Federal
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September 25, 2024
IRS Must Improve Seizure Procedure Compliance, TIGTA Says
While a review of over 70 cases in which Internal Revenue Service field officers conducted seizures found the employees largely adhered to standard procedures, three cases where they did not highlight areas where the agency could improve its compliance, the Treasury Inspector General for Tax Administration said Wednesday.
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September 25, 2024
Julie Chrisley Gets No Slack In Resentencing From Ga. Judge
Julie Chrisley, the former real estate mogul and reality TV star who was convicted of running a yearslong bank fraud scheme with her husband, Todd, was resentenced Wednesday by a Georgia federal judge to the same seven-year prison term she first received nearly two years ago.
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September 25, 2024
Expect More R&D Guidance Before Regs, IRS Atty Says
The Internal Revenue Service plans to release more guidance governing the tax treatment of research and development expenses before it formally issues proposed regulations that implement the 2017 federal tax law's changes to the incentive, an agency attorney said Wednesday.
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September 25, 2024
House Bill Proposes Tax Incentive For Efficient Vehicles
Buyers of new vehicles with higher-than-average energy performance would be entitled to a tax credit of up to $5,000 under a bill introduced in the U.S. House of Representatives.
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September 25, 2024
Direct File Needs Security, Testing Improvements, TIGTA Says
While the deployment of the Internal Revenue Service's pilot of its free online Direct File program was largely successful, the agency must address some security lapses and testing deficiencies, the Treasury Inspector General for Tax Administration said Wednesday.
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September 25, 2024
Basis-Shifting Regs May Add Accounting Fixes, IRS Atty Says
The Internal Revenue Service may include in upcoming proposed regulations a solution for partnership basis-shifting for taxpayers that want to adjust accounting methods so prior transactions can be compliant with economic substance laws, an agency attorney said Wednesday.
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September 25, 2024
Wyden Calls On 2025 Tax Bill To Include Partnership Reform
Lawmakers should consider next year how to revise partnership tax laws to better collect on large businesses' income without harming smaller entities as Congress debates over how to address expiring tax provisions, Senate Finance Committee Chairman Ron Wyden said Wednesday.
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September 25, 2024
House Bill Proposes Housing Incentive For Disabled Veterans
A bill introduced in the U.S. House of Representatives would exclude veteran disability benefits from the income calculation for the low-income housing tax credit.
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September 25, 2024
Chicago School Contractor Loses Energy Efficiency Tax Break
The owner of a Chicago-based electrical contracting company isn't entitled to an over $459,000 tax refund for upgrading Chicago Public Schools buildings with energy-efficient lighting because his company didn't design the systems, only installed them, an Illinois federal judge ruled.
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September 25, 2024
Puerto Rico Seeking Input On Implementing Global Min. Tax
Puerto Rico's Department of the Treasury is looking for public comments regarding possible implementation of the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities.
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September 24, 2024
1st Circ. Affirms Tossing Of IRS Crypto Doc Seizure Case
A New Hampshire federal court correctly dismissed a bitcoin investor's claim that the IRS violated his privacy and property rights when it seized his records from the cryptocurrency exchange Coinbase, the First Circuit ruled Tuesday, agreeing that he lacked a reasonable expectation that his account information would be kept private.
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September 24, 2024
Estate's Value Shouldn't Be Increased, Tax Court Says
The estate of a Maryland doctor who died in a car accident does not have to increase its taxable value by more than $19 million to account for the proceeds of two life insurance policies held by a family trust, the U.S. Tax Court ruled Tuesday.
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September 24, 2024
Halliburton Tardy In Contesting $35M Deduction, US Says
A Halliburton Co. lawsuit claiming a deduction for a $35 million payoff to a foreign country must be dismissed because the company waited too long to start its action, the U.S. told a Texas federal court.
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September 24, 2024
IRS Received $226K In Prohibited Levy Payments In 2023
The Internal Revenue Service collected more than $226,000 in levy payments in the 2023 fiscal year in collection due process cases that involved prohibited levies, but affected taxpayers were made whole, according to a watchdog report released Tuesday.
