Federal

  • October 08, 2025

    Tax Court Upholds Lien Notice Against Health Co.

    The IRS didn't abuse its discretion when it sustained a federal tax lien notice against a health company for unpaid income and employment taxes, the U.S. Tax Court ruled Wednesday, saying the company didn't file documents, including tax returns, needed to challenge the notice.

  • October 08, 2025

    IRS Issued Tax Notices On Time, Tax Court Says

    The Internal Revenue Service issued notices of tax deficiency related to a man's partnership on time, the U.S. Tax Court ruled Wednesday, saying the agency made the notifications within a year of the conclusion of litigation over the affected items.

  • October 08, 2025

    IRS Stops Most Operations Due To Federal Budget Impasse

    The Internal Revenue Service has temporarily halted most of its operations, furloughed workers and ended paid leave for the affected employees as Congress remains deadlocked over federal appropriations legislation to fund the government, the agency's acting human resources officer said Wednesday.

  • October 08, 2025

    Gov't Resists Prison Delay For Lobbyist Who Evaded Tax

    A Miami lobbyist who was sentenced to prison for evading more than $1 million in taxes should not be allowed to delay the start of his term, the U.S. told a Florida federal court, saying the medical injection he argues he should take at home is available in prison.

  • October 08, 2025

    Denver Attorney Returns To Reed Smith State Tax Team

    Reed Smith is expanding its tax practice with the return of an experienced attorney, now based in Denver, with multistate experience in the full spectrum of tax issues.

  • October 07, 2025

    11th Circ. Wary Of IRS Procedure In FBAR Penalty Appeal

    An Eleventh Circuit panel Tuesday appeared concerned about IRS procedures that could keep a man from recouping $419,000 he paid to resolve his failure to disclose funds held in foreign bank accounts as he appeals a district court determination that he actually owes $2.2 million.

  • October 07, 2025

    Goldstein's $968K Border Cash Claim To Be Admitted At Trial

    A Maryland federal jury will hear claims from prosecutors that SCOTUSblog publisher Tom Goldstein told Dulles International Airport border guards that the $968,000 in cash he brought into the country in 2018 had been gambling winnings, after a judge shot down his efforts to suppress his alleged statements Tuesday.

  • October 07, 2025

    Simpson Thacher Atty On Making New REIT Blueprints

    The real estate investment landscape has changed dramatically in recent years, as alternative asset managers — and their counsel — have pioneered ways to tap into new sources of capital. Simpson Thacher partner Benjamin Wells spoke to Law360 about the changes he's seen, how to navigate regulatory shifts, and how real estate investment trusts may continue to reinvent themselves.

  • October 07, 2025

    Ex-Executives' Payroll Tax Convictions Biased, 4th Circ. Told

    Two former software executives asked the Fourth Circuit to reverse their criminal convictions stemming from their failure to pay employment taxes, claiming the jury's instructions were biased.

  • October 07, 2025

    Senate OKs Top Treasury Atty Pick In Slate Of Confirmations

    The Senate approved President Donald Trump's choice of a Sidley Austin LLP partner to be general counsel of the U.S. Department of the Treasury on Tuesday as part of a combined confirmation of 108 nominees to various roles.

  • October 07, 2025

    Approach The Bench: Judge Kaplan On Suit Against The Gov't

    U.S. Court of Federal Claims Judge Elaine Kaplan's docket doesn't always garner attention in the same way trial court cases do, but that may change as the executive branch makes sweeping budget and policy changes that could lend more political significance to monetary claims against the government.

  • October 07, 2025

    Estate's $17M Transfer Not Tax-Related, 5th Circ. Told

    The estate of a woman who inherited her husband's oil business and was the victim of elder abuse told the Fifth Circuit that it had multiple reasons unrelated to avoiding estate tax for setting up a partnership and transferring $17 million into it just before she died.

  • October 07, 2025

    IRS Provides Grace Period For Int'l Money Transfer Tax Errors

    U.S. financial institutions that handle overseas money transfers won't immediately face penalties if they fail to accurately deposit new excise taxes that are required under the budget reconciliation bill enacted in July, the Internal Revenue Service announced Tuesday.

  • October 07, 2025

    TCJA Designer Tapped For Deputy Treasury Role

    An architect of the 2017 federal tax overhaul has been appointed to serve as second-in-command at the U.S. Department of the Treasury, Secretary Scott Bessent announced Tuesday.

  • October 06, 2025

    Homeowners Group Denied Social Welfare Tax Break

    A Texas homeowners association doesn't qualify for an exemption from federal income tax available to social welfare nonprofit organizations, the U.S. Tax Court said Monday.

  • October 06, 2025

    Fed. Circ. Partially Revives German Steel Co.'s Dumping Suit

    The U.S. Commerce Department cannot use a German steelmaker's likely sales prices as a proxy for the cost of producing nonprime steel plates, but the company acted too late to argue for categorizing some plates separately as it challenges Commerce's antidumping investigation, the Federal Circuit said Monday.

  • October 06, 2025

    IRS Cyber Crime Executive Named Interim Compliance Chief

    An Internal Revenue Service criminal investigations executive who founded the division's cyber crimes sections will temporarily take on an elevated role overseeing all agency enforcement operations, the IRS announced Monday.

