Federal

  • July 01, 2024

    High Court's 1-2 Punch Sets Up Long-Standing Regs For KO

    By ending its term with a stinging combination against federal agencies, the U.S. Supreme Court's conservative bloc left behind a bruised bureaucracy and a regulatory system that's now vulnerable to a barrage of incoming attacks.

  • July 01, 2024

    IRS Faces Rulemaking Pressure Following Chevron's Demise

    The Internal Revenue Service will likely face more pressure to develop tax regulations that are more firmly grounded in the law and tailored to ensure certainty for individuals, businesses and other organizations after the U.S. Supreme Court's landmark decision to overturn the decades-old Chevron doctrine.

  • July 01, 2024

    Feds Push To Keep IRS Agents Out Of Hunter Biden Tax Case

    Two Internal Revenue Service whistleblowers who Hunter Biden said wrongfully disclosed his confidential tax information should not be allowed to intervene in his suit against the U.S. government, the government told a D.C. federal court Monday.

  • July 01, 2024

    Pa. Man Gets 12 Years For $2M COVID-19 Funds Fraud

    A Pennsylvania man was sentenced to approximately 12 years in prison following his convictions for bank fraud, aggravated identity theft and unlawful monetary transactions related to theft of federal COVID-19 pandemic relief funds, according to the U.S. Attorney's Office for the Middle District of Pennsylvania.

  • July 01, 2024

    Womble Bond Adds Int'l Tax Partner In Houston Office

    Womble Bond Dickinson has added a partner to its corporate and securities group in Houston who will focus on tax law and cross-border transactions, the firm announced.

  • July 01, 2024

    Tax Court Again Rules Against Couple On Social Security Pay

    A California couple should have included Social Security disability payments in their income on their federal tax return, the U.S. Tax Court said Monday, upholding an Internal Revenue Service determination against the couple in such a case for a second time.

  • July 01, 2024

    US-Taiwan Biz Groups Push For True Double-Tax Treaty

    Top-ranking Senate members should push for the start of consultations on a bilateral tax treaty to avoid double taxation between the U.S. and Taiwan as opposed to measures already included in a stalled larger bill, two groups focused on business relations between the countries said.

  • July 01, 2024

    Nelson Mullins Adds 9-Attorney Tax Team In Houston

    Nelson Mullins Riley & Scarborough LLP announced Monday that five partners and four other tax attorneys have joined its new Houston office from Chamberlain Hrdlicka White Williams & Aughtry, including a former Texas Supreme Court justice.

  • July 01, 2024

    Longtime IRS Trial Atty Joins Jones Day In NY

    An attorney who spent his entire career at the IRS has moved to private practice at Jones Day, the firm said on Monday.

  • July 01, 2024

    Firm Can't Cast Off $1.5M Tax Levy In Alter Ego Case

    A Baltimore law firm can't stop a $1.5 million tax levy that allowed the IRS to freeze its bank account, a Maryland federal judge ruled, saying the firm failed to prove at this point in its suit that one of its clients lacked an interest in the money.

  • July 01, 2024

    IRS Floats Taking Tax Payments Directly By Credit Card

    Taxpayers using credit cards could sidestep third-party payment processors and make tax payments directly to the IRS under regulations the agency proposed Monday that align with the Taxpayer First Act.

  • July 01, 2024

    IRS Regs Would Tax Overpayment Interest On COVID Credits

    Businesses, tax-exempt groups and some governmental entities could be taxed on overpayment interest received for erroneous refunds of pandemic relief tax credits under proposed Internal Revenue Service regulations released Monday.

  • July 01, 2024

    Top 3 Federal Tax Policies Of 2024: Midyear Report

    Despite an energetic start of the year with the House's overwhelming passage of a bipartisan tax package negotiated between the chairs of the House and Senate's tax-writing committees, tax policy discussions in Congress have slowed down in the months since. Here, Law360 looks at the most consequential developments in federal tax policy from the first half of 2024.

  • July 01, 2024

    Supreme Court Widens Window To Challenge Federal Regs

    Legal challenges to federal regulations can be brought outside the normal statute of limitations if someone isn't adversely affected until after the six-year window of time to file suit, the U.S. Supreme Court ruled Monday.

  • June 28, 2024

    Chevron's End Is Just The Start For Energized Agency Foes

    By knocking down a powerful precedent that has towered over administrative law for 40 years, the U.S. Supreme Court's right wing Friday gave a crowning achievement to anti-agency attorneys. But for those attorneys, the achievement is merely a means to an end, and experts expect a litigation blitzkrieg to materialize quickly in the aftermath.

  • June 28, 2024

    In Chevron Case, Justices Trade One Unknown For Another

    The U.S. Supreme Court's decision to overrule a decades-old judicial deference doctrine may cause the "eternal fog of uncertainty" surrounding federal agency actions to dissipate and level the playing field in challenges of government policies, but lawyers warn it raises new questions over what rules courts must follow and how judges will implement them.

