Federal
-
September 19, 2025
Feds Urge Justices To Back Trump's Emergency Tariffs
The federal government told the U.S. Supreme Court Friday that lower courts incorrectly determined President Donald Trump's emergency tariffs unlawful under a statute that gives the executive broad authority to regulate the economy in matters of national emergency,.
-
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.
Expert Analysis
-
Justices' False Statement Ruling Curbs Half-Truth Liability
The U.S. Supreme Court’s recent Thompson v. U.S. decision clarified that a federal statute used to prosecute false statements made to bank regulators only criminalizes outright falsehoods, narrowing prosecutors’ reach and providing defense counsel a stronger basis to challenge indictments of merely misleading statements, says Tamara de Silva at De Silva Law Offices.
-
Perfecting Security Interests In Renewable Energy Tax Credits
The ability to transfer renewable energy tax credits has created new opportunities for developers, investors and lenders, but it also raises important questions regarding when and how the security interests in these credits are perfected — questions that must be answered definitively to protect credit claims and transactions, says Harry Teichman at Stinson.
-
Firms Still Have Lateral Market Advantage, But Risks Persist
Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
-
Making The Opportunity Zones Program Great At Last
As the opportunity zone program approaches its expiration, the Republican-led government could take specific steps to extend and improve the program, address its structural flaws, encourage broader participation and enable it to live up to its promised outcomes, say attorneys at Pillsbury.
-
We Must Allow Judges To Use Their Independent Judgment
As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.
-
Preparing For Tariffs On Canadian Power In The Northeast
The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.
-
Making The Case For Rest In The Legal Profession
For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.
-
Mitigating Tariff Risks For Healthcare In US And Canada
Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.
-
4 Ways Women Attorneys Can Build A Legal Legacy
This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.
-
A Judge's Pointers For Adding Spice To Dry Legal Writing
U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.
-
Why NY May Want To Reconsider Its LLC Transparency Law
Against the backdrop of the myriad challenges to the federal Corporate Transparency Act, it may be prudent for New York to reconsider its adoption of the LLC Transparency Act, since it's unclear whether the Empire State's "baby-CTA" statute is still necessary or was passed prematurely, say attorneys at Pillsbury.
-
IRS Scrutiny May Underlie Move Away From NIL Collectives
The University of Colorado's January announcement that it was severing its partnership with a name, image and likeness collective is part of universities' recent push to move NIL activities in-house, seemingly motivated by tax implications and increased scrutiny by the Internal Revenue Service, say attorneys at Buchanan Ingersoll.
-
7 Tips For Associates To Thrive In Hybrid Work Environments
Excerpt from Practical Guidance
As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.