Federal

  • July 22, 2025

    IRS Workforce Has Nosedived 25% Since February

    More than 25,000 Internal Revenue Service employees have left since February, a 25% overall reduction in staff driven mostly by workers who took a downsizing deal allowing them to resign while still being paid, the Treasury Inspector General for Tax Administration said Tuesday.

  • July 22, 2025

    US Expatriations Over 1,000 Again In 2nd Quarter

    While about 200 fewer people expatriated from the U.S. in the second quarter of 2025 compared with the first quarter, the number still totaled above 1,000, the Internal Revenue Service said Tuesday.

  • July 21, 2025

    Tax-Lien Biz Atty Tells Jury He Didn't Seek To Dupe Lender

    Counsel for a former compliance lawyer accused of pilfering from a $20 million line of credit extended to his tax-lien investment firm told a Manhattan federal jury Monday that the defendant was "sloppy," but never intended fraud.

  • July 21, 2025

    9th Circ. Urged To Rethink Denial Of Bad Debt Deduction

    A business owner asked the Ninth Circuit to rethink its denial of his $86 million bad debt deduction, saying the court dismissed thousands of pages of exhibits in concluding that his debt arose from loans between his companies and was not actually worthless.

  • July 21, 2025

    Captive's Premium Payments Are Income, Tax Court Says

    A captive insurance company must recognize $782,000 it received in premium payments as income, the U.S. Tax Court said Monday in clarifying that shareholders in a California company cannot deduct their premium payments to the insurer because the arrangement was not really for insurance.

  • July 21, 2025

    Wis. Homeowners Lack Basis For Tax Burden Suit, Court Told

    A Wisconsin county, town and tribal school district pushed a federal court to throw out a suit by homeowners who claim the government entities have conspired to expand the Menominee Indian Tribe's holdings of tax-exempt land and increase taxpayers' burden, saying the homeowners lacked standing.

  • July 21, 2025

    Charitable Deduction Lacked Dates, Amounts, Tax Court Says

    A Washington state man was not entitled to deduct the value of his donations to charity because he did not provide receipts identifying the donated items and their values, the U.S. Tax Court ruled Monday.

  • July 21, 2025

    House Subcommittee Advances $2.8B IRS Funding Cut

    The Internal Revenue Service's funding would be cut by $2.8 billion for the 2026 fiscal year under legislation advanced Monday by a House Appropriations subcommittee.

  • July 21, 2025

    Rising Star: Davis Polk's Aliza Slansky

    Aliza Slansky of Davis Polk & Wardwell LLP is lead counsel in Sycamore Partners' $23 billion acquisition of Walgreens Boots Alliance and advised Missouri tech company Emerson on a series of multibillion-dollar sales, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 21, 2025

    Strict Construction Rules Could Gut Solar, Wind Credits

    The U.S. Treasury Department could severely weaken the availability of the solar and wind energy tax credits that were scaled back under Republicans' new budget law with upcoming guidance that may upend long-standing construction rules used to determine eligibility.

  • July 21, 2025

    Paul Hastings Boosts Tax Team In NY With Ex-Kirkland Atty

    Paul Hastings LLP announced Monday that a former Kirkland & Ellis LLP attorney is bringing her tax practice to its New York office in a move the firm says will bolster its ability to guide clients through complex deals like mergers, acquisitions and private equity transactions.

  • July 18, 2025

    Law360 Names 2025's Top Attorneys Under 40

    Law360 is pleased to announce the Rising Stars of 2025, our list of more than 150 attorneys under 40 whose legal accomplishments belie their age.

  • July 18, 2025

    Judge Demands Layoff Plans From Trump Administration

    A California federal judge on Friday ordered the Trump administration to hand over reorganization and reduction-in-force plans linked to an executive order directing layoffs at federal agencies, finding that the government's privilege claim was outweighed by the plaintiffs' need for the information to pursue their claims under the Administrative Procedure Act.

