Federal

  • July 10, 2024

    IRS Says Related Biz Arms Must Each Apply For Fuel Credit

    Two related business departments that are both clean fuel producers and that have their own employer identification numbers must each apply on their own for the clean fuel production credit, the Internal Revenue Service said in an FAQ released Wednesday.

  • July 10, 2024

    Chevron's End Won't Affect Cubs Sale Tax Suit, 7th Circ. Told

    An anti-abuse rule the IRS is using to push for taxes on gains from Tribune Media Co.'s sale of the Chicago Cubs is not threatened by the U.S. Supreme Court ruling overturning the Chevron deference doctrine, an attorney for the IRS told the Seventh Circuit on Wednesday.

  • July 10, 2024

    IRS Issues Electricity Credit Reference Price For Wind

    The Internal Revenue Service released a 2024 reference price for determining the availability of the renewable electricity production credit for wind energy facilities in a notice issued Wednesday.

  • July 10, 2024

    House Dems Seek IRS Review Of Groups' Church Status

    A group of House Democratic lawmakers asked the Internal Revenue Service to review the tax exemptions of conservative advocacy groups that they contend have improperly received tax-exempt status as churches, according to a letter released Wednesday.

  • July 10, 2024

    5th Circ. Told 'Pay To Litigate' Rule Doesn't Bar Refund Suit

    A couple arguing the IRS failed to apply their tax overpayments to deficiencies claimed by the agency asked the Fifth Circuit to reverse a lower court's dismissal of their suit on the grounds that they hadn't paid their bill, saying the decision effectively asks them to pay twice.

  • July 09, 2024

    IRS Funding At Stake In 2025 Tax Cut Negotiations

    Lawmakers are girding for battle over the soon-to-expire individual tax cuts in the 2017 tax law, and IRS funding will be central to the debate at a time when the agency may be in need of additional resources due to changes in law.

  • July 09, 2024

    House Panel OKs Tax Breaks For More Education Expenses

    The House Ways and Means Committee sent several education-related tax bills to the full House of Representatives on Tuesday, including legislation that would make additional elementary and secondary school expenses eligible for tax-advantaged education savings accounts.

  • July 09, 2024

    Dems Request Special Counsel To Probe Justice Thomas Gifts

    Two Democratic senators have asked U.S. Attorney General Merrick Garland to appoint a special counsel to investigate whether U.S. Supreme Court Justice Clarence Thomas' failure to disclose various gifts received during his tenure on the high court amounts to chargeable ethics violations or tax crimes.

  • July 09, 2024

    IRS Errors Foul $51M Levy, Calif. Man's Estate Tells Tax Court

    The Internal Revenue Service made a slew of errors in determining a California man's estate faces a $46.2 million estate tax deficiency and a $4.6 million penalty, the estate's executor told the U.S. Tax Court.

  • July 09, 2024

    Veriwave Telco Faces FCC Action Over 'Tax Relief' Robocalls

    The Federal Communications Commission is moving to block robocalls about purported "tax relief" programs from a Delaware-based telecommunications company, announcing in an order Monday that Veriwave Telco had another 14 days to demonstrate compliance with the agency's rules or risk having downstream providers cut its traffic.

  • July 09, 2024

    Senate Tax Panel To Consider 3 Tax Court Nominees

    The Senate Finance Committee is scheduled to hold a hearing Wednesday to consider three U.S. Tax Court judge nominees, Sen. Ron Wyden, D-Ore., the panel's chairman, said in a statement Tuesday.

  • July 09, 2024

    5 Firms Steer $513M Ryan-Altus Cross-Border Tax Deal

    Dallas-based tax services and software provider Ryan said Tuesday it has inked a deal to acquire the property tax business of Altus Group Ltd. for CA$700 million ($513.4 million), enlisting three firms to assist on a deal that will expand its footprint in Canada, the U.S. and the U.K.

  • July 09, 2024

    Medical Office Manager Gets 5 Years For Tax, Mail Fraud

    The former office manager of an Illinois medical practice was sentenced to five years in federal prison and ordered to pay $3 million in restitution — most of it to his former employer — after admitting to filing a false tax return and stealing from the practice.

  • July 09, 2024

    Companies Deliberate Pillar 2 Prep After OECD Signals Relief

    Multinational corporations facing the Pillar Two global minimum tax in various jurisdictions are weighing comments from OECD officials that hint at more relief as they decide whether to prepare to comply with the rules now or gamble on the prospects of permanent safe harbors.

  • July 08, 2024

    IRS Details Steps To Take For Scam-Credit Letter Recipients

    The Internal Revenue Service published a fact sheet Monday to help taxpayers respond to letters from the agency identifying tax returns as requiring authentication after the agency said that inaccurate advice from social media and a series of scams led to an increase in questionable refund claims.

  • July 08, 2024

    Continued Worker Credit Freeze Could Push Cos. To Court

    More employers tired of waiting for the Internal Revenue Service to process their employee retention credit refund claims could decide to go to court to force the government to review their submissions following the IRS announcing that a moratorium on processing new claims would remain in place.