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September 24, 2024
IRS Largely Complies With Levy Requirements, TIGTA Says
A review of more than 48,000 levies issued by IRS field collection officers from July 2022 through June 2023 found that they were mostly compliant with both legal and administrative requirements, but the Treasury Inspector General for Tax Administration identified over 1,900 instances of noncompliance, it said Tuesday.
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September 24, 2024
Digital Asset Rules Coming By Year's End, Treasury Atty Says
The U.S. Treasury Department and the Internal Revenue Service intend to release rules "later this year" on additional reporting requirements for brokers of digital assets such as cryptocurrency and nonfungible tokens, a senior Treasury attorney said Tuesday.
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September 24, 2024
Wyden, House Dem Float Small-Biz Wage, Investment Credits
Senate Finance Committee Chairman Ron Wyden and a House Democratic tax writer proposed legislation that would provide small-business wage and investment tax credits, according to a Tuesday statement.
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September 24, 2024
Abbott Seeks $24M Refund Over Transfer Pricing Adjustments
Healthcare products giant Abbott Laboratories is owed $24.3 million for overpaid taxes after the IRS incorrectly adjusted its intragroup income and payments this year, the company told the U.S. Tax Court in a petition.
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September 24, 2024
Defunct Cannabis Co. Says It's Owed $1.4M In Worker Credits
A Seattle cannabis company that was administratively dissolved this year is entitled to roughly $1.4 million in tax credits for continuing to pay employees when its business dropped off during the COVID-19 pandemic, the company's receivership estate told a Washington federal court.
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September 24, 2024
IRS Wary Of Adding Complexity In Min. Tax Regs, Official Says
The IRS opted to use existing tax rules in proposed guidance to address risks that the U.S. corporate alternative minimum tax could count offshore income twice, an agency official said Tuesday, noting a more precise method would increase complexity.
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September 24, 2024
Treasury To Allow 3 AMT Transition Methods, Official Says
Final rules on the new corporate alternative minimum tax are expected to adopt the proposed regulations' three ways for companies to transition to the regime, and the U.S. Treasury Department is open to other ways as well, a department official said Tuesday.
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September 24, 2024
Insurer Wants Quick Appeal At 8th Circ. In DOL Tax Fight
A health insurer will seek the Eighth Circuit's review after a federal judge refused to toss a suit from the U.S. Department of Labor claiming the company unlawfully took at least $66.8 million in Minnesota state tax liability from plans it administered to pay in-network providers.
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September 24, 2024
Exxon Claims It Beat Weak Defense In $1.8B Tax Trial
Exxon Mobil urged a Texas federal judge to find that it defeated what it called a scattered defense by the U.S. government during a five-day bench trial in April when the company argued for a $1.8 billion tax refund on its natural gas deal with Qatar, according to newly released filings.
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September 24, 2024
Applications For Low-Income Energy Tax Breaks Due In Oct.
With more than 50,000 applications for the low-income communities clean energy bonus credit program submitted, three U.S. government agencies announced Tuesday that they will be accepting applications on a rolling basis for most categories through Oct. 10 to make sure they are timely processed.
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September 24, 2024
Tax Data Consent Practices Need Shoring Up, TIGTA Says
The Internal Revenue Service must take steps to make sure any tax software companies that collect taxpayer information include consent statements that are clear about the intended purpose of the disclosure of that information and the specific recipients of it, the Treasury Inspector General for Tax Administration said.
Expert Analysis
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After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1
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.
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Recruitment Trends In Emerging Law Firm Frontiers
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.
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What DOL Fiduciary Rule Means For Private Fund Managers
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.
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Money, Money, Money: Limiting White Collar Wealth Evidence
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.
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How Associates Can Build A Professional Image
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.
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Navigating New Safe Harbor For Domestic Content Tax Credits
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.
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Firms Must Rethink How They Train New Lawyers In AI Age
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.
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'Energy Communities' Update May Clarify Tax Credit Eligibility
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.
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Think Like A Lawyer: Always Be Closing
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.
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
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.
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Lean Into The 'Great Restoration' To Retain Legal Talent
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.
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How Cannabis Rescheduling May Alter Paraphernalia Imports
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.
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NCAA Settlement May End The NIL Model As We Know It
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.