  • October 06, 2025

    Tax Court Denies IT Co.'s $45M Capital Loss Penalty Challenge

    The U.S. Tax Court rejected on Monday an information technology company's bid to skirt a $45 million penalty related to the IRS' denial of its $651 million capital loss deduction, saying the agency did not violate the Administrative Procedure Act in asserting the fine.

  • October 06, 2025

    Social Security Chief Adds Duties As Inaugural CEO Of IRS

    The current administrator of the Social Security Administration is adding a new role as the Internal Revenue Service's first chief executive officer, Treasury Secretary Scott Bessent announced Monday.

  • October 06, 2025

    High Court Won't Review CPA's 'Unbecoming' Tax Challenge

    The U.S. Supreme Court declined to take up a case Monday in which a U.S. Tax Court judge found that a certified public accountant's claims that his wages weren't taxable were meritless and "unbecoming" of a professional accountant.

  • October 03, 2025

    Some Longtime Legal Blogs Go Quiet As Platform Shuts Down

    When the online publishing platform Typepad launched more than two decades ago, it became a hub for a then-growing community of law professors and legal bloggers. Its closure this week marked the end of an era that has found some bloggers looking for new homes or opting to call it quits.

  • October 03, 2025

    Justices To Weigh Compensation In Tax-Foreclosure Sale

    The U.S. Supreme Court agreed Friday to take up a case contending that a deceased homeowner's estate was denied its constitutionally owed compensation when a Michigan county sold a tax-foreclosed property at a fraction of its fair market value.

  • October 03, 2025

    DC Circ. Split On Challenge To IRS-ICE Info-Sharing Deal

    D.C. Circuit judges seemed split Friday over whether an information-sharing agreement between immigration authorities and the IRS complies with taxpayer privacy protections, with one judge noting during oral arguments that the government immigration arm requesting the tax information appears unauthorized to make the requests.

  • October 03, 2025

    Hobby Lobby's $85M Charity Case Needs Trial, Tax Court Says

    A trial is needed to determine whether Hobby Lobby's owners themselves were responsible for missing important information that led the IRS to reject their nearly $85 million charitable deduction tied to artifact donations, the U.S. Tax Court ruled.

  • October 03, 2025

    Getting It Right: An Economist On Transfer Pricing

    Michael McDonald, who retired from EY last month, spent most of his career at the U.S. Treasury Department, working on rules governing how related companies should calculate the value of intangible assets transferred between them, then later contributed to the massive rewrite of international tax rules by the OECD in 2015. McDonald reflected on both projects in an interview with Law360.

Expert Analysis

  • Law School's Missed Lessons: Communicating With Clients

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    Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.

  • Bill Leaves Renewable Cos. In Dark On Farmland Reporting

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    A U.S. Senate bill to update disclosure requirements for foreign control of U.S. farmland does not provide much-needed guidance on how to report renewable energy development on agricultural property, leaving significant compliance risks for project developers, say attorneys at Hodgson Russ.

  • Adapting To Private Practice: From US Rep. To Boutique Firm

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    My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.

  • IRS Should Work With Industry On Microcaptive Regs

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    The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.

  • CARES Act Fraud Enforcement Is Unlikely To Slow Down

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    In the five years since the passage of the Coronavirus Aid, Relief and Economic Security Act, the federal government has devoted massive resources to investigating CARES Act fraud — and all signs suggest the U.S. Department of Justice will continue vigorous enforcement in this area, say attorneys at Kostelanetz.

  • Spinoff Transaction Considerations For Biotech M&A

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    Amid current market challenges, boards and management teams of biotech companies can consider several strategies for maximizing value should a spinoff opportunity arise, but not without significant advance planning and careful implementation, particularly in cases that might qualify as tax-free, say attorneys at Paul Hastings.

  • Senate's 41% Litigation Finance Tax Would Hurt Legal System

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    The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.

  • Drawbacks For Taxpayers From Justices' Levy Dispute Ruling

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    The Supreme Court's June decision in Commissioner v. Zuch, holding the Tax Court lacks jurisdiction to resolve disputes where the IRS has stopped pursuing a levy, may require taxpayers to explore new tactics for mitigating the increased difficulty of appealing their liability via collection due process hearings, says Matthew Roberts at Meadows Collier.

  • How Energy Cos. Can Prepare For Potential Tax Credit Cuts

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    The Senate Finance Committee's version of the One Big Beautiful Bill act would create a steep phaseout of renewable energy tax credits, which should prompt companies to take several actions, including conduct a project review to discern which could begin construction before the end of the year, say attorneys at Husch Blackwell.

  • DOJ Has Deep Toolbox For Corporate Immigration Violations

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    With the U.S. Department of Justice now offering rewards to whistleblowers who report businesses that employ unauthorized workers, companies should understand the immigration enforcement landscape and how they can reduce their risk, say attorneys at McDermott.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.

  • Del. Dispatch: General Partner Discretion In Valuing Incentives

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    In Walker v. FRP Investors, the Delaware Court of Chancery recently held that the general partner of a limited partnership breached its obligations when determining the threshold value of newly issued incentive units, highlighting the court's willingness to reconstruct what a reasonable determination of value by a general partner should have been, say attorneys at Fried Frank.

  • Move Beyond Surface-Level Edits To Master Legal Writing

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    Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.

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