Federal

  • March 22, 2024

    Holland & Knight Hires Caplin & Drysdale Member In DC

    Holland & Knight LLP has boosted its Washington-based tax team, hiring a Caplin & Drysdale Chtd. member who first joined his former firm 25 years ago from the U.S. Department of the Treasury.

  • March 22, 2024

    US Unlikely To Move On Hungary Tax Treaty, Official Says

    Hungary's low corporate tax rate and other policies will likely prevent the U.S. government from resuming negotiations on a stalled 2010 tax treaty after terminating its existing Hungarian treaty in early 2023, an IRS official said Friday.

  • March 22, 2024

    IRS Steadily Returning To Pre-Covid Levels, TIGTA Says

    Internal Revenue Service initiatives have reduced some — but not all — document processing back to pre-pandemic levels, the Treasury Inspector General for Tax Administration said in a report.

  • March 22, 2024

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service issued its weekly bulletin Friday, which included rules for businesses substituting certain tax forms.

  • March 21, 2024

    Treasury Hoping Pillar 2 Guidance Favors R&D Tax Credits

    The U.S. Treasury Department is looking for future administrative guidance on the international minimum tax agreement known as Pillar Two to give favorable treatment to U.S. research and development tax credits, but it will likely come with guardrails, a Treasury official said Thursday.

  • March 21, 2024

    Tax Court OKs Collection After Man Fails To Provide Records

    A Georgia man cannot challenge a tax collection action after failing to provide financial records proving he cannot pay a liability, the U.S. Tax Court ruled Thursday.

  • March 21, 2024

    GOP Sens. Push Yellen To Commit To TCJA Extension

    Senate Finance Committee Republicans on Thursday pushed Treasury Secretary Janet Yellen to commit to extending provisions in the Tax Cuts and Jobs Act, including the law's child tax credit expansion and the corporate and individual tax cuts.

  • March 21, 2024

    Man Faces Penalty After Debating Job Status, Tax Court Says

    A Georgia man is responsible for a frivolous filing tax penalty after questioning his employment status, the U.S. Tax Court affirmed Thursday.

  • March 21, 2024

    UN Could Enhance Global Tax Agenda Setting, Officials Say

    The United Nations could play an important role in shaping the agenda for global tax negotiations so it better reflects the priorities and concerns of developing countries, a variety of tax officials said Thursday during a conference.

  • March 21, 2024

    7th Circ. Won't Let Admitted Fraudster Ditch $1.3M Restitution

    A woman who admitted to wire fraud in connection with a three-person scheme to file hundreds of false tax returns owes $1.3 million in restitution to the government, the Seventh Circuit ruled Thursday, rejecting the woman's claim that the amount was miscalculated.

  • March 21, 2024

    IRS Proposes Exceptions For 3rd-Party Summons Notices

    The IRS proposed rules Thursday that would allow some exceptions to a requirement that the agency notify taxpayers within 45 days before issuing summonses to third parties in tax assessment and collection cases, including for certain time-sensitive examinations.

  • March 21, 2024

    Wyden Probes Swiss Bank's Ties To Billionaire Under Scrutiny

    The Senate Finance Committee's Democratic majority launched an inquiry into Swiss bank Pictet Group's involvement with a U.S. billionaire under criminal investigation, raising questions about the bank's deferred prosecution agreement and $123 million fine by the U.S. Justice Department, committee Chairman Ron Wyden announced Thursday.

  • March 21, 2024

    Quintairos Prieto Taps Atlanta Atty To Lead New Tax Group

    Quintairos Prieto Wood & Boyer PA said it had created a tax division that will be led by an Atlanta-based partner who has guided clients on civil and criminal tax law, reinforcing its national expertise in litigation, regulatory and corporate law matters.

  • March 21, 2024

    H&R Block Challenges FTC Judges In False Ad Battle

    H&R Block asked a Missouri federal court to stop administrative law judges from overseeing a Federal Trade Commission proceeding that accuses the tax preparation company of deceptive advertising, claiming the judges have job protections that unconstitutionally shield them from presidential oversight.

  • March 21, 2024

    Senate Bill Seeks To End Tax-Free Merger Treatment

    A bill introduced Thursday in the U.S. Senate would end manipulation of the Internal Revenue Code that allows certain corporate mergers to be tax-free.

