Federal

  • January 15, 2025

    Former IRS Litigator Joins Jones Day In Boston

    Jones Day announced it added an experienced IRS litigator to its Boston office who will work as of counsel in the firm's tax practice.

  • January 15, 2025

    Legislators Say Transparency Act Defies First Amendment

    The Corporate Transparency Act is an unnecessary intrusion into the First Amendment rights of Americans, U.S. Sen. Thom Tillis, R-N.C., and 13 House members told the Supreme Court in seeking to maintain an injunction issued in December.

  • January 15, 2025

    IRS Establishes Clean Vehicle Credit Valuation Safe Harbors

    The Internal Revenue Service provided two safe harbors Wednesday for calculating the value of the commercial clean vehicle tax credit using either modeled incremental costs or retail-price equivalents.

  • January 15, 2025

    House Clears US-Taiwan Double Tax Relief Bill

    The U.S. House of Representatives overwhelmingly approved legislation Wednesday that would provide Taiwanese businesses in the United States with tax-treaty-like benefits and authorize the White House to negotiate a tax agreement with Taiwan.

  • January 15, 2025

    9th Circ. Won't Review Nixed Deductions For Disbarred Atty

    The Ninth Circuit on Wednesday rejected a disbarred California attorney's requests to review its December decision to uphold a U.S. Tax Court ruling denying his bid to take business deductions for the cost of challenging his disbarment and a court's declaration that he is a "vexatious litigant."

  • January 15, 2025

    IRS Pilots Aim To Broaden Fast-Track Settlement Program

    The Internal Revenue Service announced Wednesday that it would test changes to its settlement procedures through pilot programs that aim to allow more businesses and self-employed people to keep their disputes with the agency out of court. 

  • January 15, 2025

    IRS Lists Facility Types Eligible For Clean Energy Credits

    The Internal Revenue Service on Wednesday released the first annual table showing the types of facilities that have been deemed to not produce greenhouse gas emissions and are therefore eligible for the clean energy production and investment tax credits.

  • January 15, 2025

    IRS Mulling Widened Early Application Of Offshore Profit Regs

    The Internal Revenue Service is considering expanding the early application option for proposed regulations designed to help U.S. multinational corporations properly account for previously taxed earnings and profits, an agency official said Wednesday.

  • January 15, 2025

    Booz Allen Must Pay For Harm Of Tax Info Leaks, Court Told

    A proposed class action in Maryland federal court blames IRS contractor Booz Allen Hamilton over the thousands of tax returns that were stolen by an employee who took financial information about President-elect Donald Trump and others while on the job and leaked it to the media.

  • January 15, 2025

    Applicable Federal Rates To Continue Rising In Feb.

    Applicable federal rates for income tax purposes will increase across the board for the third straight month in February, the Internal Revenue Service said Wednesday.

  • January 15, 2025

    Fried Frank Guides $177M Financing For NYC Office Building

    GFP Real Estate, a commercial real estate owner and manager, has borrowed more than $177 million from merchant bank BDT & MSD to acquire and partially convert a Manhattan office building into residential units, in a financing deal advised by Fried Frank Harris Shriver & Jacobson LLP, according to official property records.

  • January 15, 2025

    IRS Issues Corp. Bond Monthly Yield Curve For Jan.

    The Internal Revenue Service on Wednesday published the corporate bond monthly yield curve for January for use in calculations for defined benefit plans, as well as corresponding segment rates and other related provisions.

  • January 14, 2025

    KPMG, Biz Groups, NY Tax Bar Urge Reg Fixes To Corp. AMT

    Energy company and life insurance groups have proposed industry-specific adjustments to the U.S. corporate alternative minimum tax regulations, while the New York State Bar Association and KPMG advocate for simpler accounting methods to assess compliance, according to comment letters to the U.S. Treasury Department.

  • January 14, 2025

    House GOP Urges TCJA Permanency At First 2025 Tax Hearing

    The 2017 tax law's expiring provisions, including the opportunity zone tax incentives, credit for advanced manufacturing and child tax credit expansion, must be made permanent as soon as possible, House Ways and Means Committee Chairman Jason Smith said Tuesday.

  • January 14, 2025

    IRS Floats Counting Affiliate Pay In $1M Pay Deduction Cap

    Compensation from affiliates of publicly traded companies would count toward the $1 million limit on tax deductions for performance-based pay of high-earning employees under rules proposed Tuesday by the U.S. Treasury Department and Internal Revenue Service.

  • January 14, 2025

    Man Didn't Prove Travel, Vehicle Deductions, Tax Court Says

    An Ohio man the IRS said incorrectly claimed nearly $14,000 in travel- and vehicle-related costs failed to substantiate them, the U.S. Tax Court said Tuesday, including failing to remember the names of trade shows he said he attended in the middle of the COVID-19 pandemic.

  • January 14, 2025

    Easement Worth $1M, Not $18M, Gov't Tells 11th Circ.

    The U.S. Tax Court was right to believe expert testimony that a claimed conservation easement donation of roughly $18 million was only worth $1 million, the government told the Eleventh Circuit, urging it to reject the donors' claims that the expert was unreliable.

  • January 14, 2025

    IRS Appoints 18 Members To Advisory Council

    The Internal Revenue Service appointed 18 new members to its advisory council to serve three-year terms starting this month, the agency said Tuesday.

  • January 14, 2025

    IRS Releases Latest Surprise Healthcare Bill Calculation Rate

    The Internal Revenue Service provided Tuesday a percentage increase for calculating certain out-of-network healthcare coverage for 2025 under legislation that barred surprise medical bills.

  • January 14, 2025

    Trump Announces Plans To Create 'External Revenue Service'

    President-elect Donald Trump said Tuesday that he planned to create an "External Revenue Service" that would collect tariffs and revenue from foreign countries.

