Federal

  • October 08, 2024

    Homeowners Again Seek Class Cert. In Tax Foreclosure Suit

    A group of former property owners has asked a Michigan federal judge to recertify a class action seeking to recover profits county treasurers made selling their tax-delinquent properties, saying the addition of class representatives fixes the flaw that dismantled the class. 

  • October 08, 2024

    Tax Court Cuts $16.7M Deduction For Conservation Donation

    A partnership that claimed a $16.7 million tax deduction for donating a conservation easement covering land in Georgia was trying to "fleece the public" with its claims that the land could be used for clay mining, a U.S. Tax Court judge said Tuesday in a decision slashing the deduction.

  • October 08, 2024

    IRS Seeks Feedback On Digital Asset Reporting Form

    The Internal Revenue Service is seeking comments by Nov. 6 on a draft of a 2025 form for digital asset transaction reporting, according to a notice.

  • October 08, 2024

    Tire Seller Counts As Importer, Owes $2M Tax, 5th Circ. Says

    A Houston truck sales company owes nearly $2 million in excise taxes because it qualifies as the importer of tires that it bought from a Chinese manufacturer, the Fifth Circuit ruled Tuesday in overturning the decision of a Texas federal judge.

  • October 08, 2024

    Tax Court Denies Ariz. Woman Spousal Relief

    The U.S. Tax Court denied an Arizona woman's request for relief from liability for a faulty return filed by her husband, saying on Tuesday that she failed to show she was a victim of abuse and incapable of challenging the filing.

  • October 08, 2024

    Loss Rule Carveouts Raise Challenges In Pillar 2, Official Says

    An IRS official flagged administrability concerns Tuesday with potential safe harbors that would, in some cases, carve out an international minimum tax agreement from interacting with long-standing domestic rules aimed at preventing companies from using the same economic loss twice.

  • October 08, 2024

    Calif. Tax Preparer Gets 6 Years For $28M Scheme

    The owner of a California tax preparation business who helped customers create sham companies was sentenced to six years in prison for a decadelong scheme that caused a tax loss of at least $28 million, according to the U.S. Department of Justice.

  • October 08, 2024

    Settlement Payments Not Deductible Alimony, 11th Circ. Told

    A divorced man who was ordered by a judge to make $3 million in payments on a past-due settlement to his ex-wife should not be allowed to shield them from tax, the U.S. government told the Eleventh Circuit, saying the payments don't qualify as alimony.

  • October 08, 2024

    7 Taxpayer Advocacy Panel Committees To Meet In November

    Seven Taxpayer Advocacy Panel committees will meet in November to discuss possible improvements to customer services, the Internal Revenue Service said Tuesday.

  • October 07, 2024

    Justices Won't Hear Man's FBAR Constitutionality Challenge

    The U.S. Supreme Court let stand Monday a Seventh Circuit decision dismissing a man's challenge to the constitutionality of the Bank Secrecy Act's requirement to report his foreign bank accounts, effectively ending the man's claim that the filings were an invasion of privacy.

  • October 07, 2024

    Jury Finds Professor Hid Foreign Bank Accounts

    An 86-year-old former college professor faces more than $500,000 plus interest in penalties after a jury found that he had deliberately failed to report his foreign bank accounts in Switzerland and Turkey, according to documents filed in a California federal court.

  • October 07, 2024

    Treasury Proposes Exempting Tribal Cos. From Income Tax

    Tribal-owned businesses would not be subject to federal income tax under proposed regulations released Monday by the U.S. Department of the Treasury, a move that would also allow such entities to be eligible to receive direct cash payments in lieu of clean energy tax credits.

  • October 07, 2024

    Henderson Franklin Adds Tax Pro To Florida Offices

    A tax attorney who formerly practiced at Stradling Yocca Carlson & Rauth PC has joined Henderson Franklin Starnes & Holt PA's business and tax planning department and will work from the firm's Florida offices in Fort Myers and Naples.

  • October 07, 2024

    Man Who Faced Espionage Case Gets Probation Over Taxes

    A Chinese engineer initially accused of illegally exporting documents on military aircraft to China was given probation and fined for failing to report about $1.4 million in business income by a Texas federal court after the government dropped its export charges.

