Federal
-
September 19, 2025
Bills Would End Emergencies For Tariffs On Brazil, Canada
A national emergency underpinning U.S. tariffs imposed on Canada and another one justifying most American tariffs on Brazil would be ended under a pair of resolutions introduced with bipartisan support by Sen. Tim Kaine, D-Va.
-
September 19, 2025
$1M FBAR Penalty Without Jury Unconstitutional, Judge Says
A woman who faced more than $1 million in civil penalties for failing to report offshore bank accounts to the IRS is off the hook, as a Texas federal court ruled Friday that the federal government violated her constitutional right to a jury trial.
-
September 19, 2025
Cayman Hedge Fund Takes $100M Tax Dispute To 3rd Circ.
A Cayman Islands hedge fund urged the Third Circuit to revive its challenge to a $100 million tax bill for earning money in connection with a U.S. business, saying the business did not exist, contrary to claims by the IRS and the U.S. Tax Court.
-
September 19, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, consisted of just one item, the removal of a proposed rule that would have allowed the U.S. State Department to share taxpayer return information related to the revocation or denial of passports for those with serious tax debts.
-
September 19, 2025
IRS Proposes Qualifying Occupations For Tips Deduction
Nearly 70 occupations, including bartenders, food preparation workers, musicians, electricians and social media influencers, were included in the proposed list of occupations subject to President Donald Trump's policy of no tax on tips, the Internal Revenue Service said Friday.
-
September 18, 2025
IRS Discloses Details On ICE Agreement In Data Sharing Row
The U.S. government disclosed additional details Thursday on the agreement between the IRS and immigration enforcement authorities to share confidential tax return information, including who had necessary permissions to access the disclosures, following a D.C. federal judge's order in a lawsuit seeking to end the interagency data sharing.
-
September 18, 2025
Extending ACA Subsidies Would Cost $350M, CBO Says
Extending pandemic-era enhancements to premium tax credits that subsidize marketplace health plans would increase the deficit by $350 million by 2035, though it would also increase the number of people with health insurance by 3.8 million, the Congressional Budget Office said Thursday.
-
September 18, 2025
Halliburton Can Contest Rule On Settlement Tax Deductions
Halliburton can continue challenging the legality of a U.S. Treasury Department regulation that denies tax deductions for settlement agreements, a Texas federal judge ruled, refusing to toss the company's claims connected to the deductibility of a $35 million payment to Nigeria's government.
-
September 18, 2025
5th Circ. Won't Rehear Crypto Exec's IRS Summons Case
The Fifth Circuit stood by its decision not to quash an IRS summons for a cryptocurrency executive's bank records, rejecting his request to reconsider its finding that he must wait until the federal government decides whether to bring legal proceedings against him before challenging a lower court's ruling.
-
September 18, 2025
IRS Leaked Private Info To News Outlets, Agency Official Says
An IRS official serving as head of the agency's Large Business and International Division who was placed on leave accused the agency of unlawfully leaking information on her employment status to news outlets including Fox News and Bloomberg, according to a complaint filed Thursday in D.C. federal court.
-
September 17, 2025
Tribal Members Tell 9th Circ. Tariff Suit Belongs In Fed. Court
Counsel for members of the Blackfeet Nation tribe told the Ninth Circuit on Wednesday their suit challenging President Donald Trump's emergency tariffs should stay in federal district courts, where constitutional and congressional claims over tribal commerce must be heard.
-
September 17, 2025
Democrats Push Wealth Tax Targeting Billionaires' Assets
Billionaires would pay higher taxes on their unrealized gains from property, stocks and other valuable assets under legislation reintroduced Wednesday by Senate Finance Committee ranking member Ron Wyden and other congressional Democrats.
-
September 17, 2025
House Panel OKs Bill To Expand Tax Court's Subpoena Power
The House Ways and Means Committee unanimously approved legislation Wednesday that would grant the U.S. Tax Court the power to issue subpoenas without connection to a scheduled hearing and apply mandatory recusal rules to its judges.
-
September 17, 2025
IRS-ICE Pact Allows For Mass Tax Data Swaps, DC Circ. Told
An information sharing agreement between the IRS and immigration enforcement agencies allows for disclosure of confidential tax information on a mass scale, as evidenced by an IRS official's declaration in a taxpayer group's suit, immigration advocacy groups challenging the agreement told the D.C. Circuit on Wednesday.
-
September 17, 2025
Partners Barred From Fighting Deal In $54M Easement Suit
Dozens of investment partners were barred from challenging a settlement with the IRS over their disputed $54 million conservation easement deduction under a U.S. Tax Court ruling Wednesday that found they waited until the last minute and didn't show why they should be allowed to participate in proceedings.
