Featured Stories

Tax Court Substance Ruling Offers Silver Lining For Taxpayers

Even though the U.S. Tax Court upheld stiff penalties under the economic substance doctrine against an eye doctor'... (more story)

3 Things To Know About Florida v. California At High Court

Florida startled many in the state tax community in late October by telling the U.S. Supreme Court the state has b... (more story)

The Tax Angle: Letter Ruling Debate, Experts' Role In Policy

From a discussion on whether seeking a private letter ruling risks sparking more IRS oversight to a former Congres... (more story)

Federal More

8th Circ. Decision Shipwrecks IRS On Shoals Of Loper Bright

The Eighth Circuit’s recent decision invalidating transfer pricing regulations in 3M Co. v. Commissioner may be the most significant tax case implementing Loper Bright's rejection of agency deference as a judi... (more story)

6th Circ. Urged To Affirm High Bar For Donor Reporting Rule

A libertarian organization urged the Sixth Circuit to affirm a finding that the federal government must meet a relatively high bar before it can force nonprofits to reveal the identities of their donors, sayin... (more story)

FBAR Penalty Against Ex-Prof Is Constitutional, Court Says

A former professor must pay the entire nearly $438,000 penalty the Internal Revenue Service assessed against him for his failure to timely disclose foreign bank accounts, a California magistrate judge held, fi... (more story)

Rule Amendments Pave Path For A Privilege Claim 'Offensive'

Litigators should consider leveraging forthcoming amendments to the Federal Rules of Civil Procedure, which will require early negotiations of privilege-related discovery claims, by taking an offensive posture... (more story)

Trump Pardons Nursing Home Owner In $39M Tax Fraud

President Donald Trump granted clemency to a nursing home operator who had been sentenced to three years in prison for a $39 million employment tax fraud scheme involving care centers he owned across the country.

Judge Unlikely To Find Eaton's Debt To Parent Wasn't Real

A U.S. Tax Court judge said Wednesday that he's unlikely to find that the intercompany debt U.S.-based Eaton Inc. owed its Irish parent was unreal and should be recharacterized as equity, all but dismissing an... (more story)

Senate GOP Resists Extending Expanded ACA Tax Premiums

Senate Finance Committee Democrats on Wednesday urged their Republican counterparts to extend the enhanced tax credits for the Affordable Care Act, which is set to expire at the end of the year, but Republican... (more story)

State & Local More

Phillips 66 Loses Appeal Of La. Refinery's $1 Billion Value

Phillips 66 cannot use the sale of a refinery in another state in its arguments for lowering the $1 billion assessment of a refinery in Louisiana, a state appeals court said, rejecting the company's appeal of the valuation.

Wis. Justices Urged To Grant Tax Break To Catholic Charities

The New Civil Liberties Alliance urged the Wisconsin Supreme Court to grant a group of Catholic charities an unemployment tax exemption in light of the U.S. Supreme Court's ruling that the state's application ... (more story)

US Asks To Join Cruise Industry's Challenge To Hawaii Tax

The federal government should be allowed to join a cruise industry trade group's case against the state of Hawaii and several counties over the extension of a transient occupancy tax to cruise passengers, the ... (more story)

Litigation Funding Could Create Ethics Issues For Attorneys

A litigation investor’s recent complaint claiming a New York mass torts lawyer effectively ran a Ponzi scheme illustrates how litigation funding arrangements can subject attorneys to legal ethics dilemmas and ... (more story)

NY Senator Pitches Bill To Regulate, Tax Hemp Beverages

A New York state senator has prefiled a bill to regulate the sale of intoxicating hemp cannabinoid beverages while levying a 10% tax on them.

E-Discovery Quarterly: Recent Rulings On Dynamic Databases

Several recent federal court decisions illustrate how parties continue to grapple with the discovery of data in dynamic databases, so counsel involved in these disputes must consider how structured data should... (more story)

MVP: Sullivan & Cromwell's Isaac Wheeler

Isaac Wheeler of Sullivan & Cromwell LLP's tax practice advised RedBird Capital Partners on the Skydance and Paramount deal, helped xAI and X on a $113 billion transaction related to their merger and guided Ti... (more story)

MVP: Latham's Pardis Zomorodi

Pardis Zomorodi, partner at Latham & Watkins LLP's transactional tax practice in Los Angeles, has guided companies through the tax aspects of major complex transactions, including 2024's largest IPO and the hi... (more story)

Taxation With Representation: Wachtell, Paul Hastings, Sidley

In this week's Taxation With Representation, Pfizer Inc. completes its acquisition of obesity drug developer Metsera Inc., motion and controls technologies company Parker-Hannifin Corp. acquires Filtration Gro... (more story)

International More

EU Needs Unified Tax Benefits For Electricity, Experts Say

The European Union needs a unified approach to tax benefits that would treat electricity more favorably than fossil fuels amid an impasse surrounding its overhaul to the energy taxation system, experts told th... (more story)

Gov'ts Widely Back Mutual Agreement Procedure In UN Treaty

Governments expressed widespread support for adopting measures to strengthen the mutual agreement procedure within a protocol on dispute resolution in the United Nations tax convention during the latest round of negotiations.

Korea Wins Annulment Of $216M Lone Star Funds Award

South Korea on Tuesday prevailed in its bid to wipe out a $216 million arbitral award issued to an affiliate of Lone Star Funds, though the private equity firm has already vowed to resubmit its claim to a new tribunal.

Malawi Reiterates Bid For Gem Export Tax Investigation

Malawi has bolstered its bid for a Washington federal judge to reconsider his decision barring the country from pursing discovery against a gemstone company that partnered with a mining outfit the country clai... (more story)

Ex-Russian Gas CFO Resentenced To 6 Years For Tax Crimes

A Florida federal judge handed a nearly six-year prison term to a Russian gas company's former chief financial officer, who was convicted for tax evasion after the Eleventh Circuit vacated a prior sentence earlier this year.

Fed. Circ. Finds Baby Formulas For Illnesses Duty-Free

A baby formula maker's products designed as therapies for children with chronic medical conditions qualify for duty-free treatment, the Federal Circuit ruled Monday, overturning the U.S. Court of International... (more story)

Fed. Circ. Backs Commerce To Nix Turkish Steel Duties

The U.S. Department of Commerce's removal of countervailing duties on Turkish steel imports was properly justified by the government, and the lower trade court correctly upheld its determination despite object... (more story)