  • October 07, 2024

    11th Circ. Balks At Ex-Braves' $47M Easement Case

    Former Atlanta Braves players John Smoltz and Ryan Klesko, challenging a U.S. Tax Court ruling that slashed the value of a conservation easement deduction by 90%, won't have their appeal heard by the Eleventh Circuit after the court said Monday the duo had jumped the gun on challenging the decision before it was made final.

  • October 07, 2024

    Mich. Couple Owe $3.3M Tax Debt, US Says

    A Michigan federal court should order the sale of three properties held by a real estate company to satisfy the roughly $3.3 million tax debt of a couple who are the company's nominee owners, the U.S. government said in a complaint Monday.

  • October 07, 2024

    DC Circ. Skeptical Of Tax Tipster's Whistleblower Award Bid

    D.C. Circuit judges seemed skeptical Monday of a tax tipster's claim that the U.S. Tax Court had jurisdiction over his case seeking to overturn the IRS' denial of a whistleblower award, saying during oral arguments that the agency had found his tips unproductive early on.

  • October 07, 2024

    Justices Won't Review Contractor's $1.3M R&D Credit Suit

    The U.S. Supreme Court let stand Monday a Fifth Circuit decision denying a construction company's shareholders a six-figure tax refund for the company's $1.3 million research credit claim, denying a petition.

  • October 07, 2024

    TCJA Extension, Biz Tax Cut To Reward Top 5%, Report Says

    Former President Donald Trump's planned extension of the 2017 tax cuts and lowering of corporate rates contribute most among his platform to lowering taxes for the wealthiest 5% and hiking them for everyone else, the left-leaning Institute on Taxation and Economic Policy said Monday in a report.

  • October 04, 2024

    Defunct Yoga Studios' Founder Cops To Tax Evasion

    The founder of a defunct chain of prominent and lucrative yoga studios who was accused of hiding $1.6 million in income from the Internal Revenue Service pled guilty to tax evasion, New York federal prosecutors said Friday.

  • October 04, 2024

    DC Circ. Won't Reconsider Whistleblower's $690M Claim

    The D.C. Circuit on Friday rejected a whistleblower's request that it rehear a ruling upholding the denial of up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program.

  • October 04, 2024

    Fed. Circ. Revives HR Co.'s $1.6M Tax Penalty Refund Bid

    A human resources company that sought $1.6 million in tax penalty refunds should not have been rejected for its failure to attach power-of-attorney forms to its requests, the Federal Circuit said Friday in vacating a decision by the U.S. Court of Federal Claims.

  • October 04, 2024

    Former NJ Doctor Owes $4.8M In FBAR Penalties, Court Told

    A former physician in New Jersey faces a tax bill of almost $5 million for failing to report 19 bank accounts he opened at Indian banks, the government told a federal court.

  • October 04, 2024

    IRS Probes Atty Over Promotion Of Deferred Law Firm Fees

    The Internal Revenue Service is investigating a lawyer it suspects of promoting a scheme to illegally shield attorneys from taxes on legal fees, according to an Ohio federal court petition seeking to enforce summonses for documents in the case.

  • October 04, 2024

    Justices Accept Ex-Chicago Alderman's False Statement Case

    The U.S. Supreme Court said Friday that it would review the conviction of an ex-Burke Warren MacKay & Serritella PC attorney and former Chicago alderman under a federal statute that prohibits making false statements to influence certain financial institutions.

Featured Stories

  • IRS Appeals Office's Easement Deals May Sap Independence

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    The IRS Independent Office of Appeals plans to settle certain conservation easement cases with similar terms offered by other IRS divisions, but these upcoming offers might be challenging for taxpayers to navigate and could undermine the office's independence from the rest of the agency.

  • Promise Of OECD's Payments Tax Treaty Called Into Question

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    The OECD-designed tool to provide developing countries with better means to apply a minimum tax on income sent from their jurisdictions to low-taxed entities within a corporate group is inadequate to address those countries' revenue needs, tax policy organizations said.

