Federal

  • July 15, 2024

    Akerman Brings On Chamberlain Hrdlicka Tax Pros In Atlanta

    Akerman LLP announced Monday that it picked up a pair of new partners for its tax practice group in Atlanta who were previously with Chamberlain Hrdlicka White Williams & Aughtry.

  • July 15, 2024

    TIGTA Says IRS Can Improve Digital Currency Enforcement

    While the IRS has carried out some enforcement actions related to virtual currency noncompliance and has launched a program focused on identifying taxpayers who leave digital assets off their returns, the agency has lots of room for improvement, the Treasury Inspector General for Tax Administration said Monday.

  • July 15, 2024

    Truck Co. Qualifies For $500M Tax Safe Harbor, 6th Circ. Told

    A Tennessee company asked the Sixth Circuit to shield it from more than $500 million in excise tax liabilities, saying a lower court correctly found that its refurbished trucks qualify for the safe harbor from the heavy-truck excise tax.

  • July 15, 2024

    Rising Star: Davis Polk's Dominic Foulkes

    Dominic Foulkes of Davis Polk & Wardwell LLP has advised companies on several multibillion-dollar transactions, including a technology-maker's $4.9 billion initial public offering, the largest in the United States in the last three years, earning him a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 12, 2024

    Rising Star: Quinn Emanuel's Emily Au

    Emily Au of Quinn Emanuel Urquhart & Sullivan LLP has been the lead attorney on several high-profile cases, including a key case across the U.K. construction industry in terms of HMRC's Value-Added Tax policy, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 12, 2024

    Law360 Names 2024's Top Attorneys Under 40

    Law360 is pleased to announce the Rising Stars of 2024, our list of 158 attorneys under 40 whose legal accomplishments belie their age.

  • July 12, 2024

    Chevron's End Doesn't Bear On 3M's Case, IRS Tells 8th Circ.

    The U.S. Supreme Court's recent overturning of Chevron deference doesn't warrant a reversal of a U.S. Tax Court ruling in 3M Co.'s transfer pricing case, the Internal Revenue Service told the Eighth Circuit on Friday.

  • July 12, 2024

    Payments To Ex-Wife Should Be Deductible, 11th Circ. Told

    A Georgia man told the Eleventh Circuit on Friday that his payments to his ex-wife as part of a marital settlement should qualify as alimony and therefore be deductible from his federal income taxes, asking the court to reverse a U.S. Tax Court decision.

  • July 12, 2024

    Mo. Says IRS 'Stonewalling' On Worker Credit Freeze Records

    The Internal Revenue Service violated public records law in failing to release documents related to its decision to stop processing new employee retention credit claims, the state of Missouri said Friday in a complaint that accuses the agency of "stonewalling."

  • July 12, 2024

    11th Circ. Urged To Grant Deductions In Ruined Records Case

    The U.S. Tax Court should have been more generous in granting tax deductions to a Florida couple whose records were destroyed by a hurricane, the couple told the Eleventh Circuit on Friday, saying the lost records were out of their control.

  • July 12, 2024

    Taxation With Representation: Ropes & Gray, Cravath, Latham

    In this Week's Taxation with Representation, Paramount Global merges with Skydance Media, Devon Energy acquires Grayson Mill Energy's Williston Basin oil and gas business, Ryan acquires Altus Group Ltd.'s property tax business, and Bain Capital buys Envestnet Inc.

  • July 12, 2024

    Former City Treasurer Gets 30 Months In $1M Embezzlement

    A former city treasurer in Alaska was sentenced to two and a half years in prison after having admitted to tax evasion and fraud in connection with a $1 million embezzlement scheme, according to Alaska federal court documents.

  • July 12, 2024

    7 Taxpayer Advocacy Panel Committees To Meet In August

    Seven of the Taxpayer Advocacy Panel's committees will hold public meetings in August focused on improving customer service at the Internal Revenue Service, the agency announced Friday.

  • July 12, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included the reporting and recording obligations associated with the stock buyback excise tax.

  • July 11, 2024

    House GOP Urges USTR To Probe Canada Digital Services Tax

    The U.S. trade representative should immediately launch an investigation into Canada's recently enacted digital services tax and determine if trade actions are necessary to protect American interests, U.S. House Ways and Means Republicans said in a letter Thursday.

  • July 11, 2024

    Tax Court Denies Real Estate Loss Deduction To Builder

    The U.S. Tax Court said Thursday that it didn't believe a man who claimed to work an extra 48 hours a week beyond his regular full-time job to build a short-term rental property, denying him a $22,000 rental real estate loss deduction reserved for real estate professionals.

  • July 11, 2024

    ABA Attys Seek To Avoid Reporting Foreign Trust Loans

    The American Bar Association's tax, real estate and trust attorneys are seeking to prevent the U.S. Treasury Department from tightening reporting requirements for the exemption of loans from foreign trusts, which are often used by wealthy families and in succession planning, according to a consultation response.

  • July 11, 2024

    Railroad Benefits Are Taxable, Tax Court Says

    A retired railroad worker and his wife must include benefits from the Railroad Retirement Board in their taxable income, having failed to prove that the benefits are nontaxable due to their disabilities, the U.S. Tax Court ruled Thursday.

  • July 11, 2024

    Ex-Leaders Ask Biden For Int'l Coordination On Billionaire Tax

    President Joe Biden should get behind Brazil's proposal for the Group of 20 nations to coordinate a minimum tax on billionaires, nearly 20 former presidents and prime ministers from countries such as Canada, France and South Korea said in an open letter.

