Federal
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December 15, 2025
2026 To Open With Mixed Applicable Federal Rate Bounceback
Some of the applicable federal rates for income tax purposes will finally increase in January, the Internal Revenue Service said Monday, though others will carry a now six-month slide into 2026.
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December 15, 2025
Fed. Court Asked To Block IRS' Microcaptive Reporting Rule
A Texas federal court should vacate an IRS rule aimed at flagging potential tax avoidance by requiring companies to disclose information about their microcaptive insurance transactions because it undermines Congress' authority, according to a Texas plastics company and its microcaptive adviser.
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December 15, 2025
IRS Updates Corp. Bond Monthly Yield Curve For December
The Internal Revenue Service on Monday updated the corporate bond monthly yield curve used in calculations for defined benefit plans for December, as well as corresponding segment rates and the interest rate for 30-year U.S. Treasury Department securities.
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December 15, 2025
Employee-Related Charges Against Goldstein Are Tossed
A Maryland federal judge has dismissed several charges against SCOTUSblog founder Tom Goldstein related to employees at his law firm, agreeing that prosecutors had failed to establish a clear rule for determining whether employees are legitimate for tax purposes.
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December 15, 2025
IRS Urged To Boost Oversight Of Puerto Rican Tax Breaks
The Internal Revenue Service needs to implement stronger oversight of tax incentives available to Puerto Rico residents who receive federal income tax exemptions if they meet certain requirements, according to a U.S. Government Accountability Office report.
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December 15, 2025
Former Montana Insurer Wants Income Exclusion
A Montana insurance company that dissolved in 2023 is challenging the IRS' determination that transactions it engaged in with an entity on the Turks and Caicos Islands didn't actually involve insurance and therefore aren't deductible for 2021.
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December 15, 2025
Supreme Court Declines Cannabis Ban Review
The U.S. Supreme Court on Monday declined to hear a case challenging the federal marijuana ban, leaving in place a high court precedent that has governed cannabis policy for 20 years.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
Expert Analysis
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Adapting To Private Practice: From US Rep. To Boutique Firm
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.
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IRS Should Work With Industry On Microcaptive Regs
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.
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CARES Act Fraud Enforcement Is Unlikely To Slow Down
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.
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Spinoff Transaction Considerations For Biotech M&A
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.
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Senate's 41% Litigation Finance Tax Would Hurt Legal System
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.
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Drawbacks For Taxpayers From Justices' Levy Dispute Ruling
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.
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How Energy Cos. Can Prepare For Potential Tax Credit Cuts
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.
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DOJ Has Deep Toolbox For Corporate Immigration Violations
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.
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Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs
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.
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Del. Dispatch: General Partner Discretion In Valuing Incentives
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.
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Move Beyond Surface-Level Edits To Master Legal Writing
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.
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9th Circ. Has Muddied Waters Of Article III Pleading Standard
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.
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Steps For Universities To Pass Tax-Exempt Test Amid Scrutiny
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.