  • 12 Lawyers Who Are The Future Of The Supreme Court Bar

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    One attorney hasn't lost a single U.S. Supreme Court case she's argued, or even a single justice's vote. One attorney is perhaps "the preeminent SCOTUS advocate." And one may soon become U.S. solicitor general, despite acknowledging there are "judges out there who don't like me." All three are among a dozen lawyers in the vanguard of the Supreme Court bar's next generation, poised to follow in the footsteps of the bar's current icons.

Expert Analysis

  • Mental Health First Aid: A Brief Primer For Attorneys

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    Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.

  • The Trade And Tax Issues Behind US-Canada Digital Tax Clash

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    The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.

  • Litigation Inspiration: Honoring Your Learned Profession

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    About 30,000 people who took the bar exam in July will learn they passed this fall, marking a fitting time for all attorneys to remember that they are members in a specialty club of learned professionals — and the more they can keep this in mind, the more benefits they will see, says Bennett Rawicki at Hilgers Graben.

  • AI May Limit Key Learning Opportunities For Young Attorneys

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    The thing that’s so powerful about artificial intelligence is also what’s most scary about it — its ability to detect patterns may curtail young attorneys’ chance to practice the lower-level work of managing cases, preventing them from ever honing the pattern recognition skills that undergird creative lawyering, says Sarah Murray at Trialcraft.

  • A Look At How De Minimis Import Rules May Soon Change

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    The planned implementation of executive actions focused on the de minimis rule as it applies to shipments means companies should use this interval to evaluate the potential applicability and impact of Section 301, Section 201 or Section 232 duties on their products, say attorneys at Holland & Knight.

  • Ruling On Foreign Dividend Break Offers 2 Tax Court Insights

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    In Varian v. Commissioner, the U.S. Tax Court allowed a taxpayer's deduction for dividends from foreign subsidiaries, providing clarity on how the U.S. Supreme Court’s Loper Bright decision may affect challenges to Treasury regulations, and revealing a potential disallowance of foreign tax credits, say attorneys at Davis Polk.

  • Why Now Is The Time For Law Firms To Hire Lateral Partners

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    Partner and associate mobility data from the second quarter of this year suggest that there's never been a better time in recent years for law firms to hire lateral candidates, particularly experienced partners — though this necessitates an understanding of potential red flags, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.

  • Considering Possible PR Risks Of Certain Legal Tactics

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    Disney and American Airlines recently abandoned certain litigation tactics in two lawsuits after fierce public backlash, illustrating why corporate counsel should consider the reputational implications of any legal strategy and partner with their communications teams to preempt public relations concerns, says Chris Gidez at G7 Reputation Advisory.

  • It's No Longer Enough For Firms To Be Trusted Advisers

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    Amid fierce competition for business, the transactional “trusted adviser” paradigm from which most firms operate is no longer sufficient — they should instead aim to become trusted partners with their most valuable clients, says Stuart Maister at Strategic Narrative.

  • Avoid Getting Burned By Agencies' Solar Financing Spotlight

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    Recently coordinated reports and advisories from the U.S. Department of the Treasury, the Consumer Financial Protection Bureau and the Federal Trade Commission maximize the spotlight on the consumer solar financing market and highlight pitfalls for lenders to avoid in this burgeoning field, says Mercedes Tunstall at Cadwalader.

  • Tax Traps In Acquisitions Of Financially Distressed Targets

    Excerpt from Practical Guidance
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    Parties to the acquisition of an insolvent or bankrupt company face myriad tax considerations, including limitations on using the distressed company's tax benefits, cancellation of indebtedness income, tax lien issues and potential tax reorganizations.

  • Navigating A Potpourri Of Possible Transparency Act Pitfalls

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    Despite the Financial Crimes Enforcement Network's continued release of guidance for complying with the Corporate Transparency Act, its interpretation remains in flux, making it important for companies to understand potentially problematic areas of ambiguity in the practical application of the law, say attorneys at Sidley.

  • How Methods Are Evolving In Textualist Interpretations

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    Textualists at the U.S. Supreme Court are increasingly considering new methods such as corpus linguistics and surveys to evaluate what a statute's text communicates to an ordinary reader, while lower courts even mull large language models like ChatGPT as supplements, says Kevin Tobia at Georgetown Law.