Federal

  • October 24, 2025

    Popular TaxProf Blog Returns After Shutdown

    After Typepad's decision to shut down last month, the Association of American Law Schools is giving new life to one of the defunct hosted blogging platform's popular legal blogs.

  • October 24, 2025

    Taxation With Representation: Latham, Wachtell, Gibson Dunn

    In this week's Taxation With Representation, Meta announces a joint venture with Blue Owl Capital to fund the development of a data center campus in Louisiana, private equity giants acquire medical technology company Hologic Inc., and National Fuel Gas Co. buys CenterPoint Energy Inc.'s Ohio natural gas utility business.

  • October 24, 2025

    Partnership Fights For $15M Easement Deduction In Tax Court

    The Internal Revenue Service didn't explain its determinations and therefore violated administrative law when it denied an Alabama partnership a $14.8 million deduction for donating a conservation easement in 2020, the partnership told the U.S. Tax Court.

  • October 23, 2025

    Legislation May Fix Tax Court Jurisdiction Feud, Judge Says

    Senate legislation to expand the U.S. Tax Court's authority to order refunds and credits in collection cases could settle a long-running dispute revived by the U.S. Supreme Court's decision to limit the tax tribunal's jurisdiction, a judge said Thursday.

  • October 23, 2025

    Fed. Circ. Affirms No Tax Refunds For Retired United Pilots

    United Airlines pilots who said they overpaid payroll taxes because of the early termination of their retirement plan in the company's bankruptcy can't get partial refunds, the Federal Circuit affirmed Thursday, saying procedural issues doomed their case.

  • October 23, 2025

    Tech Co. Goes After $1.4M IRS Adjustments In Tax Court

    An internet platform company that helps video game developers launch their games challenged $1.4 million in IRS adjustments to its tax return in the U.S. Tax Court, alleging the agency incorrectly told the company to report its software development costs as capital expenses.

  • October 23, 2025

    US Oil Cos. Pay More Tax Abroad Than At Home, Report Says

    American oil and gas companies with foreign extraction operations paid more than 80% of their total taxes abroad in recent years despite producing more oil and gas in the U.S. than everywhere else combined, a corporate transparency group said Thursday.

  • October 23, 2025

    IRS To Float Sourcing Rules For Certain Securities Loans

    The Internal Revenue Service said Thursday it intends to propose regulations that would have it look to the borrower of certain securities, rather than the lender, when determining whether related payments are sourced from the United States.

  • October 23, 2025

    IRS FAQs Include $20K Payment Reporting Requirement

    The Internal Revenue Service updated its FAQs on Thursday to include the budget reconciliation bill's reversal of a law requiring peer-to-peer payment platforms such as Venmo and PayPal to report aggregate payments of $600 or more.

  • October 23, 2025

    Court Won't Rethink 'Survivor' Winner's $3M Tax Bill

    A Rhode Island federal judge won't reconsider his opinion that the first winner of reality show "Survivor" must pay $3.3 million in taxes, maintaining that it is unclear whether the federal government can take his sister's property to pay down the debt.

  • October 23, 2025

    Eaton To Defend Interest Rates, Fees Paid After 2012 Inversion

    Eaton is preparing to defend the interest rates and guarantee fees paid by entities in the U.S. to their newly formed Irish parent after the company's 2012 acquisition and inversion at a U.S. Tax Court trial scheduled to start Nov. 3.

  • October 22, 2025

    Tax Co.'s Push To Escape Sex Harassment Verdict Falls Short

    An Idaho federal judge rejected a tax business's bid Wednesday to escape potential liability for a $111,000 sexual harassment verdict won by a worker who claimed that the tax company acquired her former employer so that her ex-boss could avoid paying out on her lawsuit.

  • October 22, 2025

    US Among Few Places With Amount B Rules, OECD Reports

    The U.S. is a significant exception to a swath of countries, including China, Japan and the U.K., that lack domestic rules allowing companies to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, the OECD reported Wednesday.

  • October 22, 2025

    Innocent Spouse Claim Is Barred, Tax Court Says

    The wife of a man who failed to report overseas income is on the hook for the couple's shared tax liabilities, the U.S. Tax Court ruled Wednesday, rejecting her request to be cleared under a provision protecting spouses who are unaware of a partner's dealings.

  • October 22, 2025

    Tax Court Judge Warns Against Unchecked AI Use In Filings

    A U.S. Tax Court judge cautioned attorneys Wednesday against relying on artificial intelligence to write filings without verifying the information it generates, saying recent "unfortunate incidents" have prompted the court to double down on accuracy in using such tools.

  • October 22, 2025

    IRS Releases FAQs For Employee Retention Credits

    The IRS issued answers Wednesday to a set of frequently asked questions related to the limitations for the fraud-riddled employee retention tax credit program that were implemented under the budget reconciliation law.

