Federal

  • October 14, 2025

    Floridian Must Pay $1.6M After Default Judgment In FBAR Suit

    A tax preparer is on the hook for $1.6 million in penalties for foreign bank accounts that he tried to conceal, a Florida federal court found in a default judgment after he failed to respond to the U.S. government's suit.

  • October 14, 2025

    High Court Says Blackfeet Members Can't Join Tariff Dispute

    The U.S. Supreme Court denied a bid by members of the Blackfeet Nation to join its review of suits challenging the legality of President Donald Trump's emergency tariffs, who had argued that their inclusion in the dispute is crucial to protect Indigenous rights under federal law.

  • October 14, 2025

    Miss. Partnership Challenges $89M Nixed Easement Deduction

    A Mississippi partnership is entitled to an $89 million tax deduction for donating a conservation easement that protected land that could have been used for mining, despite the IRS' claim that the partnership failed to prove the gift's value, the partnership told the U.S. Tax Court.

  • October 10, 2025

    The Tax Angle: IRS Leadership Changes Amid Gov't Shutdown

    The federal government shutdown doesn't appear any closer to being resolved on Capitol Hill, but that hasn't stopped the U.S. Treasury Department from pushing ahead with a dizzying amount of changes in the Internal Revenue Service's top leadership. Here's a rundown of changes at the IRS in the past week.

  • October 10, 2025

    Tax Court Told IRS Miscalculated $21M Bill In Trust Dispute

    The Internal Revenue Service made erroneous calculations regarding an Arizona partnership's capital gains and assets related to partnership interests transferred to trusts, the partnership told the U.S. Tax Court as it challenged a $21 million tax bill.

  • October 10, 2025

    IRS Generally Provided Courteous Phone Service, TIGTA Says

    Limited testing of the Internal Revenue Service's telephone calls showed that agency representatives were generally courteous and professional when assisting taxpayers, but there are some areas where the IRS can improve, according to a Treasury Inspector General for Tax Administration report released Friday.

  • October 10, 2025

    Taxation With Representation: Sullivan, MoFo, Freshfields

    In this week's Taxation With Representation, Fifth Third Bancorp acquires Comerica in an all-stock deal, Qualtrics buys experience analytics firm Press Ganey Forsta, and SoftBank buys ABB's robotics division.

  • October 10, 2025

    Express Scripts Owed Trial In $43M Tax Row, 8th Circ. Told

    Express Scripts is entitled to a trial in its $43 million case seeking a tax refund for producing its own software in the U.S., the company told the Eighth Circuit, saying a lower court wrongly made an early decision that "glossed over" the facts of a complex case.

  • October 10, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included the withdrawal of a pair of proposed regulations for a narrow set of tax-free corporate separation deals known as spinoffs and a multiyear reporting regime for those transactions.

  • October 10, 2025

    Baker Botts Adds 2 Tax Pros From Venable In San Francisco

    Baker Botts LLP is expanding its West Coast transactional team, bringing in a pair of Venable LLP tax attorneys as partners in its San Francisco office.

  • October 09, 2025

    Hospice Co. Can't Get $450K In Deductions, Tax Court Affirms

    A California-based hospice company was correctly denied $450,000 in tax deductions, the U.S. Tax Court decided Thursday, saying most of the tax breaks were not substantiated as required.

  • October 09, 2025

    GOP Sen. Joins Dems On Bill To Nix Trump's Global Tariffs

    Several Senate Democrats and one Republican introduced legislation Thursday to eliminate the national emergency associated with President Donald Trump's so-called reciprocal tariff regime.

  • October 09, 2025

    IRS Sets Inflation-Adjusted Rates For Qualified Biz Income

    The IRS adjusted a bevy of tax provisions for 2026 in response to the passage of this summer's budget reconciliation bill, including the maximum capital gains rate and the qualified business income deduction.

  • October 09, 2025

    Bulgarian Says US Delay On Sanctions Decision Harming Him

    A Bulgarian businessman whose U.S. assets were frozen after the federal government accused him of bribery and tax evasion asked a D.C. federal court to force the U.S. to rule on his administrative challenge to the allegations, saying a delay has hurt his reputation and livelihood.

