Federal

  • 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.

  • July 17, 2025

    US Challenge To Belgian Minimum Tax Rules Heads To ECJ

    A Belgian court said Thursday it has asked the European Union's highest court to weigh in on a U.S. industry group's challenge to the country's global minimum tax rules.

  • July 17, 2025

    GAO Urges IRS To Hone Method For Gauging Better Service

    The Internal Revenue Service should establish an evidence-based approach to assessing the results of its efforts to improve taxpayers' experience with the agency, the U.S. Government Accountability Office said Thursday.

  • July 16, 2025

    Attys Tout 3 Real Estate Investment Wins In Federal Budget

    Real estate investors can breathe a collective sigh of relief seeing the final version of the "One, Big, Beautiful Bill Act" that President Donald Trump signed into law this month, as it is largely favorable to the industry and keeps several much-admired tax breaks alive.

  • July 16, 2025

    House Panel Urged To Modernize Tax Rules For Digital Assets

    Congress needs to create tax rules for digital assets such as cryptocurrency and nonfungible tokens because the current regime is burdensome for businesses and pushing development out of the U.S., industry representatives told a House Ways and Means Committee subcommittee Wednesday.

  • July 16, 2025

    OECD Mulling Tweaks To Arm's-Length Range Guidance

    The Organization for Economic Cooperation and Development's guidance on the arm's-length range is an area ripe for simplification because the resources needed to calculate and make adjustments to the range are sometimes out of proportion with the amount in dispute, an official said Wednesday.

  • July 16, 2025

    No Tax Refund For Uncashed Retirement Checks, IRS Says

    The Internal Revenue Service said Wednesday that an employer administering a retirement plan cannot get a tax refund or tax adjustment when it cuts a distribution check to an individual who had not made a withholding election and did not cash the check.

Expert Analysis

  • House Bill Tax Tweaks Would Hinder Renewable Projects

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    Provisions in the budget reconciliation bill recently passed by the U.S. House of Representatives would rapidly phase out clean energy tax credits, constrain renewable energy financing arrangements and impose sweeping restrictions on projects with foreign ties, which may create compliance and supply chain issues for many developers, say attorneys at Paul Hastings.

  • Power To The Paralegals: An Untapped Source For Biz Roles

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    Law firms looking to recruit legal business talent should consider turning to paralegals, who practice several key skills every day that prepare them to thrive in marketing and client development roles, says Vanessa Torres at Lowenstein Sandler.

  • How Trucking Cos. Can Keep Rolling Under Tariff Burdens

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    Recent Trump administration tariffs present major challenges for the transportation and logistics sector — and, in particular, trucking — but providers who focus on operational efficiency, cost control, customer relationships, creative contract structures and unique offerings will stand out from the competition, say attorneys at Benesch.

  • Tariff Strategies For The US Renewable Energy Sector

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    The Trump administration's tariff actions over the last few months are challenging for the renewable energy industry — but there are strategies for contending with the uncertainty, including diversifying supply chains, seeking certification about equipment origins, and adding tariff-related language to supply contracts and offtake agreements, say attorneys at Sheppard Mullin.

  • Ch. 7 Marshaling Ruling Rests On Shaky Legal Grounds

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    In its recent holding in a Chapter 7 bankruptcy case that marshaling may not be applied against the IRS, a Texas federal court misapplied a bankruptcy code section and case law, leaving a draconian decision that could limit the scope of a powerful equitable estate tool, says Brian Shaw at Cozen O'Connor.

  • 3 Tax Issues Manufacturers Should Watch In 2025 Budget Bill

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    As Congress works toward a budget reconciliation bill, manufacturing companies should keep a keen eye on proposals to change bonus depreciation, the qualified business income deduction and energy tax credits, which could have a significant impact on capital-intensive industries, say attorneys at Frost Brown Todd.

  • $38M Law Firm Settlement Highlights 'Unworthy Client' Perils

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    A recent settlement of claims against law firm Eckert Seamans for allegedly abetting a Ponzi scheme underscores the continuing threat of clients who seek to exploit their lawyers in perpetrating fraud, and the critical importance of preemptive measures to avoid these clients, say attorneys at Lockton Companies.

  • Jurisdictional Issues At Play In 9th Circ.'s FCA Trade Case

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    A decision by the Ninth Circuit in Island Industries v. Sigma Corp. could result in the U.S. Court of International Trade’s exclusive jurisdiction over trade-related FCA cases, a big shift in the enforcement landscape just as tariffs take center stage in trade policy, say attorneys at Haynes Boone.

  • Evolving Federal Rules Pose Further Obstacles To NY LLC Act

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    Following the Financial Crimes Enforcement Network's recent changes to beneficial ownership information reporting under the federal Corporate Transparency Act — dramatically reducing the number of companies required to make disclosures — the utility of New York's LLC Transparency Act becomes less apparent, say attorneys at Pillsbury.

  • Alternative Business Structures Raise Ethics Questions

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    The new KPMG law firm, launched in Arizona following that state's repeal of the prohibition on fee sharing with nonlawyers, raises a number of important practice questions, both for the firm and those law firms seeking to partner with it, says Deborah Winokur at Cozen O’Connor.

  • The IRS Shouldn't Go To War Over Harvard's Tax Exemption

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    If the Internal Revenue Service revokes Harvard's tax-exempt status for violating established public policy — a position unsupported by currently available information — the precedent set by surviving the inevitable court challenge could undercut the autonomy and distinctiveness of the charitable sector, says Johnny Rex Buckles at Houston Law Center.

  • Mitigating Import Risks Around Southeast Asian Solar Cells

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    The U.S. Department of Commerce's recent final determinations in its antidumping and countervailing duty investigations into solar cells produced in certain Southeast Asian countries make it important for U.S. purchasers to consider risk mitigation strategies, including modifying supply chains and contractually assigning import responsibilities, say attorneys at Morgan Lewis.

  • Reassessing Corporate Separateness After Explosion Of LLCs

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    Following the dramatic increase of limited liability companies in the U.S., the Corporate Transparency Act's enactment and the Trump administration's subsequent narrowing of that law, it's worth revisiting the underlying legal principles that govern shell companies in order to remedy the problems that initially motivated the CTA, says Jeff Newton at Omni Bridgeway.

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