that story in mind, says Luke Andrews at Poole Huffman.

  • A Vision For Economic Clerkships In The Legal System

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    As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.

  • State-Regulated Cannabis Can Thrive Without Section 280E

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    Marijauna's reclassification as a Schedule III-controlled substance comes at a critical juncture, as removing marijuana from being subjected to Section 280E of the Internal Revenue Code is the only path forward for the state-regulated cannabis industry to survive and thrive, say Andrew Kline at Perkins Coie and Sammy Markland at FTI Consulting.

  • Asset Manager Exemption Shifts May Prove Too Burdensome

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    The U.S. Department of Labor’s recent change to a prohibited transaction exemption used by retirement plan asset managers introduces a host of new costs, burdens and risks to investment firms, from registration requirements to new transition periods, say attorneys at Simpson Thacher.

  • A Look At New IRS Rules For Domestically Controlled REITs

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    The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.

  • E-Discovery Quarterly: Recent Rulings On Text Message Data

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    Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.

  • Should NIL Collectives Be Allowed Tax-Favored Status?

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    Arguments are being made for and against allowing organizations to provide charitable contribution tax deductions for donations used to compensate student-athletes, a practice with impacts on competition for student-athletes and overall tax fairness, but ultimately it is a question for Congress, say Andres Castillo and Barry Gogel at the University of Maryland School of Law.

  • Understanding The IRC's Excessive Refund Claim Penalty

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    Taxpayers considering protective refund claims pending resolution of major questions in tax cases like Moore v. U.S., which is pending before the U.S. Supreme Court, should understand how doing so may also leave them vulnerable to an excessive refund claim penalty under Internal Revenue Code Section 6676, say attorneys at McDermott.

  • Don't Use The Same Template For Every Client Alert

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    As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

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    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

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    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.