  • June 28, 2024

    The Tax Angle: IRS Budget Vote, TCJA's Racial Impact

    From a look at an upcoming vote on IRS funding for fiscal 2025 to an analysis of GOP claims that tax incentives in the 2017 Tax Cuts and Jobs Act benefited Black Americans, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • June 28, 2024

    IRS Finalizes Broker Rules For Digital Asset Sales

    Brokers of digital assets such as cryptocurrency and non-fungible tokens will face tax reporting requirements for the first time similar to those for brokers of securities and other financial instruments under final regulations issued Friday by the Internal Revenue Service.

  • June 28, 2024

    Final Rules Exempt REITs From Stock Buyback Tax

    Real estate investment trusts and regulated investment companies may be able to avoid the stock buyback tax but would still be required to keep records under final regulations on reporting and paying the tax released by Treasury and the IRS Friday.

  • June 28, 2024

    IRS Plans To Quickly Finalize Partnership Basis-Shifting Regs

    The IRS is moving quickly to finalize partnership rules that target abusive tax avoidance using basis shifting within related partnerships, the agency's top attorney said Friday, asking practitioners to weigh in on the rulemaking so enforcement can properly target the problematic transactions.

  • June 28, 2024

    IRS Improves Availability But Can Do More, TIGTA Says

    The Internal Revenue Service has improved the accessibility and availability of customer services in underserved, underrepresented and rural communities, but it could do more to expand into other geographic areas, the Treasury Inspector General for Tax Administration said Friday.

  • June 28, 2024

    IRS Whistleblower Office Overhaul In Process, Chief Says

    The Internal Revenue Service is working through initiatives to improve its whistleblower program that were laid out in the agency's strategic operating plan, including improving systems and processes and drastically increasing staffing, the director of the agency's Whistleblower Office said Friday.

  • June 28, 2024

    NY Law Firm Botched Gas Co. Sale, Ex-Client Says

    Albany, New York-based Whiteman Osterman & Hanna LLP is facing a lawsuit in New York federal court alleging it failed to properly structure the sale of a gas company and caused its owner to incur an avoidable tax liability.

  • June 28, 2024

    IRS Reminds Marijuana Businesses They Can't Get Tax Breaks

    The Internal Revenue Service sought to remind taxpayers Friday that businesses selling marijuana, even in states where it's legal, are not entitled to federal tax deductions, saying some taxpayers are filing invalid claims for refunds through amended returns.

  • June 28, 2024

    Chevron Ruling No Sea Change For Tax Court, Judge Says

    The U.S. Tax Court will continue to rely on the IRS and Treasury's expertise in the tax code following the U.S. Supreme Court's landmark decision to overturn the 40-year-old Chevron doctrine that directed courts to defer to federal agencies' interpretations of ambiguous law, a judge said Friday.

Expert Analysis

  • Trump Hush Money Case Offers Master Class In Trial Strategy

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    The New York criminal hush money trial of former President Donald Trump typifies some of the greatest challenges that lawyers face in crafting persuasive presentations, providing lessons on how to handle bad facts, craft a simple story that withstands attack, and cross-examine with that story in mind, says Luke Andrews at Poole Huffman.

  • A Vision For Economic Clerkships In The Legal System

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    As courts handle increasingly complex damages analyses involving vast amounts of data, an economic clerkship program — integrating early-career economists into the judicial system — could improve legal outcomes and provide essential training to clerks, say Mona Birjandi at Data for Decisions and Matt Farber at Secretariat.

  • State-Regulated Cannabis Can Thrive Without Section 280E

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    Marijauna's reclassification as a Schedule III-controlled substance comes at a critical juncture, as removing marijuana from being subjected to Section 280E of the Internal Revenue Code is the only path forward for the state-regulated cannabis industry to survive and thrive, say Andrew Kline at Perkins Coie and Sammy Markland at FTI Consulting.

  • Asset Manager Exemption Shifts May Prove Too Burdensome

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    The U.S. Department of Labor’s recent change to a prohibited transaction exemption used by retirement plan asset managers introduces a host of new costs, burdens and risks to investment firms, from registration requirements to new transition periods, say attorneys at Simpson Thacher.

  • A Look At New IRS Rules For Domestically Controlled REITs

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    The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.

  • E-Discovery Quarterly: Recent Rulings On Text Message Data

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    Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.

  • Should NIL Collectives Be Allowed Tax-Favored Status?

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    Arguments are being made for and against allowing organizations to provide charitable contribution tax deductions for donations used to compensate student-athletes, a practice with impacts on competition for student-athletes and overall tax fairness, but ultimately it is a question for Congress, say Andres Castillo and Barry Gogel at the University of Maryland School of Law.

  • Understanding The IRC's Excessive Refund Claim Penalty

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    Taxpayers considering protective refund claims pending resolution of major questions in tax cases like Moore v. U.S., which is pending before the U.S. Supreme Court, should understand how doing so may also leave them vulnerable to an excessive refund claim penalty under Internal Revenue Code Section 6676, say attorneys at McDermott.

  • Don't Use The Same Template For Every Client Alert

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    As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

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    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

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    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.

  • Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks

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    Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

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