Federal

  • November 05, 2025

    Ex-Mashpee Tribal Leader Gets 3.5 Years For Casino Bribes

    The former chair of the Mashpee Wampanoag Tribe on Wednesday was sentenced to a 42-month prison term for orchestrating a bribery scheme tied to the tribe's $1 billion casino project, as a Massachusetts federal judge chastised him for characterizing his yearslong conduct as "mistakes."

  • November 05, 2025

    Fed. Circ. Skeptical Of Family Trusts' Tax Fraud Case

    The Federal Circuit seemed skeptical Wednesday of an $80 million tax challenge by a group of family trusts that claimed they were unfairly stuck with tax liabilities after being duped into selling assets to a fraudster who then engaged in abusive tax shelter transactions behind their backs.

  • November 05, 2025

    Justices Skeptical About Trump's Emergency Tariff Authority

    Several U.S. Supreme Court justices asked the government to defend why well-established judicial doctrines shouldn't limit President Donald Trump's tariffs imposed under the International Emergency Economic Powers Act during oral arguments Wednesday, casting doubt on whether they believe the law provides that kind of authority.

  • November 05, 2025

    IRS Provides Penalty Relief For 2025 Tips, OT Reporting

    The Internal Revenue Service will treat the 2025 tax year as a transition period for enforcement and administration of the information reporting requirements for the new deductions for tips and overtime, according to guidance released Wednesday.

  • November 04, 2025

    Malawi Asks Judge To Undo Halt Of Gem Export Tax Probe

    Malawi asked a Washington federal judge to reconsider his recent decision to bar the country from pursuing discovery against a gemstone company that it alleges partnered with a mining outfit to dodge billions of dollars in taxes and export royalties.

  • November 04, 2025

    Former Eaton CFO Says Bond Investors Needed Reassurance

    Eaton Corp.'s former chief financial officer chronicled on Tuesday the company's efforts to finance its 2012 acquisition of Ireland-based Cooper Industries, describing an atmosphere of leery bond investors after the Great Recession of 2008, on the second day of the company's U.S. Tax Court trial.

  • November 04, 2025

    Tax Court Blocks Ariz. Salesman's Business Deductions

    The U.S. Tax Court on Tuesday rejected a series of business deductions claimed by an Arizona man working in outside sales and affirmed penalties against him for substantially understating his taxes.

  • November 04, 2025

    3M Ruling Highlights Loper Bright's Reach In Axing Tax Regs

    A U.S. Supreme Court ruling that gutted deference to agencies took center stage in the Eighth Circuit's recent decision that backed 3M's challenge to transfer pricing rules, signaling the strict statutory analysis that courts may now apply to tax regulations.

  • November 04, 2025

    Ga. Biz Asks Tax Court To Block IRS Easement Changes

    A Georgia company asked the U.S. Tax Court to reverse the Internal Revenue Service's adjustments to a claimed noncash charitable contribution for a $61 million conservation easement donation and rule that the company's filing was accurate, according to a petition released Tuesday.

  • November 04, 2025

    Developer Seeks To Restore Nixed $29M Easement Deduction

    The Internal Revenue Service failed to explain its rejection of a $29 million charitable tax deduction claim for an Alabama-based developer's 2016 conservation easement donation to a regional water district, the developer told the U.S. Tax Court as it challenged the decision.

  • November 04, 2025

    Tax Court Affirms Rejection Of Co.'s Settlement Offer

    The Internal Revenue Service did not abuse its discretion in rejecting an offer from a small business to settle its tax debt, the U.S. Tax Court said Tuesday, finding that the company never submitted financial documents the agency needed to accept the deal.

  • November 04, 2025

    Shutdown Leaves Tax Pros Few Options To Find Clients Relief

    The IRS has been beset by worsening delays in addressing taxpayers' cases, driven by widespread furloughs and a wave of retirements, and the ongoing government shutdown has compounded the issue by bringing federal district courts to a halt, leaving tax practitioners few options to seek relief for clients.

  • November 04, 2025

    DC Circ. Skeptical Of IRS Data Leaker's Qualms About Judge

    The D.C. Circuit seemed unlikely Tuesday to grant a request for resentencing by an IRS contractor serving prison time for leaking the tax returns of President Donald Trump and others to the media, suggesting his judge did nothing wrong in giving him the maximum term.

  • November 03, 2025

    Eaton Debt Analysis Must Trace Distinct Steps, Tax Court Told

    An attorney for Eaton Corp. told the U.S. Tax Court on Monday that the interest rates and guarantee fees the company paid to its newly formed Irish parent in 2012 must be analyzed as a set of distinct steps, beginning with determining a standalone credit rating for the U.S. company — an analysis a government attorney said was "needlessly elaborate."

