Friday, February 2, 2018

TOP NEWS

IRS Rules Would OK Partnerships To Adjust Outside Bases

The IRS on Thursday proposed highly awaited rules that would allow a partnership to make adjustments to its outside basis when the agency determined the partnership owes tax under the new centralized partnership audit regime that took effect at the beginning of the year. Read more »

Analysis

EU Nations Won’t Wait For Agreement On Digital Tax Rules

Some European Union countries may forge ahead with their own policies for taxing the digital economy in the absence of bloc-wide consensus, specialists say, citing the new U.S. tax law and another potential punt from the Organization for Economic Cooperation and Development. Read more »

3rd Circ. Says Lawyer Must Disclose Client List To IRS

A Third Circuit panel affirmed on Thursday a Pennsylvania district court’s order enforcing two IRS administrative summonses for a lawyer to share client and settlement lists related to his unpaid taxes, rejecting his contentions that the information was protected under Pennsylvania’s attorney-client privilege or under rules of professional conduct. Read more »

DOJ Settles Final Case In IRS Political Targeting Row

The Internal Revenue Service reached its final settlement on Thursday in a series of cases accusing the agency of political bias in the processing of applications for tax-exempt status, according to an announcement from the U.S. Department of Justice. Read more »

FEDERAL

Full 11th Circ. Nixes 30-Year Precedent On Tax Affidavits

A full panel of Eleventh Circuit judges on Wednesday overturned more than 30 years of legal precedent by ruling that self-serving, uncorroborated affidavits may create an issue of fact and overcome a motion for summary judgment in tax cases. Read more »

Business Trio Can't Void IRS Settlement, 7th Circ. Finds

A trio of former business partners in the oil industry lost their lawsuit to walk back on a settlement they reached with the IRS to pay back taxes when the Seventh Circuit on Wednesday found the partners hadn’t gone through proper administrative channels first. Read more »

Solar Co. Seeks $12M In Federal Clean Energy Cash Grants

A solar company sued the federal government Wednesday in the Court of Federal Claims, seeking almost $12 million it said it's owed in renewable energy cash grants provided under the 2009 stimulus law. Read more »

INTERNATIONAL

Gov’t Sues For FBAR Penalties Over UK Bank Accounts

The U.S. government on Wednesday asked a California federal judge to force a taxpayer to pay penalties tied to over a dozen U.K. bank accounts that she allegedly failed to disclose in a Foreign Bank and Financial Accounts form. Read more »

EXPERT ANALYSIS

Under New Tax Law, Time Is Running Out For Ponzi Victims

Counsel representing victims of Ponzi schemes should note that the Tax Cuts and Jobs Act eliminates the theft tax loss provisions of the Internal Revenue Code for tax years after 2017. The time to act is now, before this important tax benefit goes away, says Kevin Diamond of Rico Murphy & Diamond LLP. Read more »

How Notice 2018-13 Frames Foreign Earnings Transition Tax

On Jan. 19, the U.S. Department of the Treasury and the IRS issued Notice 2018-13, elaborating on previous guidance about the Tax Cuts and Jobs Act’s new deemed repatriation provision. The notice also describes the agencies' intent to issue updated Form 5471 instructions, which will introduce an important — and much needed — limitation to filing requirements following the repeal of Section 958(b)(4), say attorneys at Morgan Lewis & Bockius LLP. Read more »

Opinion

Evolving Due Process In The Digital Age

Because courts have not modernized as quickly as companies like Amazon, Tesla and Apple, Americans are becoming increasingly dissatisfied, but technological innovations may be able to help Americans access their due process, says Stephen Kane of FairClaims. Read more »

LEGAL INDUSTRY

Feature

Under Judge Garland, DC Goes 'Circuit Riding'

With a traveling D.C. Circuit seal affixed to a wall behind him, a table-turned-makeshift bench beneath him and a room full of law students in front of him in an American University conference hall, Chief Judge Merrick B. Garland started oral arguments in two appeals last week by answering his own question: Why are we here? Read more »

Cook County Clerk Appeals Order On Access To E-Filed Suits

Cook County Circuit Court Clerk Dorothy Brown is appealing an injunction that would have required her office to provide instant access to lawsuits filed electronically in the Chicago-area circuit courts by next week, according to court documents filed Wednesday. Read more »

Law360's Weekly Verdict: Legal Lions & Lambs

A team of attorneys led by Norton Rose Fulbright's Abbe Lowell secured the dismissal of the corruption case against U.S. Sen. Bob Menendez, D-N.J., earning them a spot on this week's legal lions list, while the legal lambs list was headed up by a Troutman Sanders LLP attorney bench-slapped by the Eleventh Circuit for convincing a district court to shirk the appeals court's mandate in a retail chain exclusivity row. Read more »

Law360's 2018 Editorial Board Selection Survey

Law360 is looking for avid readers of our publications to serve as members on our 2018 editorial advisory boards. Read more »

Series

What I Learned In My First Year: A Judge's Example

Law school taught me how to think like a lawyer, but the district court judge I clerked for my first year out of law school taught me how to be a lawyer. This was the gift she gave to all of her law clerks, in one form or another, says M.C. Sungaila of Haynes and Boone LLP. Read more »

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