  • July 11, 2024

    IRS Proposes 'Basket Contracts' As Listed Transactions

    The Internal Revenue Service proposed rules Thursday that would flag so-called basket option contracts as potentially abusive listed transactions, imposing additional reporting requirements under the threat of penalty for individuals and businesses involved in such arrangements.

  • July 11, 2024

    Low-Speed EV Maker Sues Treasury Over Blocked Tax Credits

    The U.S. Department of the Treasury violated the Administrative Procedure Act when it passed final regulations excluding low-speed vehicles from qualifying for clean vehicle tax credits, a maker of low-speed electric cars told a D.C. federal court.

  • July 10, 2024

    Ex-VP Of Fla. Aerospace Co. Sentenced To Prison For Fraud

    The former vice president of a Miami-based aerospace company was sentenced to just over a year in federal prison after he pled guilty to fraud-related charges in connection to a scheme that involved embezzling millions of dollars and splitting the proceeds with a co-conspirator.

  • July 10, 2024

    Engineer Who Faced Export Charges Cops To Tax Counts

    A Chinese-born engineer has pled guilty to two counts of filing a false tax return related to allegations that he and his wife omitted gross income from their tax returns between 2015 and 2019, after Texas federal prosecutors initially charged the couple with export violations and fraud. 

  • July 10, 2024

    Tax Court Nominees Vow To Sort Out Post-Chevron Cases

    Three nominees for spots on the U.S. Tax Court assured Senate lawmakers Wednesday that they could resolve cases involving federal regulations and congressional intent after the U.S. Supreme Court overturned the Chevron deference doctrine.

  • July 10, 2024

    OECD Publishes Pillar 2 Technical Reporting Language Draft

    The Organization for Economic Cooperation and Development published a draft of technical details required to digitally input and disseminate information required for Pillar Two global minimum tax returns Wednesday.

Featured Stories

  • 3 Defenses The IRS Can Fall Back On After Chevron's Demise

    Kat Lucero

    The U.S. Supreme Court's decision to eliminate federal agencies' ability to rely on the 40-year-old Chevron doctrine to defend their interpretations of ambiguous laws will likely trigger more litigation against the IRS. But that doesn't mean the agency is completely defenseless against such suits. Here, Law360 explores three defense options for the IRS following Chevron's demise.

  • IRS Funding At Stake In 2025 Tax Cut Negotiations

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    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.

  • Continued Worker Credit Freeze Could Push Cos. To Court

    David van den Berg

    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.

Expert Analysis

  • A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates

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    Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.

  • States Should Loosen Law Firm Ownership Restrictions

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    Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.

  • After Chevron: Uniform Tax Law Interpretation Not Guaranteed

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    The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.

  • Texas Ethics Opinion Flags Hazards Of Unauthorized Practice

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    The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • How High Court Approached Time Limit On Reg Challenges

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    The U.S. Supreme Court's decision in Corner Post v. Federal Reserve Board effectively gives new entities their own personal statute of limitations to challenge rules and regulations, and Justice Brett Kavanaugh's concurrence may portend the court's view that those entities do not need to be directly regulated, say attorneys at Snell & Wilmer.

  • How To Clean Up Your Generative AI-Produced Legal Drafts

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    As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.

  • A Tale Of 2 Trump Cases: The Rule Of Law Is A Live Issue

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    The U.S. Supreme Court’s decision this week in Trump v. U.S., holding that former President Donald Trump has broad immunity from prosecution, undercuts the rule of law, while the former president’s New York hush money conviction vindicates it in eight key ways, says David Postel at Henein Hutchison.

  • Industry Self-Regulation Will Shine Post-Chevron

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    The U.S. Supreme Court's Loper decision will shape the contours of industry self-regulation in the years to come, providing opportunities for this often-misunderstood practice, says Eric Reicin at BBB National Programs.

  • 3 Ways Agencies Will Keep Making Law After Chevron

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    The U.S. Supreme Court clearly thinks it has done something big in overturning the Chevron precedent that had given deference to agencies' statutory interpretations, but regulated parties have to consider how agencies retain significant power to shape the law and its meaning, say attorneys at K&L Gates.

  • Atty Well-Being Efforts Ignore Root Causes Of The Problem

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    The legal industry is engaged in a critical conversation about lawyers' mental health, but current attorney well-being programs primarily focus on helping lawyers cope with the stress of excessive workloads, instead of examining whether this work culture is even fundamentally compatible with lawyer well-being, says Jonathan Baum at Avenir Guild.

  • Tracking Implementation Of IRA Programs As Election Nears

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    As the Biden administration races to cement key regulations implementing the Inflation Reduction Act, a number of the law's programs and incentives are at risk of delay or repeal if Republicans retake control of Congress, the White House or both — so stakeholders should closely watch ongoing IRA implementation and guidance, say attorneys at Squire Patton.

  • Unpacking The Circuit Split Over A Federal Atty Fee Rule

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    Federal circuit courts that have addressed Rule 41(d) of the Federal Rules of Civil Procedure are split as to whether attorney fees are included as part of the costs of a previously dismissed action, so practitioners aiming to recover or avoid fees should tailor arguments to the appropriate court, says Joseph Myles and Lionel Lavenue at Finnegan.

  • Takeaways From Justices' Redemption Insurance Decision

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    The U.S. Supreme Court’s recent decision in Connelly v. U.S. examines how to determine the fair market value of shares in a closely held company for estate tax purposes, and clarifies how life insurance held by the company to enable redemption of a decedent’s shares affects that calculation, says Evelyn Haralampu at Burns & Levinson.