  • July 08, 2024

    Ways And Means To Vote On Section 529 Tax Bills

    The House Ways and Means Committee is scheduled to vote Tuesday on several education-related tax bills, including legislation that would make additional elementary and secondary school expenses eligible for tax-advantaged education savings accounts.

  • July 08, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin reported recently issued guidance on exceptions to the 10% additional tax for people who make permissible early retirement account withdrawals for emergency personal expenses and for victims of domestic abuse.

  • July 08, 2024

    IRS Failed To Analyze Storage Costs, TIGTA Says

    The IRS didn't negotiate with the federal agency that stores its paper tax records, instead agreeing to pay a new monthly rate of $2.8 million without doing the required cost analysis, the Treasury Inspector General for Tax Administration said in a report released Monday.

  • July 08, 2024

    Top International Tax Cases Of 2024: Midyear Report

    With a U.S. Supreme Court decision affirming a key 2017 tax provision on repatriation, millions of dollars in FBAR penalties upheld and a French ruling confirming the U.S. government's access to foreign bank accounts, the IRS stacked up important court victories on international enforcement in the first half of 2024. Here, Law360 reviews those and other significant rulings from the past six months.

  • July 08, 2024

    Atty Drops FOIA Suit Against IRS Over Partnership Audits

    An Ohio attorney agreed to drop a public records suit against the Internal Revenue Service that had sought documents related to partnership audits after the agency released thousands of records he had requested, according to a D.C. federal court filing.

  • July 08, 2024

    IRS Must Produce Audit Records, Waste Co. Says

    Garbage-hauling giant Waste Management Inc. asked a D.C. federal court to force the IRS to produce its tax files on the company for 2017, including audit records, saying the agency has been dragging its feet in violation of the Freedom of Information Act.

  • July 08, 2024

    Feds Seize $63M LA Estate Tied To Armenian Bribe Probe

    The U.S. Department of Justice said Monday that it will seize a $63 million Los Angeles estate that it claims was bought with bribe payments for the family of a former Armenian government official.

  • July 05, 2024

    How Reshaped Circuit Courts Are Faring At The High Court

    Seminal rulings from the U.S. Supreme Court's latest term will reshape many facets of American society in the coming years. Already, however, the rulings offer glimpses of how the justices view specific circuit courts, which have themselves been reshaped by an abundance of new judges.

  • July 05, 2024

    Breaking Down The Vote: The High Court Term In Review

    The U.S. Supreme Court's lethargic pace of decision-making this term left the justices to issue a slew of highly anticipated and controversial rulings during the term's final week — rulings that put the court's ideological divisions on vivid display. Here, Law360 takes a data dive into the numbers behind this court term.

Expert Analysis

  • After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1

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    The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.

  • Recruitment Trends In Emerging Law Firm Frontiers

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    BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.

  • What DOL Fiduciary Rule Means For Private Fund Managers

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    Attorneys at Ropes & Gray discuss how the U.S. Department of Labor's recently released final fiduciary rule, which revises the agency's 1975 regulation, could potentially cause private fund managers' current marketing practices and communications to be considered fiduciary advice, and therefore subject them to strict prohibitions.

  • Money, Money, Money: Limiting White Collar Wealth Evidence

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    As courts increasingly recognize that allowing unfettered evidence of wealth could prejudice a jury against a defendant, white collar defense counsel should consider several avenues for excluding visual evidence of a lavish lifestyle at trial, says Jonathan Porter at Husch Blackwell.

  • How Associates Can Build A Professional Image

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    As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.

  • Navigating New Safe Harbor For Domestic Content Tax Credits

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    The U.S. Department of the Treasury’s recent notice simplifying domestic content calculations for certain solar, onshore wind and battery storage projects, which directly acknowledges the difficulty for taxpayers in gathering data to support a domestic content analysis, should make it easier to qualify additional domestic content bonus tax credits, say attorneys at A&O Shearman.

  • Firms Must Rethink How They Train New Lawyers In AI Age

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    As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.

  • 'Energy Communities' Update May Clarify Tax Credit Eligibility

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    A recent IRS notice that includes updated lists of locations where clean energy projects can qualify for additional tax credits — based 2023 unemployment data and placed-in-service dates — should help provide clarity regarding project eligibility that sponsors and developers need, say attorneys at Troutman Pepper.

  • Think Like A Lawyer: Always Be Closing

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    When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.

  • How Cannabis Rescheduling May Alter Paraphernalia Imports

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    The Biden administration's recent proposal to loosen federal restrictions on marijuana use raises questions about how U.S. Customs and Border Protection enforcement policies may shift when it comes to enforcing a separate federal ban on marijuana accessory imports, says R. Kevin Williams at Clark Hill.

  • NCAA Settlement May End The NIL Model As We Know It

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    The recent House v. NCAA settlement in California federal court, in which the NCAA agreed to allow schools to directly pay March Madness television revenue to their athletes, may send outside name, image and likeness collectives in-house, says Mike Ingersoll at Womble Bond.

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