Federal

  • February 13, 2024

    Crypto Exec Wants IRS Summonses Quashed, Citing Privacy

    A cryptocurrency executive charged in a 2020 bitcoin fraud investigation was never notified about Internal Revenue Service summonses later sent to two banks that sought his and his company's financial records, he told a Texas federal court, arguing that the summonses should be quashed.

  • February 13, 2024

    Ex-IRS Contractor Appeals 5-Year Sentence For Tax Info Leak

    A former IRS contractor sentenced to five years in prison for stealing and leaking former President Donald Trump's tax returns — and those of thousands of other wealthy people — to the media told a D.C. federal court he will appeal his final judgment.

  • February 13, 2024

    Lawmakers Call On IRS For Lead Pipe Replacement Clarity

    Fifteen bipartisan members of Congress called on the Internal Revenue Service to clarify the tax treatment of lead pipe replacement grants in a letter released Tuesday.

  • February 12, 2024

    IRS Data Safeguards Still Lacking, GOP Leader Says

    A watchdog report shows the Internal Revenue Service doesn't appear to be doing much to better protect sensitive taxpayer data even after a contractor was found to have stolen thousands of tax returns, including former President Donald Trump's, the top House Republican tax writer said Monday.

  • February 12, 2024

    Ga. Attys Claim Fund Managers Organized Illegal Tax Shelter

    Managers of a fund profited by selling units in a "grossly inflated" tax shelter and then hid a federal criminal investigation into the arrangement from investors, partners in an Athens, Georgia, law firm said in a suit recently transferred to federal court.

  • February 12, 2024

    IRS To Float Requirements For Tax-Free Spinoffs, Official Says

    The Internal Revenue Service is planning to propose guidance that would replace regulations floated in 2016 to clarify when corporations can undertake spinoffs and other tax-free distributions without unlawfully distributing earnings and profits, an agency official said Monday.

  • February 12, 2024

    Cybergang Member Gets 16 Years For $45M Tax Scheme

    A Florida federal judge delivered the steepest sentence yet for a member of a cybergang that hacked the computers of accounting firms and stole thousands of client identities to siphon $45 million in tax refunds, ordering him to serve 16 years in prison.

  • February 12, 2024

    Head Of IRS Criminal Investigation Division To Retire

    The chief of the Internal Revenue Service's Criminal Investigation division will step down from his position April 6, the agency announced Monday.

  • February 12, 2024

    IRS Must Increase Closures Of High-Dollar Audits, GAO Says

    The Internal Revenue Service must take steps to close a higher percentage of audits for high-income returns, the U.S. Government Accountability Office said in a report published Monday.

  • February 12, 2024

    IRS Updates Employer Health Penalty Index For 2025

    The Internal Revenue Service published guidance Monday updating indexing adjustment amounts for calculating employer health coverage penalties in 2025.

  • February 09, 2024

    Pillar 2 Shouldn't Hit 'Double Dipping' Loss Rules, CPAs Say

    The Pillar Two international minimum tax agreement should not impact U.S. rules that are designed to prevent companies from "double dipping" with a single economic loss, the American Institute of Certified Public Accountants recommended in a letter made public Friday.

  • February 09, 2024

    Senate GOP Push For Tax Bill Changes Could Slow Progress

    Senate Republicans' desire to add their own priorities to the tax bill recently passed by the House, along with a jam-packed Senate agenda, could delay the proposal in its journey to President Joe Biden's desk.

  • February 09, 2024

    6th Circ. Backs Fine Against Doctor For Willful FBAR Violation

    A Michigan doctor clearly met the standard for a willful failure to file reports of foreign bank accounts, the Sixth Circuit said, confirming a lower court decision resulting in a $930,000 penalty against him.

  • February 09, 2024

    The Tax Angle: SALT, Housing Credits, Opportunity Zones

    House Democrats held their two-day legislative issues conference this week, formulating plans to win majority control of the chamber in November so they can shape the policy agenda next year when parts of the GOP's 2017 tax law expire. Here's a peek into a reporter's notebook at a few of the developing tax stories that Democrats discussed at their meeting.