  • July 18, 2025

    Trade Legal Matters To Watch: Midyear Report

    Aggressive, sweeping tariff actions have defined the first six months of President Donald Trump's second term, altering the global trade environment in attempts to return manufacturing to the U.S. and reset trading deficits, but legal challenges to certain duties may obstruct Trump's long-term trade strategy in ongoing negotiations later this year.

  • July 18, 2025

    DC Circ. Affirms Toss Of Tax Pros' PTIN User Fee Challenge

    A D.C. federal court properly dismissed a lawsuit by tax return preparers challenging the IRS' process for issuing their special identification numbers, the D.C. Circuit ruled Friday, saying the suit violated rules against filing duplicate claims.

  • July 18, 2025

    IRS Offers Guidance On Use Of Transfer Pricing Exception

    Taxpayers can use an exception in the tax code for payments for services rendered by foreign related parties without applying a related U.S. Treasury Department regulation's provisions for transfer pricing purposes, the IRS Office of Chief Counsel said Friday.

  • July 18, 2025

    Trump Asks Supreme Court To Decline Early Tariff Challenge

    President Donald Trump's administration urged the U.S. Supreme Court to reject a request from Illinois-based toy makers to hear their challenge against the White House's global tariffs, arguing the justices should not "leapfrog" parallel proceedings in circuit courts.

  • July 18, 2025

    3 Key Budget Bill Issues Tax Pros Want IRS To Clarify Quickly

    The GOP's new tax overhaul is driving demand for guidance on long-sought business and worker-friendly provisions among tax professionals and lawmakers, who are watching to see if IRS staff cuts and funding reductions will hinder the agency's ability to take swift regulatory action. Here, Law360 looks at three areas where tax pros say a quick turnaround on guidance or regulations would be most helpful.

  • July 18, 2025

    Western Union Says IRS Used Flawed Rule To Hike Income

    The Internal Revenue Service erroneously included more than $8.2 million in foreign income in Western Union Co.'s foreign tax calculation based on an agency rule that was passed without properly notifying the public, the company told the U.S. Tax Court.

  • July 18, 2025

    Taxation With Representation: Wachtell, Slaughter And May

    In this week's Taxation With Representation, Blackstone pours billions into data centers and related infrastructure, Waters Corp. and Becton Dickinson look to form a new life sciences powerhouse, Reckitt sells 70% of its Essential Home business to private equity firm Advent, and Chevron completes its acquisition of Hess following a favorable arbitral award.

  • July 18, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included the withdrawal of plans to eliminate a safe harbor that allows some businesses an expanded use of net operating losses.

  • July 18, 2025

    IRS Issues 2026 Table For Premium Tax Credit Calculations

    The Internal Revenue Service published the table used to determine the 2026 premium tax credit Friday.

  • July 17, 2025

    Canada Mulling Changes To Ability To Rewrite Transactions

    Canada's Department of Finance is considering changes to legislation that outlines the tax authority's power to recharacterize transactions set forth in contracts between related parties when their behavior doesn't match what the contract says, an official said Thursday.

  • July 17, 2025

    IRS Leaker Asks DC Circ. To Bar Comments By Ex-Employer

    A tech worker appealing a five-year sentence for leaking tax returns while on the job at the IRS through contractor Booz Allen asked the D.C. Circuit on Thursday to block his former employer from weighing in, saying the company's opinion that he should finish his prison term is irrelevant.

  • July 17, 2025

    5th Circ. Affirms Nix Of Doctor's Captive Insurance Deductions

    The owner of a Texas urgent care network is not entitled to $1 million in tax deductions for insurance premiums he paid to inside companies, the Fifth Circuit ruled, affirming the U.S. Tax Court's decision that the payments were not actually for insurance.

Expert Analysis

  • 5 Ways To Create Effective Mock Assignments For Associates

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    In order to effectively develop associates’ critical thinking skills, firms should design mock assignments that contain a few key ingredients, from messy fact patterns to actionable feedback, says Abdi Shayesteh at AltaClaro.