  • January 14, 2025

    IRS Updates Scam Protections For 2025 Filing Season

    The Internal Revenue Service announced changes Tuesday for the 2025 tax filing season designed to help protect taxpayers and tax professionals from scams and schemes, including updates to certain forms and increasing reviews and education.

  • January 14, 2025

    Feds Ask 2 Years For Ex-Pol On Tax, Pandemic Aid Charges

    A former Massachusetts state senator should spend two years in prison after being convicted of illegally obtaining unemployment assistance and filing a false tax return, the federal government argued, citing the "greed" at the heart of the politician's conduct.

  • January 14, 2025

    DOL Finalizes ERISA Voluntary Correction Program Changes

    The U.S. Department of Labor's employee benefits arm has finalized changes to a program allowing retirement plan managers to voluntarily self-correct when they fail to forward employee contributions on time or make other transaction errors, according to a notice the agency posted online Tuesday.

  • January 13, 2025

    Special Counsel Slams Biden's Critique Of Son's Prosecution

    The special counsel who oversaw the investigation into Hunter Biden, which was wiped out by a presidential pardon, released a report published Monday criticizing President Joe Biden's "baseless accusations" that his son was "selectively" prosecuted and warning that such comments threaten "the integrity of the justice system as a whole."

  • January 13, 2025

    Feds Say Par Funding Fraud Caused $404M In Losses

    Prosecutors and defense attorneys spent hours in a marathon hearing Monday trying to convince a Pennsylvania judge of how much financial damage they thought the principals of the Par Funding merchant lending business did by allegedly fleecing investors, with the government pushing for a $404 million figure.

Expert Analysis

  • Why DOJ's Whistleblower Program May Have Limited Impact

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    The U.S. Department of Justice’s new whistleblower pilot program aims to incentivize individuals to report corporate misconduct, but the program's effectiveness may be undercut by its differences from other federal agencies’ whistleblower programs and its interplay with other DOJ policies, say attorneys at Milbank.

  • How Justices Upended The Administrative Procedure Act

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    In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.

  • Trump's Best Hush Money Appeal Options Still Likely To Fail

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    The two strongest potential arguments former President Donald Trump could raise in appealing his New York hush money conviction seem promising at first, but precedent strongly suggests they will still ultimately fail — though, of course, Trump's unique position could lead to surprising results, says former New York Supreme Court Justice Ethan Greenberg, now at Anderson Kill.

  • Tips For Tax Equity-Tax Credit Transfers That Pass IRS Muster

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    Although the Internal Revenue Service has increased its scrutiny of complex partnership structures, which must demonstrate their economic substance and business purpose, recent cases and IRS guidance together provide a reliable road map for creating legitimate tax equity structures, say Ian Boccaccio and Michael Messina at Ryan Tax.

  • Mirror, Mirror On The Wall, Is My Counterclaim Bound To Fall?

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    A Pennsylvania federal court’s recent dismissal of the defendants’ counterclaims in Morgan v. Noss should remind attorneys to avoid the temptation to repackage a claim’s facts and law into a mirror-image counterclaim, as this approach will often result in a waste of time and resources, says Matthew Selmasska at Kaufman Dolowich.

  • 3 Leadership Practices For A More Supportive Firm Culture

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    Traditional leadership styles frequently amplify the inherent pressures of legal work, but a few simple, time-neutral strategies can strengthen the skills and confidence of employees and foster a more collaborative culture, while supporting individual growth and contribution to organizational goals, says Benjamin Grimes at BKG Leadership.

  • E-Discovery Quarterly: Rulings On Hyperlinked Documents

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    Recent rulings show that counsel should engage in early discussions with clients regarding the potential of hyperlinked documents in electronically stored information, which will allow for more deliberate negotiation of any agreements regarding the scope of discovery, say attorneys at Sidley.

  • Loper Bright Limits Federal Agencies' Ability To Alter Course

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    The U.S. Supreme Court's recent decision to dismantle Chevron deference also effectively overrules its 2005 decision in National Cable & Telecommunications Association v. Brand X, greatly diminishing agencies' ability to change regulatory course from one administration to the next, says Steven Gordon at Holland & Knight.

  • A Guide To Long-Term, Part-Time Employee Determinations

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    With final regulations under the Secure Act requiring 401(k) retirement benefits for long-term, part-time employees expected soon, Amy Sheridan and David Guadagnoli at Sullivan & Worcester look at how the proposed rules would shift the risk-reward calculus on excluding categories of employees, and what plan sponsors would need to consider when designing retirement plans.

  • After Chevron: Delegation Of Authority And Tax Regulators

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    The U.S. Department of the Treasury and the Internal Revenue Service will face higher standards following Loper Bright’s finding that courts should determine whether agency rules meet the best possible interpretation of the tax code, as well as the scope of the authority delegated by Congress, says Edward Froelich at McDermott.

  • Lawyers Can Take Action To Honor The Voting Rights Act

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    As the Voting Rights Act reaches its 59th anniversary Tuesday, it must urgently be reinforced against recent efforts to dismantle voter protections, and lawyers can pitch in immediately by volunteering and taking on pro bono work to directly help safeguard the right to vote, says Anna Chu at We The Action.

  • How To Grow Marketing, Biz Dev Teams In A Tight Market

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    Faced with fierce competition and rising operating costs, firms are feeling the pressure to build a well-oiled marketing and business development team that supports strategic priorities, but they’ll need to be flexible and creative given a tight talent market, says Ben Curle at Ambition.

  • Rock Climbing Makes Me A Better Lawyer

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    Rock climbing requires problem-solving, focus, risk management and resilience, skills that are also invaluable assets in my role as a finance lawyer, says Mei Zhang at Haynes and Boone.

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