Federal

  • November 12, 2025

    FERC Can't Order Refund Of Extra Tax Costs, DC Circ. Told

    The Federal Energy Regulatory Commission requiring an Energy Transfer LP unit to refund customers extra costs tacked onto its rates for deferred federal income tax reasons was unlawful retroactive ratemaking, the subsidiary told the D.C. Circuit, urging a reversal of the commission's order.

  • November 12, 2025

    MVP: Eversheds Sutherland's Maria Todorova

    Eversheds Sutherland's Maria Todorova secured a pivotal win for Duke Energy by successfully arguing that South Carolina's investment tax credit statute allowed the company to claim $20 million for qualifying investments, earning her a spot as one of the 2025 Law360 Tax MVPs.

  • November 12, 2025

    DOJ Fights Claim That IRS Unlawfully Shared Info With ICE

    The Trump administration has said the IRS complied with regulations when considering information requests from immigration enforcement officials, urging a D.C. federal judge to deny advocacy groups' request to submit a supplemental filing asserting that documents it turned over show otherwise.

  • November 12, 2025

    DC Circ. Affirms Toss Of Tax Tipster's Award Challenge

    The U.S. Tax Court correctly dismissed a man's claim to a whistleblower award for tips he gave the IRS about businesses he alleged had skipped employment taxes, the D.C. Circuit ruled Wednesday, saying the IRS didn't take any action against the taxpayers.

  • November 12, 2025

    8th Circ. Denies Medtronic's Bid To Rethink Pricing Ruling

    The Eighth Circuit denied healthcare tech company Medtronic's request to reconsider the court's approach for pricing a licensing agreement with a Puerto Rican affiliate, leaving in place Wednesday a ruling that directed the U.S. Tax Court to give the Internal Revenue Service's method another look.

  • November 12, 2025

    6th Circ. Asked To Rethink Tax Court Filing Deadline Ruling

    The Sixth Circuit should rethink its decision that the 90-day deadline to file a U.S. Tax Court petition is flexible and can be extended sometimes, the U.S. argued, saying the ruling widens a circuit split on an issue critical to tax administration.

  • November 10, 2025

    Law360 MVP Awards Go To Top Attorneys From 76 Firms

    The attorneys chosen as Law360's 2025 MVPs have distinguished themselves from their peers by securing significant achievements in high-stakes litigation, complex global matters and record-breaking deals.

  • November 10, 2025

    IRS Sets Safe Harbor For Trusts Staking Digital Assets

    Investment and grantor trusts can stake their digital assets — which can generate passive income — without losing their tax benefits if they meet certain requirements, including obtaining approval from the U.S. Securities and Exchange Commission to authorize such activities, the Internal Revenue Service said in a revenue procedure Monday.

  • November 10, 2025

    Ex-Russian Gas Exec Seeks Release After Tax Sentence Axed

    A former Russian gas company executive convicted of hiding more than $100 million from the IRS asked a Florida federal court to release him from prison now that his sentence has been vacated on appeal, while the U.S. urged the court to deliver the same seven-year term.

  • November 10, 2025

    Supreme Court Declines Lawyer's Bid For New Tax Fraud Trial

    The U.S. Supreme Court won't hear a personal injury lawyer's appeal of his conviction over allegations he concealed more than $2.6 million in income from the Internal Revenue Service.

  • November 07, 2025

    Eaton Should Have Weighed Borrowing In Europe, Judge Says

    When it acquired Ireland-based Cooper Industries in 2012, Eaton Corp. should have considered the costs of borrowing in Europe to finance the transaction, Tax Court Judge Albert Lauber said Friday in questioning a former Eaton official.

  • November 07, 2025

    Justices Cast Constitutional Clouds Over Trump's Tariffs

    Several U.S. Supreme Court justices appeared skeptical of the government's arguments seeking to salvage President Donald Trump's emergency tariffs, signaling that the high court may come down with a ruling that reinforces Congress' constitutional authority to impose tariffs.