  • Congress Should Pass Sex Abuse Settlement Tax Exemptions

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    The proposed Survivor Justice Tax Prevention Act would expand tax exemptions more clearly for sexual abuse cases, and finally remove the stigma around compensation for emotional and psychological damage, says Rocco Strangio at Milestone & Co.

  • What's Next For Accounting Enforcement After SEC's Big 2024

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    The U.S. Securities and Exchange Commission under the Trump administration will likely continue to focus enforcement efforts on many of the same accounting and auditing issues that it pursued over the past year — but other areas, such as ESG, internal controls and cryptocurrency cases, may fall out of focus, say attorneys at Debevoise.

  • Mentorship Resolutions For The New Year

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    Attorneys tend to focus on personal achievements or career milestones when they set yearly goals, but one important area often gets overlooked in this process — mentoring relationships, which are some of the most effective tools for professional growth, say Kelly Galligan at Rutan & Tucker and Andra Greene at Phillips ADR.

  • Coaching Little League Makes Me A Better Lawyer

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    While coaching poorly played Little League Baseball early in the morning doesn't sound like a good time, I love it — and the experience has taught me valuable lessons about imperfection, compassion and acceptance that have helped me grow as a person and as a lawyer, says Alex Barnett at DiCello Levitt.

  • 5 Litigation Funding Trends To Note In 2025

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    Lawyers and their clients must be prepared to navigate an evolving litigation funding market in 2025, made more complicated by a new administration and the increasing overall cost of litigation, says Jeffery Lula at GLS Capital.

  • Rethinking Litigation Risk And What It Really Means To Win

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    Attorneys have a tendency to overestimate litigation risk before summary judgment and underestimate risk after it, but an eight-stage litigation framework can clarify risk at different points and help litigators reassess what true success looks like in any particular case, says Joshua Libling at Arcadia Finance.

  • Small Biz Caught In Corporate Transparency Act Crossfire

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    Despite compliance being put on hold due to a nationwide preliminary injunction, small businesses have been caught in the middle of the legal battle over the Corporate Transparency Act — and confusion over the law's requirements could result in major penalties, say attorneys at Snell & Wilmer.

  • No, Litigation Funders Are Not 'Fleeing' The District Of Del.

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    A recent study claimed that litigation funders have “fled” Delaware federal court due to a standing order requiring disclosure of third-party financing, but responsible funders have no problem litigating in this jurisdiction, and many other factors could explain the decline in filings, say Will Freeman and Sarah Tsou at Omni Bridgeway.

  • Hydrogen Regs Will Provide More Certainty — If They Survive

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    Newly finalized regulations implementing the Section 45V clean hydrogen tax credit allow producers more flexibility, and should therefore help put the industry on more solid footing — but the incoming Trump administration and Republican Congress will have multiple options for overturning or altering the regulations, say attorneys at Steptoe.

  • 5 E-Discovery Predictions For 2025 And Beyond

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    In the year to come, e-discovery will be shaped by new and emerging trends, from the adoption of artificial intelligence provisions in protective orders, to the proliferation of emojis as a source of evidence in contemporary litigation, say attorneys at Littler.

  • What's Ahead As Transparency Act Comes To A Crossroads

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    Synthesizing the contrasting federal district and appellate court rulings on the Corporate Transparency Act’s validity reveals several main areas of debate that will likely remain at issue as challenges to the law continue winding through the courts, say attorneys at Farella Braun.

  • Final Hydrogen Tax Credit Regs Add Flexibility For Producers

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    The recently released final regulations implementing the Inflation Reduction Act's clean hydrogen production tax credit offer taxpayers greater flexibility, reducing risk and creating more certainty for investments in the industry, thus diminishing — but not eliminating — the risk of legal challenges to the regulations, say attorneys at Steptoe.

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