Federal
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December 15, 2025
2026 To Open With Mixed Applicable Federal Rate Bounceback
Some of the applicable federal rates for income tax purposes will finally increase in January, the Internal Revenue Service said Monday, though others will carry a now six-month slide into 2026.
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December 15, 2025
Fed. Court Asked To Block IRS' Microcaptive Reporting Rule
A Texas federal court should vacate an IRS rule aimed at flagging potential tax avoidance by requiring companies to disclose information about their microcaptive insurance transactions because it undermines Congress' authority, according to a Texas plastics company and its microcaptive adviser.
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December 15, 2025
IRS Updates Corp. Bond Monthly Yield Curve For December
The Internal Revenue Service on Monday updated the corporate bond monthly yield curve used in calculations for defined benefit plans for December, as well as corresponding segment rates and the interest rate for 30-year U.S. Treasury Department securities.
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December 15, 2025
Employee-Related Charges Against Goldstein Are Tossed
A Maryland federal judge has dismissed several charges against SCOTUSblog founder Tom Goldstein related to employees at his law firm, agreeing that prosecutors had failed to establish a clear rule for determining whether employees are legitimate for tax purposes.
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December 15, 2025
IRS Urged To Boost Oversight Of Puerto Rican Tax Breaks
The Internal Revenue Service needs to implement stronger oversight of tax incentives available to Puerto Rico residents who receive federal income tax exemptions if they meet certain requirements, according to a U.S. Government Accountability Office report.
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December 15, 2025
Former Montana Insurer Wants Income Exclusion
A Montana insurance company that dissolved in 2023 is challenging the IRS' determination that transactions it engaged in with an entity on the Turks and Caicos Islands didn't actually involve insurance and therefore aren't deductible for 2021.
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December 15, 2025
Supreme Court Declines Cannabis Ban Review
The U.S. Supreme Court on Monday declined to hear a case challenging the federal marijuana ban, leaving in place a high court precedent that has governed cannabis policy for 20 years.
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December 12, 2025
Judge Says Eaton Moved $14B Subsidiary For Tax Purposes
A U.S. Tax Court judge said Friday that he plans to find Eaton's U.S. group transferred ownership of a $14 billion subsidiary overseas in 2012 solely to justify payment of higher interest rates and guarantee fees to the company's new Irish parent.
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December 12, 2025
DOJ Shake-Up Keeps Criminal Tax Meetings, Ex-Official Says
The U.S. Department of Justice — despite recently eliminating its Tax Division as part of a broad restructuring — continues to meet with practitioners representing clients who may face federal criminal tax charges, the former division chief said Friday.
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December 12, 2025
IRS To Revamp Voluntary Disclosure Program
The Internal Revenue Service will be updating a program early next year that would allow taxpayers to voluntarily report previously undisclosed income as a way to resolve their tax issues to facilitate a simpler reporting process, the agency's criminal enforcement chief said Friday.
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December 12, 2025
Treasury Withdraws Proposed Regs On Spousal Tax Liability
The U.S. Treasury Department has withdrawn two sets of proposed regulations addressing married individuals who filed joint tax returns then later sought relief from joint and several tax liability, according to a notice issued Friday.
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December 12, 2025
New Scholarship Tax Credit Plan Open To States, IRS Says
States can make an advance election to participate in a new tax credit program for contributions made to scholarship organizations, the Treasury Department and the Internal Revenue Service announced Friday, adding that the program is set to start in 2027.
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December 12, 2025
Treasury Issues Final Rules For Taxing Foreign Gov't Income
The U.S. Treasury Department issued final regulations Friday for determining whether income of foreign governments derived within the U.S. is taxable along with proposed regulations concerning when a foreign government has effective control of a commercial entity.
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December 12, 2025
IRS Sets 2026 Wage Base For Covered Compensation
The taxable wage base used to calculate covered compensation for employee retirement plans will be $184,500 for the 2026 tax year, the Internal Revenue Service announced in a revenue ruling Friday.