  • February 09, 2024

    Jordan Calls For Investigation Into DOJ's Deal With IRS Leaker

    House Judiciary Committee Chairman Jim Jordan is investigating whether federal prosecutors were politically motivated to allow the former IRS contractor who leaked former President Donald Trump's tax returns to plead guilty to a single count of illegal disclosure, calling the arrangement "a sweetheart deal."

  • February 09, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, which included a ruling regarding the treatment of unused housing credit amounts allocated to a state.

  • February 09, 2024

    Taxation With Representation: Sullivan & Cromwell, Kirkland

    In this week's Taxation With Representation, California Resources Corp. acquires Aera Energy, ZeroFox Holdings goes private, and Acerinox purchases Haynes International.

  • February 08, 2024

    NJ, Ft. Lee Mayor Fail To Merge NY Congestion Pricing Suits

    A federal judge on Thursday rejected a bid to consolidate two lawsuits — one filed by New Jersey, the other by the mayor of a Garden State town — seeking to halt New York City's congestion pricing toll plan, ruling that the suits make similar claims but seek different remedies.

  • February 08, 2024

    3M Tells 8th Circ. IRS Used Invalid Regs To Allocate Income

    Multinational conglomerate 3M urged the Eighth Circuit to reverse a U.S. Tax Court decision upholding regulations that the IRS had used to disregard Brazilian legal restrictions when allocating the company's income, contending that the rules contravene an underlying transfer pricing statute.

  • February 08, 2024

    First Returns Submitted Using IRS Free E-File Pilot Program

    Early testers of the Internal Revenue Service's free electronic tax return pilot program successfully filed the first returns using the system, an agency official said Thursday.

  • February 08, 2024

    Tax Court Frees Woman From Ex's Omitted Income

    Meeting the criteria for innocent spouse relief, a Wisconsin woman is not liable for a portion of a tax liability from the year her divorce was finalized, the U.S. Tax Court ruled Thursday.

  • February 08, 2024

    Tax Court Rejects Guardian's Claims For Tweaked Treatment

    An Illinois woman is ineligible for head-of-household status as well as the earned income tax credit because her dependent spent most of the year living elsewhere, the U.S. Tax Court ruled Thursday.

  • February 08, 2024

    US Grantor Trusts Need Int'l Reporting Clarity, Treasury Told

    The U.S. Treasury Department should clarify that domestic grantor trusts aren't required to file international information returns, the American Institute of Certified Public Accountants said in a letter made public Thursday, claiming that current uncertainty has led to redundant reporting.

  • February 08, 2024

    DC Circ. Skeptical Of 5-Hour Energy Partner's Tax Challenge

    D.C. Circuit judges seemed skeptical of a Canadian citizen's argument that $6.5 million in gains she received from selling a share of a U.S. partnership that sold 5-Hour Energy drinks shouldn't be federally taxed, grappling to understand her reasoning during oral arguments Thursday.

  • February 08, 2024

    IRS Mostly Compliant With Purchase Card Rules, TIGTA Says

    The Internal Revenue Service is mostly compliant with regulations on purchase card spending, the Treasury Inspector General for Tax Administration said in a report published Thursday.

Expert Analysis

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • IRS Proposal May Help Clarify Donor-Advised Fund Excise Tax

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    Recently proposed regulations provide important clarifications of the Internal Revenue Code's excise tax on donor-advised fund distributions by providing detailed definitions of key terms and addressing some of the open issues related to their operation and administration, say attorneys at Morgan Lewis.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Liability Exposure For Unpaid Payroll Taxes May Surprise You

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    The Ninth Circuit’s recent decision in Richard W. York v. U.S. offers important lessons for business owners and others who may be responsible for a company's checkbook about how someone else's failure to submit payroll taxes can result in their personal liability, says Douglas Charnas at McGlinchey Stafford.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

  • Finding Focus: Strategies For Attorneys With ADHD

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    Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.

  • Unlocking Value In Carve-Out M&A Transactions

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    Some of the largest mergers and acquisitions in 2023 were carve-out transactions, and despite their unique intricacies and challenges, these transactions offer both buyers and sellers the opportunity to generate outsized returns in an otherwise vigorously competitive landscape, when carefully planned and diligently executed, say Kevin Crews and Rami Totari at Kirkland.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

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    After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.

  • Tips For Litigating Against Pro Se Parties In Complex Disputes

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    Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.

  • Anticipating Intensified Partnership Enforcement From IRS

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    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

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