Federal

  • December 12, 2025

    Judge Says Eaton Moved $14B Subsidiary For Tax Purposes

    A U.S. Tax Court judge said Friday that he plans to find Eaton's U.S. group transferred ownership of a $14 billion subsidiary overseas in 2012 solely to justify payment of higher interest rates and guarantee fees to the company's new Irish parent.

  • December 12, 2025

    DOJ Shake-Up Keeps Criminal Tax Meetings, Ex-Official Says

    The U.S. Department of Justice — despite recently eliminating its Tax Division as part of a broad restructuring — continues to meet with practitioners representing clients who may face federal criminal tax charges, the former division chief said Friday.

  • December 12, 2025

    IRS To Revamp Voluntary Disclosure Program

    The Internal Revenue Service will be updating a program early next year that would allow taxpayers to voluntarily report previously undisclosed income as a way to resolve their tax issues to facilitate a simpler reporting process, the agency's criminal enforcement chief said Friday.

  • December 12, 2025

    Treasury Withdraws Proposed Regs On Spousal Tax Liability

    The U.S. Treasury Department has withdrawn two sets of proposed regulations addressing married individuals who filed joint tax returns then later sought relief from joint and several tax liability, according to a notice issued Friday.

  • December 12, 2025

    New Scholarship Tax Credit Plan Open To States, IRS Says

    States can make an advance election to participate in a new tax credit program for contributions made to scholarship organizations, the Treasury Department and the Internal Revenue Service announced Friday, adding that the program is set to start in 2027.

  • December 12, 2025

    Treasury Issues Final Rules For Taxing Foreign Gov't Income

    The U.S. Treasury Department issued final regulations Friday for determining whether income of foreign governments derived within the U.S. is taxable along with proposed regulations concerning when a foreign government has effective control of a commercial entity.

  • December 12, 2025

    IRS Sets 2026 Wage Base For Covered Compensation

    The taxable wage base used to calculate covered compensation for employee retirement plans will be $184,500 for the 2026 tax year, the Internal Revenue Service announced in a revenue ruling Friday.

  • December 12, 2025

    Taxation With Representation: Cravath, Skadden, Debevoise

    In this week's Taxation With Representation, Paramount Skydance Corp. launches a hostile bid for Warner Bros. Discovery, challenging Netflix's deal to acquire the studio and streaming business, IBM acquires data streaming company Confluent, and natural gas company Antero Resources Corp. expands via a deal with HG Energy.

  • December 12, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included final regulations for the excise tax on corporations' stock buybacks and similar transactions without what is known as the funding rule.

  • December 11, 2025

    IRS Plans Outreach Campaign For NIL Income Earners

    The Internal Revenue Service plans to launch an outreach campaign to educate student-athletes, entertainers, artists and social media influencers about the tax implications of income earned through personal brand marketing, endorsements and similar activities, an agency official said Thursday.

  • December 11, 2025

    Judge Slams Eaton Expert For Offering Legal Analysis

    A report submitted by one of Eaton's expert witnesses in its acquisition financing trial overstepped the limits of an expert's role, offering legal rather than economic analysis and seeming to advocate for the company​​​​, a U.S. Tax Court judge said Thursday.

  • December 11, 2025

    Failed ACA Credit Extension Votes Leave Costs In Limbo

    The Senate failed Thursday to pass procedural votes on two healthcare proposals to address the upcoming lapse in the Affordable Care Act's enhanced premium tax credits, including a proposal by Democrats to extend the subsidies for three years.

  • December 11, 2025

    Fed Terminates 3 Actions Against Credit Suisse, JPMorgan

    The Federal Reserve said Thursday that it has terminated a trio of enforcement actions against Credit Suisse Group AG and JPMorgan Chase & Co., lifting consent orders that were tied to alleged illicit finance practices and trade surveillance failures.

  • December 11, 2025

    Group Seeks Cannabis Reclassification Regarding Tax Status

    Cannabis shouldn't be categorized as a Schedule 1 or 2 drug, so tax law regarding the sale of illegal drugs shouldn't be applied to cannabis sales, a coalition of cannabis industry groups told the U.S. Tax Court in an amicus brief Thursday.