-
September 17, 2025
Spencer Fane Adds Corporate, RE Attys In The Midwest
Spencer Fane LLP announced the addition of two new attorneys in the Midwest this week — a partner joining its corporate and business transactions group and a counsel joining its real estate group.
-
September 17, 2025
11th Circ. Finds Couple On Hook For Penalty On Back Taxes
A couple who owed $1.7 million in back taxes is on the hook for a penalty after the Eleventh Circuit rejected their dual claims that an Internal Revenue Service supervisor failed to correctly approve the penalty and that U.S. Tax Court judges have unconstitutional job protections.
-
September 17, 2025
IRS Spent $40M On Outdated Computer Systems, TIGTA Says
A decade-old plan at the Internal Revenue Service to consolidate dozens of computer systems has made little progress, the Treasury Inspector General for Tax Administration said Wednesday, reporting that the agency spent nearly $40 million last year on maintaining outdated systems.
-
September 16, 2025
$300M Hyatt Rewards Tax Ruling Criticized By 7th Circ. Judge
A Seventh Circuit judge took issue Tuesday with a U.S. Tax Court's finding that Hyatt should report $300 million in rewards program fund revenue, saying the decision seemed to focus on a factor that was shot down by decades-old legal precedent.
-
September 16, 2025
Avalara Investors' Claims Pass Muster After 9th Circ. Revival
A Washington federal judge has allowed a proposed class action to proceed accusing tax software company Avalara Inc. of misleading investors ahead of an $8.4 billion deal to take the company private, but said the suit failed to adequately allege negligence by individual board members, giving investors one week to amend those claims.
-
September 16, 2025
Tax-Exempt Hospitals Face Financial Duress, Panel Hears
The nation's nonprofit hospitals are under growing financial stress due to cutbacks in federal funding, an aging population and unnecessary spending on programs unrelated to providing healthcare to their communities, industry experts told lawmakers Tuesday at a congressional hearing.
-
September 16, 2025
Tax Court's Petition Deadline Is Flexible, 1st Circ. Told
A taxpayer advocacy group urged the First Circuit on Tuesday to become the fourth appellate court to find that the deadline for filing a petition in the U.S. Tax Court can be extended to create fairness, arguing that the deadline is not a jurisdictional bar.
-
September 16, 2025
Loeb & Loeb Opens DC-Area Office With Ex-Reed Smith Attys
Loeb & Loeb LLP announced Tuesday the opening of a new office in Virginia, along with the arrival of an eight-person private client and tax controversy staff formerly of Reed Smith LLP.
-
September 16, 2025
House Panel To Weigh Greater Subpoena Power For Tax Court
House lawmakers are scheduled to consider a bill Wednesday that would grant the U.S. Tax Court the power to issue subpoenas without connection to a scheduled hearing and would apply mandatory recusal rules to its judges, the Joint Committee on Taxation reported Tuesday.
-
September 16, 2025
Brewer Denounces Gov't Home Distilling Ban In 6th Circ.
A brewery owner challenging the U.S. tax code's ban on home distilleries criticized the government's claim that he isn't hurt enough by the prohibition to warrant a suit, telling the Sixth Circuit that the ban prevents him from making whiskey at home and renders him ineligible for a distilling permit.
Expert Analysis
-
Unpacking The New Opportunity Zone Tax Incentive Program
The One Big Beautiful Bill Act brought several improvements to the opportunity zone tax incentive program that should boost investments in qualified funds, including making it permanent, increasing federal income tax benefits in rural areas, redesignating the qualified zones, and requiring more in-depth reporting, says Marc Schultz at Snell & Wilmer.
-
Trump Tax Law's Most Impactful Energy Changes
The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.
-
Adapting To Private Practice: From Texas AUSA To BigLaw
As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.
-
Advice For 1st-Gen Lawyers Entering The Legal Profession
Nikki Hurtado at The Ferraro Law Firm tells her story of being a first-generation lawyer and how others who begin their professional journeys without the benefit of playbooks handed down by relatives can turn this disadvantage into their greatest strength.
-
UK's 1st ICSID Claim Shows Bilateral Investment Treaty Reach
For the first time, the U.K. is facing a claim under the International Centre for Settlement of Investment Disputes Convention, underscoring the broader reality that treaty protections are no longer confined to investors in emerging markets, says Philipp Kurek at Signature Litigation.
-
Trump Tax Law's Most Impactful Corp. And Individual Changes
The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.
-
From Clerkship To Law Firm: 5 Transition Tips For Associates
Excerpt from Practical Guidance
Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.
-
Trump Tax Law's Most Consequential International Changes
The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.
-
Associates Can Earn Credibility By Investing In Relationships
As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.
-
Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling
The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.
-
What 2 Profs Noticed As Transactional Law Students Used AI
After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.
-
BigLaw Settlements Should Not Spur Ethics Deregulation
A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.
-
5 Ways Lawyers Can Earn Back The Public's Trust
Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.