Federal
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July 30, 2025
Tax Overhaul Is Mixed Bag For Interest Expense Deductions
Companies that are eager to increase their interest expense deductions under the new federal tax overhaul may end up with a smaller tax break than expected due to how the law factors their foreign income into the deduction calculation.
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July 30, 2025
Groups Warn IRS Policy Shift Could Beget Dark Money Deluge
Leaders of national nonprofit organizations said Wednesday that the IRS' efforts to weaken a 71-year-old tax law banning churches from endorsing political candidates would lead to unlimited amounts of untraceable campaign contributions flowing through the nonprofit sector.
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July 30, 2025
Dechert Adds Tax Pro From PwC In DC
Dechert LLP has continued to grow its financial services platform in Washington, D.C., with the hire of a partner from PwC.
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July 30, 2025
Trump To Hit India With 25% Tariff, 'Penalty' Starting Friday
President Donald Trump said Wednesday that he planned to impose a 25% tariff on India beginning Friday, plus an additional "penalty," citing the country's energy and defense dealings with Russia as top concerns along with trade barriers.
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July 29, 2025
IRS To Permit Corp. AMT Top-Down Election For Partnerships
The IRS said Tuesday that revised proposed rules for the corporate alternative minimum tax will accommodate different approaches to calculating a partnership's investment income, including the top-down approach permitting a corporate partner to use figures that the partner reported in its own financial statement.
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July 29, 2025
Economists Decry Federal Budget's Looser Interest Deduction
It's regrettable that Congress loosened rules allowing companies to deduct interest costs from tax liabilities in its latest budget, which as a whole is poised to worsen the country's fiscal trajectory while prompting higher interest rates, a panel of economists said Tuesday.
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July 29, 2025
Refiners Seek Clarity From Treasury For Clean Fuel Credit
The U.S. Treasury Department should clarify at what points during the refining process an oil and gas mixture qualifies for the clean fuel production tax credit to be consistent with its preceding incentive for biofuels, an oil and gas refining association said in a letter released Tuesday.
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July 29, 2025
Ensure Energy Tax Credit Limit On Foreign Cos., Letter Says
The U.S. Department of the Treasury should publish guidance aimed at preventing foreign corporations from circumventing the new budget law's limits on energy tax credits by starting construction before the restrictions kick in, a solar technology and manufacturing company said in a letter Tuesday.
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July 29, 2025
Ex-IRS Acting Commissioner Joins KPMG's DC Office
A former senior Internal Revenue Service employee who served as the agency's acting commissioner this year has joined KPMG LLP's Washington national tax practice as a senior managing director, the firm announced.
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July 29, 2025
4th Circ. Rejects BofA's Claim Of Tax Offsets After Mergers
Bank of America cannot use its tax overpayments to offset interest on tax underpayments by Merrill Lynch just because the two companies later merged, the Fourth Circuit affirmed Tuesday in a $163 million case that affects more than 20 years' worth of tax adjustments.
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July 29, 2025
IRS Wrong To Fight Flexible Tax Court Deadline, 8th Circ. Told
A couple arguing for flexibility to the 90-day deadline for challenging tax bills in the U.S. Tax Court told the Eighth Circuit that the Internal Revenue Service is wrong in claiming that such leniency would upend tax collection.
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July 28, 2025
New IRS Chief Rejects 'Wizard Of Oz'-Style Leadership
New Internal Revenue Commissioner Billy Long vowed Monday to engage more directly with agency employees to improve taxpayer service, emphasizing that he does not want to be a "Wizard of Oz"-style leader hiding behind a curtain.
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July 28, 2025
SALT Cap Complexity Could Rewrite Tax Planning Strategies
The new $40,000 cap on state and local tax deductibility in the GOP's 2025 tax overhaul will likely prompt a new wave of strategic tax planning activity among wealthy business owners and individuals seeking to maximize their deductions and make use of state-level workarounds before the temporary relief expires.
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July 28, 2025
Fired Worker Owes Tax On $1.5M Settlement, Tax Court Says
A former PNC Investments LLC employee who won a defamation settlement after being fired must pay tax on the $1.5 million award, the U.S. Tax Court said Monday, rejecting the ex-worker's argument that the money didn't count as income.
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July 28, 2025
10th Circ. Says Carbon Group Can't Appeal Tax Assessment
An entity that owns interest in a carbon producer can't appeal a $2 million tax assessment made by a Colorado county on a carbon unit operator that the entity owns interest in because the federal court doesn't have jurisdiction, the Tenth Circuit said Monday.
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July 28, 2025
Trailer Maker's Bid To Escape $4M Excise Taxes Dismissed
A trailer manufacturer can't avoid more than $4 million in excise taxes, interest and penalties, a South Dakota federal court ruled, finding it couldn't rely on an exemption from a technical advice memorandum after Congress altered the definition of off-highway vehicles.
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July 28, 2025
US, Japanese Businessman Settle $11.6M FBAR Dispute
A Japanese businessman and the federal government have settled their $11.6 million tax filing dispute after the man claimed a language barrier was to blame and the U.S. tried to push past a jury's verdict, according to a Hawaii federal court filing.