  • March 21, 2024

    IRS Tweaks Proposed Partnership Treatment Rules

    The Internal Revenue Service issued a correction notice Thursday fixing a reference in proposed regulations about the treatment of related people within partnerships.

  • March 21, 2024

    IRS Issues Fixes In Safe Harbor Regulations

    The Internal Revenue Service issued two correction notices Thursday to amend final regulations focused on certain safe harbor exceptions.

  • March 20, 2024

    Endo Plan To Trim $5B In Debt Confirmed By NY Judge

    Drugmaker Endo International got a New York bankruptcy judge's approval for its Chapter 11 plan that aims to cut more than $5 billion in debt and hand over ownership to its lenders, roughly a month after it finalized a $465 million deal to resolve criminal and civil opioid claims.

  • March 20, 2024

    Wyden Bill Would Target Abuse Of Annuity Trusts

    A bill introduced Wednesday by the Senate Finance Committee chairman, Sen. Ron Wyden, D-Ore., would attempt to limit the abuse of a type of annuity trusts by the wealthy, in part by imposing a requirement that the instruments have a minimum term of at least 15 years.

  • March 20, 2024

    IRS Releases Foreign Housing Expense Limits For 2024

    The Internal Revenue Service released adjustments to the limitation on foreign housing expense deductions and exclusions for 2024 on Wednesday.

  • March 20, 2024

    IRS Asks Justices To Scrap Couple's Late-Filed Tax Court Suit

    The IRS asked the U.S. Supreme Court to consider reversing the Third Circuit's revival of a couple's challenge to their tax bill, saying the appeals court incorrectly concluded that a 90-day deadline for petitioning the U.S. Tax Court need not always be met.

  • March 20, 2024

    RI Ex-Broker Gets 8 Years In Ponzi Scheme

     A Rhode Island man was sentenced to eight years in prison for running a decade-long Ponzi scheme to defraud investors and to evade his taxes.

  • March 20, 2024

    How The Supreme Court Could Narrow Chevron

    After hours of oral argument in a closely watched administrative law case, it appeared that some U.S. Supreme Court justices could be open to limiting the opportunities for lower courts to defer to federal agencies' legal interpretations in disputes over rulemaking — and legal experts said there are a number of ways they could do it.

  • March 20, 2024

    IRS Withholding Docs On Partnership Audits, Baker Atty Says

    The Internal Revenue Service has not responded to a request for documents pertaining to the agency's scrutiny of large partnerships and should be forced to disclose them, an attorney with Baker McKenzie told a D.C. federal court.

  • March 20, 2024

    IRS Grants Income Exclusion To Those Fleeing 6 Countries

    Individuals who fled conditions in Ukraine, Belarus, Sudan, Haiti, Niger and Iraq after specific dates in 2023 can exclude foreign earned income, and can exclude or deduct housing costs, from gross income that year because of adverse conditions in the countries, the IRS said.

Expert Analysis

  • 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.

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

  • Newman Suspension Shows Need For Judicial Reform

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    The recent suspension of U.S. Circuit Judge Pauline Newman following her alleged refusal to participate in a disability inquiry reveals the need for judicial misconduct reforms to ensure that judges step down when they can no longer serve effectively, says Aliza Shatzman at The Legal Accountability Project.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

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    Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • How Law Firms Can Use Account-Based Marketing Strategies

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    Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.

  • While Risks Exist, AI Could Transform IRS Enforcement

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    The Internal Revenue Service's recently announced use of artificial intelligence could revolutionize the agency's enforcement efforts, and transparency about its use and a forum for challenging AI findings could help mitigate fears that the technology will increase bias, say attorneys at Lewis Brisbois.

  • Strategic Succession Planning At Law Firms Is Crucial

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    Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.

  • Maximizing Law Firm Profitability In Uncertain Times

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    As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • How Gov't Agencies Will Fare In The Event Of A Shutdown

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    With a federal shutdown potentially set to begin at the end of this month, it may be useful to consider the approximate timelines that agencies such as the Federal Trade Commission and IRS have announced for curtailing operations, and potential strategies for mitigating challenges that may arise while agency functions are limited, say attorneys at Cleary.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

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