  • October 08, 2025

    Trump Tariffs Unconstitutional, Watchdog Tells Justices

    Either President Donald Trump doesn't have authority to impose tariffs under the International Emergency Economic Powers Act, or the law is unconstitutional, the nonprofit group Consumer Watchdog told the U.S. Supreme Court Wednesday, urging the justices to affirm lower court rulings deeming those measures unlawful.

  • October 08, 2025

    3rd Time's The Charm? The Tax Court's Odyssey In Medtronic

    A U.S. Tax Court judge has been sent back to the drawing board once again in the long-running transfer pricing litigation brought by Medtronic, raising questions about how much weight the court must give to IRS transfer pricing regulations and how much authority it has to go its own way.

  • October 08, 2025

    Senate Tax Panel Advances IRS Chief Counsel Nomination

    The Senate Finance Committee approved President Donald Trump's nomination of a Sullivan & Cromwell attorney to be general counsel of the Internal Revenue Service, the nearly party-line vote Wednesday setting up the nomination for a vote by the full Senate.

  • October 08, 2025

    Tax Court Upholds Lien Notice Against Health Co.

    The IRS didn't abuse its discretion when it sustained a federal tax lien notice against a health company for unpaid income and employment taxes, the U.S. Tax Court ruled Wednesday, saying the company didn't file documents, including tax returns, needed to challenge the notice.

  • October 08, 2025

    IRS Issued Tax Notices On Time, Tax Court Says

    The Internal Revenue Service issued notices of tax deficiency related to a man's partnership on time, the U.S. Tax Court ruled Wednesday, saying the agency made the notifications within a year of the conclusion of litigation over the affected items.

  • October 08, 2025

    IRS Stops Most Operations Due To Federal Budget Impasse

    The Internal Revenue Service has temporarily halted most of its operations, furloughed workers and ended paid leave for the affected employees as Congress remains deadlocked over federal appropriations legislation to fund the government, the agency's acting human resources officer said Wednesday.

  • October 08, 2025

    Gov't Resists Prison Delay For Lobbyist Who Evaded Tax

    A Miami lobbyist who was sentenced to prison for evading more than $1 million in taxes should not be allowed to delay the start of his term, the U.S. told a Florida federal court, saying the medical injection he argues he should take at home is available in prison.

  • October 08, 2025

    Denver Attorney Returns To Reed Smith State Tax Team

    Reed Smith is expanding its tax practice with the return of an experienced attorney, now based in Denver, with multistate experience in the full spectrum of tax issues.

  • October 07, 2025

    11th Circ. Wary Of IRS Procedure In FBAR Penalty Appeal

    An Eleventh Circuit panel Tuesday appeared concerned about IRS procedures that could keep a man from recouping $419,000 he paid to resolve his failure to disclose funds held in foreign bank accounts as he appeals a district court determination that he actually owes $2.2 million.

  • October 07, 2025

    Goldstein's $968K Border Cash Claim To Be Admitted At Trial

    A Maryland federal jury will hear claims from prosecutors that SCOTUSblog publisher Tom Goldstein told Dulles International Airport border guards that the $968,000 in cash he brought into the country in 2018 had been gambling winnings, after a judge shot down his efforts to suppress his alleged statements Tuesday.

  • October 07, 2025

    Simpson Thacher Atty On Making New REIT Blueprints

    The real estate investment landscape has changed dramatically in recent years, as alternative asset managers — and their counsel — have pioneered ways to tap into new sources of capital. Simpson Thacher partner Benjamin Wells spoke to Law360 about the changes he's seen, how to navigate regulatory shifts, and how real estate investment trusts may continue to reinvent themselves.

Expert Analysis

  • How Trucking Cos. Can Keep Rolling Under Tariff Burdens

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    Recent Trump administration tariffs present major challenges for the transportation and logistics sector — and, in particular, trucking — but providers who focus on operational efficiency, cost control, customer relationships, creative contract structures and unique offerings will stand out from the competition, say attorneys at Benesch.