  • October 22, 2025

    'The Right Facts' Can Reduce Cos.' Tariff Impacts, Atty Says

    Multinational companies with U.S. distributors that typically bear fewer business risks and earn low profit margins may be able to mitigate the effect of U.S. tariffs on their business as a whole by having a foreign principal bear the tariff costs, an attorney said Wednesday.

  • October 22, 2025

    Belgian Gov't Looks To Overturn US Tax Data Transfer Ruling

    Belgium's data privacy watchdog was wrong to rule that the transfer of personal tax information to the U.S. breaks European Union law, the Belgian government told a Brussels court Wednesday, because the practice was established before the EU's data protection law took effect.

  • October 22, 2025

    Presidential Firing Limits Fight Builds At High Court

    The ousted U.S. Merit Systems Protection Board chair has encouraged the U.S. Supreme Court to include a caveat for "legislative courts" if it overturns precedent that empowers Congress to limit the president's authority to fire certain agency officials, but opponents of independent agencies want a clean break from the status quo. 

  • October 22, 2025

    Senate Sends IRS Clerical Error Correction Bill To Trump

    A bill that would allow the IRS to adjust tax assessments to correct mathematical or clerical errors is headed to President Donald Trump's desk for his signature after the Senate approved the legislation, a senator who co-sponsored a related bill said Wednesday.

  • October 22, 2025

    Trade Court OKs $235K Tax Bill On Korean Soju Imports

    South Korean alcoholic beverages were improperly classified upon entering the U.S., and U.S. Customs and Border Protection correctly calculated a nearly $235,000 bill in unpaid federal excise taxes plus interest, according to the U.S. Court of International Trade.

  • October 22, 2025

    Widow Not Liable For Husband's Tax Debt, 4th Circ. Told

    An 80-year-old widow whose husband was imprisoned after hiding more than $20 million from the IRS told the Fourth Circuit that he was "abusive and controlling" and that she shouldn't have to pay the millions of dollars they jointly owe, despite contrary claims by the government.

  • October 22, 2025

    Construction Co. Owner Hid Income, Tax Court Says

    A man who said he was a former officer of a California construction company was actually a 50% shareholder and failed to report income for 2016, including money diverted from a client to the purchase of a motor home, the U.S. Tax Court found.

  • October 21, 2025

    Nonprofits Face Pressure From GOP Tax Changes, Aides Say

    Nonprofit organizations, charities and universities face sweeping changes under the Republicans' 2025 tax overhaul, Capitol Hill staffers said Tuesday, pointing to higher taxes on executive pay and endowments alongside revamped limits and incentives for individuals and corporations claiming charitable deductions.

  • October 21, 2025

    Partnership Deadline To Dispute IRS Is Fixed, Tax Court Says

    A deadline to petition the U.S. Tax Court to challenge IRS adjustments to partnership returns is effectively fixed and cannot be extended, the court said Tuesday in a reviewed decision that denied an Alabama LLC's late bid to restore a $46 million deduction for donating to charity.

Expert Analysis

  • 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.

  • 7 Tips For Associates To Thrive In Hybrid Work Environments

    Excerpt from Practical Guidance
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    As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.

  • IRS Should Revise Overbroad Microcaptive Regs

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    Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.

  • Terraform Case May Be Bellwether For Crypto Enforcement

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    The prosecution of crypto company Terraform Labs and its CEO, Do Kwon, offers a unique test of the line between lawful and unlawful conduct in digital transactions, and the Trump administration’s posture toward the case will provide clues about its cryptocurrency enforcement agenda in the years to come, say attorneys at Brooks Pierce.

  • How Law Firms Can Counteract The Loneliness Epidemic

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    The legal industry is facing an urgent epidemic of loneliness, affecting lawyer well-being, productivity, retention and profitability, and law firm leaders should take concrete steps to encourage the development of genuine workplace connections, says Michelle Gomez at Littler and Gwen Mellor Romans at Herald Talent.

  • Texas Fraud Case Shows Dangers Of Faulty Crypto Reporting

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    The recent sentencing of a man who failed to properly report capital gains from bitcoin sales is a reminder that special attention must be given to the IRS' reporting requirements in order to stay out of the government's crosshairs, says Saverio Romeo at Fox Rothschild.

  • Potential Impacts Of IRS' $1M Affiliate Pay Deduction Cap

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    If finalized, a recent Internal Revenue Service proposal expanding Section 162(m) of the Internal Revenue Code to include the highly compensated employees of affiliates would make tracking which executives may be subject to the limit from year to year far more complex, say attorneys at Debevoise.

  • 5 Keys To Building Stronger Attorney-Client Relationships

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    Attorneys are often focused on being seen as the expert, but bonding with clients and prospects by sharing a few key personal details provides the basis for a caring, trusted and profoundly deeper business relationship, says Deb Feder at Feder Development.

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