Federal

  • November 10, 2025

    IRS Sets Safe Harbor For Trusts Staking Digital Assets

    Investment and grantor trusts can stake their digital assets — which can generate passive income — without losing their tax benefits if they meet certain requirements, including obtaining approval from the U.S. Securities and Exchange Commission to authorize such activities, the Internal Revenue Service said in a revenue procedure Monday.

  • November 10, 2025

    Ex-Russian Gas Exec Seeks Release After Tax Sentence Axed

    A former Russian gas company executive convicted of hiding more than $100 million from the IRS asked a Florida federal court to release him from prison now that his sentence has been vacated on appeal, while the U.S. urged the court to deliver the same seven-year term.

  • November 10, 2025

    Supreme Court Declines Lawyer's Bid For New Tax Fraud Trial

    The U.S. Supreme Court won't hear a personal injury lawyer's appeal of his conviction over allegations he concealed more than $2.6 million in income from the Internal Revenue Service.

  • November 07, 2025

    Eaton Should Have Weighed Borrowing In Europe, Judge Says

    When it acquired Ireland-based Cooper Industries in 2012, Eaton Corp. should have considered the costs of borrowing in Europe to finance the transaction, Tax Court Judge Albert Lauber said Friday in questioning a former Eaton official.

  • November 07, 2025

    Justices Cast Constitutional Clouds Over Trump's Tariffs

    Several U.S. Supreme Court justices appeared skeptical of the government's arguments seeking to salvage President Donald Trump's emergency tariffs, signaling that the high court may come down with a ruling that reinforces Congress' constitutional authority to impose tariffs.

  • November 07, 2025

    State Tax Rules Flagged To DOJ In Interstate Commerce Probe

    Tax attorneys and business groups are using a federal effort that aims to reduce interstate commerce burdens to highlight litigation over state taxes and call for codifying U.S. Supreme Court precedent on the commerce clause.

  • November 07, 2025

    Calif. Cannabis Co. Fights $10M IRS Bill In Tax Court

    A California company that manages cannabis operators challenged $10 million in taxes and penalties in the U.S. Tax Court, arguing the Internal Revenue Service stripped it of business deductions by incorrectly determining it trafficked in a controlled substance.

  • November 07, 2025

    Donor Wants Tax Court To Reinstate Easement Deductions

    An Oklahoma donor asked the U.S. Tax Court to reinstate deductions of $12 million and $13 million he claimed through partnership entities on a pair of charitable conservation easement donations, asserting the Internal Revenue Service disallowed the tax breaks without adequate explanation.

  • November 07, 2025

    9th Circ. Sides With Calif. In Tribal Cigarette Tax Fight

    The Ninth Circuit on Friday backed California in a dispute it brought to enforce cigarette taxes against a tobacco company owned and operated by a federally recognized Native American tribe, holding that the tribal leader defendants can't claim sovereign or qualified immunity exempts them from the federal tax law.

  • November 07, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service on Friday released its weekly internal revenue bulletin, which included proposed regulations that would remove rules that allow revenue officials to look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.

  • November 07, 2025

    DOJ Backs Trump In NY False-Records Conviction Appeal

    The U.S. Department of Justice is throwing its support behind President Donald Trump's effort to overturn his New York criminal conviction for falsifying business records, filing a proposed amicus brief on Friday citing the U.S. Supreme Court's landmark 2024 decision "defining the contours of a president's federal constitutional immunity from criminal prosecution."

  • November 07, 2025

    Wyden, Warren Flag IRS CEO's Fiserv Tenure In Probe

    Two Senate Finance Committee members said they are investigating Internal Revenue Service CEO Frank Bisignano's conduct in his previous position as Fiserv Inc.'s CEO, saying the financial setbacks the company has faced this year raise questions about his ability to serve as a key IRS official.

  • November 07, 2025

    Taxation With Representation: Kirkland, Cravath, Paul Weiss

    In this week's Taxation With Representation, consumer products giant Kimberly-Clark acquires Tylenol maker Kenvue, shale producers SM Energy and Civitas Resources announce a merger, and power management company Eaton buys Boyd Corp.'s thermal business.

  • November 06, 2025

    Goldstein Loses Bid To Trim Tax Charges Before Trial

    A Maryland federal judge Thursday handed SCOTUSblog co-founder Tom Goldstein a series of losses on pre-trial motions aimed at trimming the 22 federal tax charges he'll face at trial next year, ruling that many of the motions involved factual disputes fit for trial and keeping the government's case intact.

  • November 06, 2025

    Tax Court OKs Disallowance Of Unverified Litigation Fees

    The IRS correctly determined that a woman who'd been at odds with her various attorneys — having filed breach of contract suits against two separate legal teams — inadequately justified her claimed $28,000 deduction for legal expenses, the U.S. Tax Court said Thursday.