  • November 03, 2025

    4 Ways Justices' Jarkesy Ruling Could Affect Tax Controversy

    As lower courts have begun to weigh the U.S. Supreme Court’s 2024 ruling that the SEC’s imposition of civil penalties without a jury trial was unconstitutional, attorneys say the decision could reshape tax disputes and potentially force the IRS to reconsider its approach to enforcement. Here, Law360 examines potential ways the Jarkesy precedent could influence tax controversy.

  • November 03, 2025

    'No Basis In Reality' In $10M Easement Claim, Tax Court Says

    A U.S. Tax Court judge rejected a partnership's claim that its donation of a conservation easement over 200 acres in Georgia was worth a $10 million tax deduction, saying in an opinion Monday that it "has no basis in reality."

  • November 03, 2025

    2 Doctrines Likely To Direct Justices' Review Of Trump Tariffs

    When the U.S. Supreme Court hears oral arguments Wednesday over whether President Donald Trump can impose tariffs under the International Emergency Economic Powers Act, it will likely test two doctrines the justices have recently considered: the major questions and nondelegation doctrines.

  • November 03, 2025

    Tribes Push Supreme Court To Overturn Okla. Tax Ruling

    The Oklahoma Supreme Court incorrectly ruled that a member of the Muscogee Creek Nation owes Oklahoma income tax, groups representing Native American tribes told the U.S. Supreme Court, asking the justices to hear the case and reverse the ruling.

  • November 03, 2025

    Veteran Tax Controversy Atty Moves Team To Kostelanetz

    A longtime New Jersey tax attorney and three of his associates have joined Kostelanetz LLP, the boutique tax firm announced Monday, saying it expected them to bolster its tax controversy practice and add to its commitment to volunteer work and legal education.

  • October 31, 2025

    Int'l Tax In October: Deal With China, Halt To Canada Talks

    A tentative deal to reduce American tariffs on Chinese goods, ruptured trade talks between the U.S. and Canada, court defeats for the Danish and U.S. tax administrations and an end to the European Union's plan for a financial transaction tax topped the list of international tax news in October. Here, Law360 looks at the biggest developments from the past month.

  • October 31, 2025

    Twin Peaks Lender Says Developer Defaulted On $12M Loan

    A Florida franchisee group is suing a developer in state court over a $12 million loan to build two Twin Peaks restaurants in an EB-5 visa program, alleging the developer defaulted on the note and then told the IRS that it converted the loan into equity interest.  

  • October 31, 2025

    Up Next At High Court: Tariffs, Fugitives & Contractor Liability

    The U.S. Supreme Court will begin its November oral argument session Monday, during which the justices will consider President Donald Trump's authority to impose tariffs on foreign countries under an emergency statute, whether military contractors can be held liable for alleged breaches of contracts in war zones, and if there are time limits for litigants who want to vacate a void judgment. Here, Law360 breaks down the week's oral arguments.

  • October 31, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included the continued monthslong slide in applicable federal rates for income tax purposes.

  • October 31, 2025

    Taxation With Representation: Skadden, Davis Polk

    In this week's Taxation With Representation, American Water Works Co. and Essential Utilities announce a merger, semiconductor companies Skyworks and Qorvo combine to create an industry giant, and Terex Corp. and REV Group team up to form a specialty equipment manufacturer.

  • October 31, 2025

    Ruling Dispute In Limbo As 6th Circ. Rebuffs Shutdown Pause

    The Sixth Circuit denied a federal government attorney's request to pause a closely watched case about a U.S. Tax Court filing deadline after he told the court he was barred from working during the shutdown, leaving his plan to request a rehearing in limbo.

Expert Analysis

  • Adapting To Private Practice: From US Rep. To Boutique Firm

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    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.

  • IRS Should Work With Industry On Microcaptive Regs

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    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.

  • CARES Act Fraud Enforcement Is Unlikely To Slow Down

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    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.

  • Spinoff Transaction Considerations For Biotech M&A

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    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.

  • Senate's 41% Litigation Finance Tax Would Hurt Legal System

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    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.

  • Drawbacks For Taxpayers From Justices' Levy Dispute Ruling

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    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.

  • How Energy Cos. Can Prepare For Potential Tax Credit Cuts

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    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.

  • DOJ Has Deep Toolbox For Corporate Immigration Violations

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    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.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    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.

  • Del. Dispatch: General Partner Discretion In Valuing Incentives

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    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.

  • Move Beyond Surface-Level Edits To Master Legal Writing

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    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.

  • 9th Circ. Has Muddied Waters Of Article III Pleading Standard

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    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.

  • Steps For Universities To Pass Tax-Exempt Test Amid Scrutiny

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    After decades of a quiet governmental acceptance of tax-exempt status, universities are facing unprecedented and public pressure to defend themselves, and must consider how to protect this valuable status, say attorneys at Eversheds Sutherland.

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