  • November 07, 2025

    State Tax Rules Flagged To DOJ In Interstate Commerce Probe

    Tax attorneys and business groups are using a federal effort that aims to reduce interstate commerce burdens to highlight litigation over state taxes and call for codifying U.S. Supreme Court precedent on the commerce clause.

  • November 07, 2025

    Calif. Cannabis Co. Fights $10M IRS Bill In Tax Court

    A California company that manages cannabis operators challenged $10 million in taxes and penalties in the U.S. Tax Court, arguing the Internal Revenue Service stripped it of business deductions by incorrectly determining it trafficked in a controlled substance.

  • November 07, 2025

    Donor Wants Tax Court To Reinstate Easement Deductions

    An Oklahoma donor asked the U.S. Tax Court to reinstate deductions of $12 million and $13 million he claimed through partnership entities on a pair of charitable conservation easement donations, asserting the Internal Revenue Service disallowed the tax breaks without adequate explanation.

  • November 07, 2025

    9th Circ. Sides With Calif. In Tribal Cigarette Tax Fight

    The Ninth Circuit on Friday backed California in a dispute it brought to enforce cigarette taxes against a tobacco company owned and operated by a federally recognized Native American tribe, holding that the tribal leader defendants can't claim sovereign or qualified immunity exempts them from the federal tax law.

  • November 07, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service on Friday released its weekly internal revenue bulletin, which included proposed regulations that would remove rules that allow revenue officials to look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.

  • November 07, 2025

    DOJ Backs Trump In NY False-Records Conviction Appeal

    The U.S. Department of Justice is throwing its support behind President Donald Trump's effort to overturn his New York criminal conviction for falsifying business records, filing a proposed amicus brief on Friday citing the U.S. Supreme Court's landmark 2024 decision "defining the contours of a president's federal constitutional immunity from criminal prosecution."

  • November 07, 2025

    Wyden, Warren Flag IRS CEO's Fiserv Tenure In Probe

    Two Senate Finance Committee members said they are investigating Internal Revenue Service CEO Frank Bisignano's conduct in his previous position as Fiserv Inc.'s CEO, saying the financial setbacks the company has faced this year raise questions about his ability to serve as a key IRS official.

  • November 07, 2025

    Taxation With Representation: Kirkland, Cravath, Paul Weiss

    In this week's Taxation With Representation, consumer products giant Kimberly-Clark acquires Tylenol maker Kenvue, shale producers SM Energy and Civitas Resources announce a merger, and power management company Eaton buys Boyd Corp.'s thermal business.

  • November 06, 2025

    Goldstein Loses Bid To Trim Tax Charges Before Trial

    A Maryland federal judge Thursday handed SCOTUSblog co-founder Tom Goldstein a series of losses on pre-trial motions aimed at trimming the 22 federal tax charges he'll face at trial next year, ruling that many of the motions involved factual disputes fit for trial and keeping the government's case intact.

  • November 06, 2025

    Tax Court OKs Disallowance Of Unverified Litigation Fees

    The IRS correctly determined that a woman who'd been at odds with her various attorneys — having filed breach of contract suits against two separate legal teams — inadequately justified her claimed $28,000 deduction for legal expenses, the U.S. Tax Court said Thursday.

  • November 06, 2025

    Whistleblower Entitled To Award For $31M Tip, DC Circ. Told

    The U.S. Tax Court wrongly denied a whistleblower award to a woman who said she helped the Internal Revenue Service assess more than $31 million in corporate income, her supporter told the D.C. Circuit, saying the court allowed the agency to omit relevant information it was required to provide.

  • November 06, 2025

    IRS Microcaptive Reporting Rules Suit Can Move Forward

    A global tax services provider can move forward with its suit against the IRS to vacate tax reporting rules for microcaptive insurance companies, a Texas federal court said, finding the company had a stake in the challenge and a right to bring the case.

