Federal

  • September 19, 2025

    Foreign Entity Rules Begin To Shape Clean Energy Deals

    The recently enacted federal budget that attaches stricter foreign supply chain and business ownership rules to clean energy tax credits has started to take practical effect, with project developers rewriting agreements to avoid getting snagged in the new regulatory regime.

  • September 19, 2025

    Pillar 2 At 4: High Compliance Costs, Low Tax Liabilities

    Four years after countries agreed to an international minimum corporate tax regime known as Pillar Two, finance executives and policy observers are voicing a common refrain: multinational companies likely will pay more compliance costs than actual taxes under the new rules.

  • 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.

Expert Analysis

  • Tax-Free Ways To Help Employees After The LA Wildfires

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    Following the recent wildfires in Los Angeles, there are various tax-free ways to give employees the resources and flexibility they need, including simpler methods like disaster relief payments under Internal Revenue Code Section 139 and leave-sharing programs, and others that require more planning, says Ligeia Donis at Baker McKenzie.

  • Judge Should Not Have Been Reprimanded For Alito Essay

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    Senior U.S. District Judge Michael Ponsor's New York Times essay critiquing Supreme Court Justice Samuel Alito for potential ethical violations absolutely cannot be construed as conduct prejudicial to the administration of the business of the courts, says Ashley London at the Thomas R. Kline School of Law of Duquesne University.

  • Lights, Camera, Ethics? TV Lawyers Tend To Set Bad Example

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    Though fictional movies and television shows portraying lawyers are fun to watch, Hollywood’s inaccurate depictions of legal ethics can desensitize attorneys to ethics violations and lead real-life clients to believe that good lawyers take a scorched-earth approach, says Nancy Rapoport at the University of Nevada, Las Vegas.

  • Accountant-Owned Law Firms Could Blur Ethical Lines

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    KPMG’s recent application to open a legal practice in Arizona represents the first overture by an accounting firm to take advantage of the state’s relaxed law firm ownership rules, but enforcing and supervising the practice of law by nonattorneys could prove particularly challenging, says Seth Laver at Goldberg Segalla.

  • AI Will Soon Transform The E-Discovery Industrial Complex

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    Todd Itami at Covington discusses how generative artificial intelligence will reshape the current e-discovery paradigm, replacing the blunt instrument of data handling with a laser scalpel of fully integrated enterprise solutions — after first making e-discovery processes technically and legally harder.

  • When Innovation Overwhelms The Rule Of Law

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    In an era where technology is rapidly evolving and artificial intelligence is seemingly everywhere, it’s worth asking if the law — both substantive precedent and procedural rules — can keep up with the light speed of innovation, says Reuben Guttman at Guttman Buschner.

  • What Compensation Committees Must Keep In Mind In 2025

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    New disclosure obligations, an evolving discussion on the analysis of executive perks and updated proxy adviser policies — on top of a new presidential administration — are all important things compensation committees must pay close attention to in 2025, say attorneys at Simpson Thacher.

  • Anticipating Direction Of Cosmetics Regulation Under Trump

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    It is unclear how cosmetics regulation reform from the last few years will fare under President Donald Trump, but the new administration's emphasis on deregulation and Robert F. Kennedy Jr.'s views on product safety provide some insight, say attorneys at Crowell & Moring.

  • IRS Basis-Shifting Rule Poses Notable Reporting Obligations

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    While the IRS’ recently finalized rule requiring partnerships to report certain related-party basis adjustment transactions is narrower than originally proposed, taxpayers and their advisers will still need to comb through myriad transactions to comply, say attorneys at Debevoise.

  • Imagine The Possibilities Of Openly Autistic Lawyering

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    Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.

  • Litigation Funding Disclosure Debate: Strategy Considerations

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    In the ongoing debate over whether courts should require disclosure of litigation funding, funders and plaintiffs tend to argue against such mandates, but voluntarily disclosing limited details about a funding arrangement can actually confer certain benefits to plaintiffs in some scenarios, say Andrew Stulce and Marc Cavan at Longford Capital.

  • Top Considerations For Insurance Companies In 2025

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    As insurance industry participants look to plan for the year, regulatory changes, climate-related challenges, the ongoing effects of social inflation and the potential for significant mergers and acquisitions will be among the key items for insurer boards and management to have on their radar, say attorneys at Debevoise.

  • Scope And Nature Of Judicial Relief Will Affect Loper's Impact

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    The practical result of post-Loper Bright rulings against regulatory actions will depend on the relief courts grant — and there has been controversy in these types of cases over whether the ruling is applied just to the parties or nationwide, and whether the action can be left in place while it's corrected, says Steven Gordon at Holland & Knight.

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