Federal

  • April 29, 2025

    IRS Shouldn't Elect To Use OECD Pricing Method, AICPA Says

    The IRS shouldn't unilaterally apply the Organization for Economic Cooperation and Development's streamlined approach to price-related companies' baseline distribution and marketing costs and should give companies a wide berth to choose the approach, the American Institute of Certified Public Accountants told the agency.

  • April 28, 2025

    Court Urged To Reconsider Jurisdiction In Tribal Tariff Row

    Blackfeet Nation members are asking a Montana federal judge to reconsider an order to transfer their challenge against President Donald Trump's tariffs on imports from Canada and abroad to the U.S. Court of International Trade, saying the decision is based on the constitutional question of the Indian commerce clause.

  • April 28, 2025

    NC Dentist Acquitted Of $3M Fraud, Tax Evasion Charges

    A North Carolina dentist was acquitted of wire fraud and tax evasion charges on the fourth day of a federal jury trial in which prosecutors had alleged the dentist submitted false loan applications to the Small Business Administration and failed to pay income taxes.

  • April 28, 2025

    Feds Urged To Drop Crypto Mixer Charges After DOJ Memo

    Federal prosecutors are weighing whether to continue pursuing a criminal case against two executives of crypto mixing service Samourai Wallet in light of a recent U.S. Department of Justice memo limiting certain digital asset prosecutions.

  • April 28, 2025

    Tax Services Provider Andersen Files Confidential IPO Plans

    Tax and legal services provider Andersen Group Inc. said Monday it confidentially filed for an initial public offering, marking a first step toward going public amid market volatility that has largely frozen IPOs in recent weeks.

  • April 28, 2025

    Board Game Co., 11 Others Say Trump Tariffs Unconstitutional

    President Donald Trump's tariffs exceed the constitutional authority of the executive branch, argued 12 American companies, including a manufacturer of tabletop games that are printed in China, urging a federal court to halt them.

  • April 28, 2025

    Car Dealer Can't Duck Fines For Cash Reporting Failures

    The U.S. Tax Court upheld more than $118,000 in penalties Monday against an Arizona-based car dealership, rejecting its argument that third-party tax software errors were to blame for its failures to report cash transactions of over $10,000 for 2016.

  • April 28, 2025

    2nd Circ. Upholds Clinic Manager's Repeat Charges For Fraud

    A decision that allowed the federal government to reindict a health clinic manager for a Medicare and tax fraud scheme can stand, a Second Circuit panel found Monday, agreeing with the lower court that his offenses were serious enough to permit it.

  • April 28, 2025

    No Harm Shown Over DOGE Access To Tax Data, US Says

    The U.S. government asked a D.C. federal court to throw out four organizations' bid to keep the White House's Department of Government Efficiency from accessing confidential taxpayer data, saying their suit fails to show injury to the groups' members.

  • April 28, 2025

    Feds No Longer Want Convicted Ex-Ill. Speaker To Forfeit $3M

    The federal government has reversed course on a bid for former Illinois House Speaker Michael Madigan to forfeit more than $3 million in the wake of his partial conviction on public corruption, saying it stands by its legal arguments but was backing off as "a matter of discretion."

  • April 28, 2025

    Latham Advises REIT's $340M Stock Offering

    Retail-focused real estate investment trust Agree Realty Corp. signed a forward sale agreement in which the REIT made a more than $340 million public offering of 4.5 million shares of its common stock for the price of $75.70 apiece, in a deal guided by Latham & Watkins LLP, the law firm announced.

  • April 28, 2025

    Miami Tax Prep Owner Barred From Work For 3 Years

    A Miami tax preparation business and its owner are barred from doing any tax work for three years and must pay $446,000 in client fees to the government for preparing false returns the government claims caused a $500,000 tax loss, a Florida federal court said Monday.

  • April 28, 2025

    High Court Passes On Dell Worker's Income Tax Case

    The U.S. Supreme Court declined Monday to review a decision that nearly $300,000 in income earned by an employee of Dell Techologies Inc. is taxable, letting stand a Fifth Circuit ruling that additionally upheld a penalty against the man for making frivolous arguments.

  • April 25, 2025

    Judge Blocks Trump Order Limiting Fed. Worker Bargaining

    A Washington, D.C., federal judge on Friday blocked President Donald Trump's order last month seeking to end collective bargaining for workers at more than a dozen federal agencies with national security roles, two days after suggesting during oral arguments that Trump's order was retaliatory.

  • April 25, 2025

    Feds Say Tariff Fight Belongs In International Trade Court

    The Trump administration wants to litigate a challenge to its tariffs in a federal trade court, not the D.C. district court, arguing that the U.S. Court of International Trade is the only venue with jurisdiction to hear the case.

  • April 25, 2025

    Sen. Crapo Calls Exec Session For Commerce, Treasury Noms

    U.S. Senate Finance Committee Chairman Mike Crapo, R-Idaho, announced Friday that it will hold an executive session Tuesday to consider President Donald Trump's picks for roles at the U.S. Department of Commerce and U.S. Department of the Treasury.

  • April 25, 2025

    US Seeks To Block Refund For Captive Insurance Penalties

    A Pennsylvania federal court should reject a company's bid for an immediate penalty refund for operating what the IRS claimed is an abusive tax shelter through its microcaptive insurance program, the government argued Friday, saying the company is seeking protection in an unrelated U.S. Supreme Court ruling.