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July 25, 2025
Trump Trade Deals Do Little To Ease Importers' Concerns
President Donald Trump's recently announced framework trade deals offer new insight into tariff rates for several countries come Aug. 1, but experts say unanswered questions about those agreements and others still at large continue to stifle longer-term planning, leaving importers in uncertain territory.
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July 25, 2025
Ex-Credit Suisse Client Gets 2½ Years For Hiding Assets
A Florida federal judge on Friday sentenced a Colombian-American businesswoman and former Credit Suisse client to two and a half years in prison for conspiring with family members to hide more than $90 million in assets from the IRS through a series of foreign bank accounts.
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July 25, 2025
Mayo Clinic's $11.5M Tax Refund Affirmed By 8th Circ.
The Mayo Clinic qualifies as an "educational organization" under federal tax law, making it eligible for a tax exemption for such organizations and meriting a nearly $11.5 million refund, the Eighth Circuit said Friday, affirming a federal district court.
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July 25, 2025
Vegas Workers Laud Tax Breaks On Tips, OT At Hearing
The new federal tax deductions for tips and overtime pay will be extremely beneficial to working-class residents of Las Vegas, the House Ways and Means Committee heard from workers and others at a field hearing Friday, while Democrats criticized the temporary nature of the tax breaks.
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July 25, 2025
Rising Star: Gibson Dunn's Michael Q. Cannon
Michael Q. Cannon of Gibson Dunn & Crutcher LLP has been the lead attorney on several high-profile cases, including playing a key role in advising on the tax aspects of the world's largest merger and acquisition deal in 2023, earning him a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 25, 2025
IRS Provides Guidance Meant To Speed Up Corporate Audits
The Internal Revenue Service released guidance Friday that aims to make audits more efficient for corporate taxpayers, including by phasing out a document request process taxpayers had criticized as time-consuming and of little value.
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July 25, 2025
Legal Org. Urges DC Circ. To Reject Trump's Tariff Powers
The D.C. Circuit should affirm a ruling that sided with toy makers and blocked President Donald Trump from using an international economic law to impose emergency tariffs because the law does not give the president the authority he claims, a legal organization argued.
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July 25, 2025
Taxation With Representation: Weil, Freshfields, Linklaters
In this week's Taxation With Representation, CC Capital and One Investment Management acquire Insignia Financial Ltd., catering giant Compass Group PLC acquires Dutch food and hospitality company Vermaat Groep BV, drugmaker Sanofi acquires biotech company Vicebio, and The Ether Machine launches as a public company.
Expert Analysis
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Bill Leaves Renewable Cos. In Dark On Farmland Reporting
A U.S. Senate bill to update disclosure requirements for foreign control of U.S. farmland does not provide much-needed guidance on how to report renewable energy development on agricultural property, leaving significant compliance risks for project developers, say attorneys at Hodgson Russ.
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Adapting To Private Practice: From US Rep. To Boutique Firm
My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.
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IRS Should Work With Industry On Microcaptive Regs
The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.
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CARES Act Fraud Enforcement Is Unlikely To Slow Down
In the five years since the passage of the Coronavirus Aid, Relief and Economic Security Act, the federal government has devoted massive resources to investigating CARES Act fraud — and all signs suggest the U.S. Department of Justice will continue vigorous enforcement in this area, say attorneys at Kostelanetz.
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Spinoff Transaction Considerations For Biotech M&A
Amid current market challenges, boards and management teams of biotech companies can consider several strategies for maximizing value should a spinoff opportunity arise, but not without significant advance planning and careful implementation, particularly in cases that might qualify as tax-free, say attorneys at Paul Hastings.
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Senate's 41% Litigation Finance Tax Would Hurt Legal System
The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.
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Drawbacks For Taxpayers From Justices' Levy Dispute Ruling
The Supreme Court's June decision in Commissioner v. Zuch, holding the Tax Court lacks jurisdiction to resolve disputes where the IRS has stopped pursuing a levy, may require taxpayers to explore new tactics for mitigating the increased difficulty of appealing their liability via collection due process hearings, says Matthew Roberts at Meadows Collier.
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How Energy Cos. Can Prepare For Potential Tax Credit Cuts
The Senate Finance Committee's version of the One Big Beautiful Bill act would create a steep phaseout of renewable energy tax credits, which should prompt companies to take several actions, including conduct a project review to discern which could begin construction before the end of the year, say attorneys at Husch Blackwell.
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DOJ Has Deep Toolbox For Corporate Immigration Violations
With the U.S. Department of Justice now offering rewards to whistleblowers who report businesses that employ unauthorized workers, companies should understand the immigration enforcement landscape and how they can reduce their risk, say attorneys at McDermott.
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Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs
In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.
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Del. Dispatch: General Partner Discretion In Valuing Incentives
In Walker v. FRP Investors, the Delaware Court of Chancery recently held that the general partner of a limited partnership breached its obligations when determining the threshold value of newly issued incentive units, highlighting the court's willingness to reconstruct what a reasonable determination of value by a general partner should have been, say attorneys at Fried Frank.
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Move Beyond Surface-Level Edits To Master Legal Writing
Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.
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9th Circ. Has Muddied Waters Of Article III Pleading Standard
District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.