  • Tariff Strategies For The US Renewable Energy Sector

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    The Trump administration's tariff actions over the last few months are challenging for the renewable energy industry — but there are strategies for contending with the uncertainty, including diversifying supply chains, seeking certification about equipment origins, and adding tariff-related language to supply contracts and offtake agreements, say attorneys at Sheppard Mullin.

  • Ch. 7 Marshaling Ruling Rests On Shaky Legal Grounds

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    In its recent holding in a Chapter 7 bankruptcy case that marshaling may not be applied against the IRS, a Texas federal court misapplied a bankruptcy code section and case law, leaving a draconian decision that could limit the scope of a powerful equitable estate tool, says Brian Shaw at Cozen O'Connor.

  • 3 Tax Issues Manufacturers Should Watch In 2025 Budget Bill

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    As Congress works toward a budget reconciliation bill, manufacturing companies should keep a keen eye on proposals to change bonus depreciation, the qualified business income deduction and energy tax credits, which could have a significant impact on capital-intensive industries, say attorneys at Frost Brown Todd.

  • $38M Law Firm Settlement Highlights 'Unworthy Client' Perils

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    A recent settlement of claims against law firm Eckert Seamans for allegedly abetting a Ponzi scheme underscores the continuing threat of clients who seek to exploit their lawyers in perpetrating fraud, and the critical importance of preemptive measures to avoid these clients, say attorneys at Lockton Companies.

  • Jurisdictional Issues At Play In 9th Circ.'s FCA Trade Case

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    A decision by the Ninth Circuit in Island Industries v. Sigma Corp. could result in the U.S. Court of International Trade’s exclusive jurisdiction over trade-related FCA cases, a big shift in the enforcement landscape just as tariffs take center stage in trade policy, say attorneys at Haynes Boone.

  • Evolving Federal Rules Pose Further Obstacles To NY LLC Act

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    Following the Financial Crimes Enforcement Network's recent changes to beneficial ownership information reporting under the federal Corporate Transparency Act — dramatically reducing the number of companies required to make disclosures — the utility of New York's LLC Transparency Act becomes less apparent, say attorneys at Pillsbury.

  • Alternative Business Structures Raise Ethics Questions

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    The new KPMG law firm, launched in Arizona following that state's repeal of the prohibition on fee sharing with nonlawyers, raises a number of important practice questions, both for the firm and those law firms seeking to partner with it, says Deborah Winokur at Cozen O’Connor.

  • The IRS Shouldn't Go To War Over Harvard's Tax Exemption

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    If the Internal Revenue Service revokes Harvard's tax-exempt status for violating established public policy — a position unsupported by currently available information — the precedent set by surviving the inevitable court challenge could undercut the autonomy and distinctiveness of the charitable sector, says Johnny Rex Buckles at Houston Law Center.

  • Mitigating Import Risks Around Southeast Asian Solar Cells

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    The U.S. Department of Commerce's recent final determinations in its antidumping and countervailing duty investigations into solar cells produced in certain Southeast Asian countries make it important for U.S. purchasers to consider risk mitigation strategies, including modifying supply chains and contractually assigning import responsibilities, say attorneys at Morgan Lewis.

  • Reassessing Corporate Separateness After Explosion Of LLCs

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    Following the dramatic increase of limited liability companies in the U.S., the Corporate Transparency Act's enactment and the Trump administration's subsequent narrowing of that law, it's worth revisiting the underlying legal principles that govern shell companies in order to remedy the problems that initially motivated the CTA, says Jeff Newton at Omni Bridgeway.

  • Crisis Management Lessons From The Parenting Playbook

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    The parenting skills we use to help our kids through challenges — like rehearsing for stressful situations, modeling confidence and taking time to reset our emotions — can also teach us the fundamentals of leading clients through a corporate crisis, say Deborah Solmor at the Wisconsin Alumni Research Foundation and Cara Peterman at Alston & Bird.

  • Immunity Waiver Ruling A Setback For Ch. 7 Trustees

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    While governmental units should welcome the U.S. Supreme Court's recent decision in U.S. v. Miller restricting the reach of the Bankruptcy Code's sovereign immunity waiver, Chapter 7 trustees now have a limited ability to maximize bankruptcy estates, says Dan Prieto at Jones Day.

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