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December 12, 2025
Taxation With Representation: Cravath, Skadden, Debevoise
In this week's Taxation With Representation, Paramount Skydance Corp. launches a hostile bid for Warner Bros. Discovery, challenging Netflix's deal to acquire the studio and streaming business, IBM acquires data streaming company Confluent, and natural gas company Antero Resources Corp. expands via a deal with HG Energy.
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December 12, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included final regulations for the excise tax on corporations' stock buybacks and similar transactions without what is known as the funding rule.
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December 11, 2025
IRS Plans Outreach Campaign For NIL Income Earners
The Internal Revenue Service plans to launch an outreach campaign to educate student-athletes, entertainers, artists and social media influencers about the tax implications of income earned through personal brand marketing, endorsements and similar activities, an agency official said Thursday.
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December 11, 2025
Judge Slams Eaton Expert For Offering Legal Analysis
A report submitted by one of Eaton's expert witnesses in its acquisition financing trial overstepped the limits of an expert's role, offering legal rather than economic analysis and seeming to advocate for the company, a U.S. Tax Court judge said Thursday.
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December 11, 2025
Failed ACA Credit Extension Votes Leave Costs In Limbo
The Senate failed Thursday to pass procedural votes on two healthcare proposals to address the upcoming lapse in the Affordable Care Act's enhanced premium tax credits, including a proposal by Democrats to extend the subsidies for three years.
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December 11, 2025
Fed Terminates 3 Actions Against Credit Suisse, JPMorgan
The Federal Reserve said Thursday that it has terminated a trio of enforcement actions against Credit Suisse Group AG and JPMorgan Chase & Co., lifting consent orders that were tied to alleged illicit finance practices and trade surveillance failures.
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December 11, 2025
Group Seeks Cannabis Reclassification Regarding Tax Status
Cannabis shouldn't be categorized as a Schedule 1 or 2 drug, so tax law regarding the sale of illegal drugs shouldn't be applied to cannabis sales, a coalition of cannabis industry groups told the U.S. Tax Court in an amicus brief Thursday.
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December 11, 2025
Tax Court Rejects Nevada Couple's Law Firm Deductions
A married couple who are both attorneys are subject to a federal tax lien because they are not entitled to deductions and reduced gross receipts related to their law firm, and they aren't entitled to claimed losses from real estate, the U.S. Tax Court said Thursday.
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December 10, 2025
House Advances Bill To Suspend Tax Refund Claim Limits
The House Ways and Means Committee approved several tax bills Wednesday, including legislation that suspends the limitation period to file a refund claim until an IRS collection due process hearing concludes and all appeals rights have lapsed in levy cases.
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December 10, 2025
Judge Probes IRS Expert On Method For Eaton's Credit Rating
A U.S. Tax Court judge asked an IRS expert Wednesday about his calculation of a standalone credit rating for Eaton's U.S. group in 2012, when it acquired an Irish entity and inverted, noting that the expert, unlike ratings agency Standard & Poor's, factored in Eaton's debt to the Irish parent.
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December 10, 2025
6th Circ. Chides US For Lacking Merits In Distilling Ban Case
A Sixth Circuit judge criticized the U.S. Department of Justice on Wednesday for refusing to address the merits of a suit challenging the constitutionality of the U.S. tax code's ban on home distilling, saying the government cannot decide what the appellate court reviews.
Expert Analysis
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Power To The Paralegals: How And Why Training Must Evolve
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.
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5 Real Estate Takeaways From Trump's Sweeping Tax Law
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.
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Evaluating The Current State Of Trump's Tariff Deals
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.
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How Hyperlinks Are Changing E-Discovery Responsibilities
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.
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Preserving Refunds As Tariffs Await Supreme Court Weigh-In
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.
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Revamped Opportunity Zones Can Aid Clean Energy Projects
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.
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Writing Musicals Makes Me A Better Lawyer
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.
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How Fashion, Tech Can Maximize New Small Biz Tax Breaks
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.
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Adapting To Private Practice: From Va. AUSA To Mid-Law
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.
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7 Document Review Concepts New Attorneys Need To Know
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.
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Agentic AI Puts A New Twist On Attorney Ethics Obligations
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.
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Opportunity Zone's Future Corp. Tax Benefits Still Uncertain
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.
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How GILTI Reform Affects M&A Golden Parachute Planning
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.