Federal

  • November 10, 2025

    Law360 MVP Awards Go To Top Attorneys From 76 Firms

    The attorneys chosen as Law360's 2025 MVPs have distinguished themselves from their peers by securing significant achievements in high-stakes litigation, complex global matters and record-breaking deals.

  • 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.

Expert Analysis

  • Despite Dark Clouds, Outlook For US Solar Has Bright Spots

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    While tariff, tax policy and bankruptcy news seemingly portends unending challenges for the U.S. solar energy industry, signs of continued growth in solar generating capacity and domestic solar manufacturing suggest that there is a path forward, say attorneys at Beveridge & Diamond.

  • 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.

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