  • December 11, 2025

    Tax Court Rejects Nevada Couple's Law Firm Deductions

    A married couple who are both attorneys are subject to a federal tax lien because they are not entitled to deductions and reduced gross receipts related to their law firm, and they aren't entitled to claimed losses from real estate, the U.S. Tax Court said Thursday.

  • December 10, 2025

    House Advances Bill To Suspend Tax Refund Claim Limits

    The House Ways and Means Committee approved several tax bills Wednesday, including legislation that suspends the limitation period to file a refund claim until an IRS collection due process hearing concludes and all appeals rights have lapsed in levy cases.

  • December 10, 2025

    Judge Probes IRS Expert On Method For Eaton's Credit Rating

    A U.S. Tax Court judge asked an IRS expert Wednesday about his calculation of a standalone credit rating for Eaton's U.S. group in 2012, when it acquired an Irish entity and inverted, noting that the expert, unlike ratings agency Standard & Poor's, factored in Eaton's debt to the Irish parent.

  • December 10, 2025

    6th Circ. Chides US For Lacking Merits In Distilling Ban Case

    A Sixth Circuit judge criticized the U.S. Department of Justice on Wednesday for refusing to address the merits of a suit challenging the constitutionality of the U.S. tax code's ban on home distilling, saying the government cannot decide what the appellate court reviews.

  • December 10, 2025

    DOJ Seeks Fairness Review From High Court In Tax Dispute

    A property owner is appropriately compensated if given surplus proceeds from a government sale of their property for more than the owner owed, provided the sale was conducted fairly, the federal government told the U.S. Supreme Court.

  • December 10, 2025

    7th Circ. Upholds Tax Conviction Of DHS Special Agent

    A jury relied on enough evidence to convict a former U.S. Department of Homeland Security agent of tax crimes related to his secret dealings with drug dealers, the Seventh Circuit said Wednesday, rejecting his claim that proof of his corruption was insufficient.

  • December 10, 2025

    Magistrate Backs FinCEN Rules In All-Cash Real Estate Deals

    A magistrate judge in Florida federal court rejected arguments from a title insurance company in upholding a U.S. Department of Treasury rule establishing new reporting requirements for all-cash residential real estate transactions as a means of combating financial crime.

  • December 09, 2025

    Judge Wants Cost-Benefit Analysis Of Eaton Guarantees

    A U.S. Tax Court judge asked one of Eaton's experts Tuesday how much the company could have saved by issuing debt from its new Irish parent in 2012 instead of having the parent guarantee bonds the U.S. company issued to third parties.

  • December 09, 2025

    7th Circ. Denies Tax Evader's New Trial Over Disciplined Atty

    A man convicted of tax fraud will not get a new trial based on his lawyer's removal from the Seventh Circuit Bar two months after his conviction in an unrelated case, the appellate court ruled Tuesday, saying the discipline must relate to his own defense.

  • December 09, 2025

    US Asks 5th Circ. To Revive ACA Employer Tax Penalties

    The IRS properly penalized a janitorial services company for failing to provide employees with healthcare coverage under the Affordable Care Act, the U.S. government said, urging the Fifth Circuit to reverse a Texas federal court ruling that voided regulations promulgating the penalties.

  • December 09, 2025

    IRS Provides Guidance On Health Savings Account Expansion

    The IRS provided guidance Tuesday on new tax benefits for Health Savings Account participants, including a provision making bronze and catastrophic plans available through the Affordable Care Act marketplace HSA-compatible, even if they don't meet the definition of a high-deductible health plan.

Expert Analysis

  • Painting Makes Me A Better Lawyer

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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
    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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.

  • How Hyperlinks Are Changing E-Discovery Responsibilities

    Author Photo

    A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.

  • Preserving Refunds As Tariffs Await Supreme Court Weigh-In

    Author Photo

    In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.