  • April 25, 2025

    IRS Says Docs In Captive Insurance Case Are Privileged

    The IRS defended its refusal to release information to a tax services company seeking audit records of its captive insurance program, telling a Texas federal court that the agency's redactions of the requested records are protected by attorney-client privilege and other exceptions to the Freedom of Information Act.

  • April 25, 2025

    Takeaways From Justices' Questioning In Tax Collection Suit

    The U.S. Supreme Court heard oral arguments this past week in a nearly 11-year-old case that could redefine taxpayers' challenges of Internal Revenue Service determinations to collect tax debts. Here, Law360 examines tax practitioners' key takeaways from the justices' remarks.

  • April 25, 2025

    Taxation With Representation: Dechert, Brown Rudnick

    In this week's Taxation With Representation, Boeing sells parts of its digital aviation solutions business to Thoma Bravo, Baker Tilly and Moss Adams join forces, Mobico sells its U.S. school bus business to I Squared Capital, and Apollo commits to a joint venture with Bullrock Energy Ventures.

  • April 25, 2025

    5 Issues Benefits Attys Want The Gov't To Shed Light On

    The first three months of President Donald Trump's administration have left lawyers who represent employers and benefit plans hungry for clarity on issues like cryptocurrency as a 401(k) investment and coverage for gender-affirming care. Here, Law360 looks at five areas where attorneys are hoping for guidance or regulations.

  • April 25, 2025

    No Weekly Internal Revenue Bulletin Articles For April 28

    The Internal Revenue Service's weekly bulletin, issued Friday, said there were no articles to be published for April 28.

  • April 24, 2025

    Union Challenges Treasury's Suit Over CBA Executive Order

    A National Treasury Employees Union affiliate urged a Kentucky federal judge Thursday not to find the U.S. Department of the Treasury can lawfully terminate its labor contracts with the national union, arguing the district court does not have jurisdiction and the agency can't request an advisory opinion.

  • April 24, 2025

    Gov't Stands By $1.7M In FBAR Penalties Against Texan

    Constitutional law does not stop the U.S. from imposing $1.7 million in penalties against a Texan for failure to report foreign bank accounts, the U.S. told a federal court in arguing against the "myriad" of arguments she has made to dismiss the case.

  • April 24, 2025

    Silicon Valley Bank Liquidators Fight $41M Bill In Tax Court

    The trust responsible for liquidating assets of the shuttered Silicon Valley Bank told the U.S. Tax Court that the IRS has wrongly charged the bank's operator more than $41 million in additional taxes by claiming it didn't substantiate losses and research activities in the years leading up to its bankruptcy.

Expert Analysis

  • Adapting To Private Practice: From Fed. Prosecutor To BigLaw

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    Making the jump from government to private practice is no small feat, but, based on my experience transitioning to a business-driven environment after 15 years as an assistant U.S. attorney, it can be incredibly rewarding and help you become a more versatile lawyer, says Michael Beckwith at Dickinson Wright.

  • Justices' False Statement Ruling Curbs Half-Truth Liability

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    The U.S. Supreme Court’s recent Thompson v. U.S. decision clarified that a federal statute used to prosecute false statements made to bank regulators only criminalizes outright falsehoods, narrowing prosecutors’ reach and providing defense counsel a stronger basis to challenge indictments of merely misleading statements, says Tamara de Silva at De Silva Law Offices.

  • Perfecting Security Interests In Renewable Energy Tax Credits

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    The ability to transfer renewable energy tax credits has created new opportunities for developers, investors and lenders, but it also raises important questions regarding when and how the security interests in these credits are perfected — questions that must be answered definitively to protect credit claims and transactions, says Harry Teichman at Stinson.

  • Firms Still Have Lateral Market Advantage, But Risks Persist

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    Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.

  • Making The Opportunity Zones Program Great At Last

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    As the opportunity zone program approaches its expiration, the Republican-led government could take specific steps to extend and improve the program, address its structural flaws, encourage broader participation and enable it to live up to its promised outcomes, say attorneys at Pillsbury.

  • We Must Allow Judges To Use Their Independent Judgment

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    As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.

  • Preparing For Tariffs On Canadian Power In The Northeast

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    The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.

  • Making The Case For Rest In The Legal Profession

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    For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.

  • Mitigating Tariff Risks For Healthcare In US And Canada

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    Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.

  • 4 Ways Women Attorneys Can Build A Legal Legacy

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    This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.

  • A Judge's Pointers For Adding Spice To Dry Legal Writing

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    U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.

  • Why NY May Want To Reconsider Its LLC Transparency Law

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    Against the backdrop of the myriad challenges to the federal Corporate Transparency Act, it may be prudent for New York to reconsider its adoption of the LLC Transparency Act, since it's unclear whether the Empire State's "baby-CTA" statute is still necessary or was passed prematurely, say attorneys at Pillsbury.

  • IRS Scrutiny May Underlie Move Away From NIL Collectives

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    The University of Colorado's January announcement that it was severing its partnership with a name, image and likeness collective is part of universities' recent push to move NIL activities in-house, seemingly motivated by tax implications and increased scrutiny by the Internal Revenue Service, say attorneys at Buchanan Ingersoll.

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