  • November 06, 2025

    No $22M Break For Real Estate Partnership, 6th Circ. Affirms

    An Ohio real estate partnership cannot claim a $22 million charitable tax deduction on a 2016 preservation easement, the Sixth Circuit found, affirming the U.S. Tax Court and Internal Revenue Service's conclusions that the partnership grossly misstated the value of the donated historic building.

Expert Analysis

  • High Court, Not A Single Justice, Should Decide On Recusal

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    As public trust in the U.S. Supreme Court continues to decline, the court should adopt a collegial framework in which all justices decide questions of recusal together — a reform that respects both judicial independence and due process for litigants, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.

  • Adapting To Private Practice: 3 Tips On Finding The Right Job

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    After 23 years as a state and federal prosecutor, when I contemplated moving to a law firm, practicing solo or going in-house, I found there's a critical first step — deep self-reflection on what you truly want to do and where your strengths lie, says Rachael Jones at McKool Smith.

  • Painting Makes Me A Better Lawyer

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    Painting trains me to see both the fine detail and the whole composition at once, enabling me to identify friction points while keeping sight of a client's bigger vision, but the most significant lesson I've brought to my legal work has been the value of originality, says Jana Gouchev at Gouchev Law.

  • Compliance Pointers Amid Domestic Terrorism Clampdown

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    A recent presidential memorandum marks a shift in federal domestic-terrorism enforcement that should prompt nonprofits to enhance diligence related to grantees, vendors and events, and financial institutions to shore up their internal resources for increased suspicious-activity monitoring and reporting obligations, say attorneys at Morgan Lewis.

  • Trump Tax Law Has Mixed Impacts On Commercial Real Estate

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    The One Big Beautiful Bill Act brings sweeping changes to the real estate industry — and while the permanency of opportunity zones and bonus depreciation creates predictability for some taxpayers, sunsetting incentives for renewable energy projects will leave others with hard choices, says Jordan Metzger at Cole Schotz.

  • Protecting Sensitive Court Filings After Recent Cyber Breach

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    In the wake of a recent cyberattack on federal courts' Case Management/Electronic Case Files system, civil litigants should consider seeking enhanced protections for sensitive materials filed under seal to mitigate the risk of unauthorized exposure, say attorneys at Redgrave.

  • What Ethics Rules Say On Atty Discipline For Online Speech

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    Though law firms are free to discipline employees for their online commentary about Charlie Kirk or other social media activity, saying crude or insensitive things on the internet generally doesn’t subject attorneys to professional discipline under the Model Rules of Professional Conduct, says Stacie H. Rosenzweig at Halling & Cayo.

  • 2 Rulings Highlight IRS' Uncertain Civil Fraud Penalty Powers

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    Conflicting decisions from the U.S. Tax Court and the Northern District of Texas that hinge on whether the IRS can administratively assert civil fraud penalties since the U.S. Supreme Court’s 2024 decision in SEC v. Jarkesy provide both opportunities and potential pitfalls for taxpayers, says Michael Landman at Bird Marella.

  • Junior Attys Must Beware Of 5 Common Legal Brief Mistakes

    Excerpt from Practical Guidance
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    Junior law firm associates must be careful to avoid five common pitfalls when drafting legal briefs — from including every possible argument to not developing a theme — to build the reputation of a sought-after litigator, says James Argionis at Cozen O'Connor.

  • Digital Asset Report Opens Doors For Banks, But Risks Linger

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    A recent report from a White House working group discussing digital asset market structure signals how banks may elect to expand into digital asset custody, trading and related services in the years ahead, but the road remains layered with challenges, say attorneys at Foley & Lardner.

  • Power To The Paralegals: How And Why Training Must Evolve

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    Empowering paralegals through new models of education that emphasize digital fluency, interdisciplinary collaboration and human-centered lawyering could help solve workforce challenges and the justice gap — if firms, educators and policymakers get on board, say Kristine Custodio Suero and Kelli Radnothy.

  • 5 Real Estate Takeaways From Trump's Sweeping Tax Law

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    Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.

  • Evaluating The Current State Of Trump's Tariff Deals

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    As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.

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