  • November 06, 2025

    Whistleblower Entitled To Award For $31M Tip, DC Circ. Told

    The U.S. Tax Court wrongly denied a whistleblower award to a woman who said she helped the Internal Revenue Service assess more than $31 million in corporate income, her supporter told the D.C. Circuit, saying the court allowed the agency to omit relevant information it was required to provide.

  • November 06, 2025

    IRS Microcaptive Reporting Rules Suit Can Move Forward

    A global tax services provider can move forward with its suit against the IRS to vacate tax reporting rules for microcaptive insurance companies, a Texas federal court said, finding the company had a stake in the challenge and a right to bring the case.

  • November 06, 2025

    No $22M Break For Real Estate Partnership, 6th Circ. Affirms

    An Ohio real estate partnership cannot claim a $22 million charitable tax deduction on a 2016 preservation easement, the Sixth Circuit found, affirming the U.S. Tax Court and Internal Revenue Service's conclusions that the partnership grossly misstated the value of the donated historic building.

  • November 06, 2025

    Tax Court Says IRS Took Too Long To Ax Easement Deduction

    The Internal Revenue Service failed to timely disallow a charitable deduction related to a company's conservation easement donation, the U.S. Tax Court said, throwing out a partnership adjustment by the agency.

  • November 06, 2025

    2nd Circ. Orders New Look At Trump's Hush Money Case

    In a published opinion, the Second Circuit on Thursday ordered a federal district judge to take a fresh look at President Donald Trump's attempt to move his New York hush money conviction to federal court, citing the U.S. Supreme Court's 2024 presidential immunity ruling as grounds for reconsidering the case.

  • November 05, 2025

    Judge Questions Transfer Of Eaton's $14B Foreign Asset

    A U.S. Tax Court judge questioned a former Eaton Corp. official Wednesday about the company's decision to restructure the ownership of a valuable foreign subsidiary when it inverted in 2012, noting that the move placed a $14 billion asset out of the U.S. company's reach.

  • November 05, 2025

    IRS Direct File Will Not Be Offered In 2026, States Confirm

    State revenue agencies confirmed Wednesday that the Internal Revenue Service has informed them that its free online tax preparation tool, Direct File, will not be offered for the 2026 filing season and potentially other years.

  • November 05, 2025

    IRS Layoffs Include Over 500 Exam Employees, Docs Show

    The federal workers laid off during the government shutdown include more than 500 people in the exam and collections section of the IRS responsible for enforcing tax laws, a federal employee told a California federal court in a lawsuit over the firings.

  • November 05, 2025

    Docs Show IRS Improperly Shared Data With ICE, Groups Say

    Documents submitted by the U.S. government to a D.C. federal court show the IRS violated taxpayer privacy laws by sharing individuals' addresses with ICE despite its requests lacking required information and by accepting an unreasonable explanation about why the information was requested, several groups said.

  • 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."

Expert Analysis

  • Power To The Paralegals: How And Why Training Must Evolve

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    Empowering paralegals through new models of education that emphasize digital fluency, interdisciplinary collaboration and human-centered lawyering could help solve workforce challenges and the justice gap — if firms, educators and policymakers get on board, say Kristine Custodio Suero and Kelli Radnothy.

  • 5 Real Estate Takeaways From Trump's Sweeping Tax Law

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    Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.

  • Evaluating The Current State Of Trump's Tariff Deals

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    As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.

  • How Hyperlinks Are Changing E-Discovery Responsibilities

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    A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.

  • Preserving Refunds As Tariffs Await Supreme Court Weigh-In

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    In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.

  • Revamped Opportunity Zones Can Aid Clean Energy Projects

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    The Qualified Opportunity Zone program, introduced in 2017 and reshaped in the One Big Beautiful Bill Act, offers investors federal tax incentives for development in low-income communities — incentives that are especially meaningful for clean energy projects, where capital-intensive infrastructure and long-term planning are essential, say attorneys at Dentons.

  • Writing Musicals Makes Me A Better Lawyer

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    My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.

  • How Fashion, Tech Can Maximize New Small Biz Tax Breaks

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    Fashion and technology companies, which invest heavily in innovation, should consider taking advantage of provisions in the One Big Beautiful Bill Act that favor small businesses, restructuing if necessary to become eligible for expanded research and experimental expenditure credits and qualified small business stock incentives, says Aime Salazar at Olshan Frome.

  • Adapting To Private Practice: From Va. AUSA To Mid-Law

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    Returning to the firm where I began my career after seven years as an assistant U.S. attorney in Virginia has been complex, nuanced and rewarding, and I’ve learned that the pursuit of justice remains the constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.

  • 7 Document Review Concepts New Attorneys Need To Know

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    For new associates joining firms this fall, stepping into the world of e-discovery can feel like learning a new language, but understanding a handful of fundamentals — from coding layouts to metadata — can help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.

  • Agentic AI Puts A New Twist On Attorney Ethics Obligations

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    As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.

  • Opportunity Zone's Future Corp. Tax Benefits Still Uncertain

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    Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.

  • How GILTI Reform Affects M&A Golden Parachute Planning

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    Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.

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