Federal

  • May 06, 2025

    Bessent Eyes IRS' Technology Budget For Major Cuts

    The Internal Revenue Service must cut its bloated technology budget and decrease the agency's overall spending, U.S. Treasury Secretary Scott Bessent told a House Appropriations panel Tuesday.

  • May 06, 2025

    Eversheds Sutherland Brings On EY Tax Pro In Atlanta

    Eversheds Sutherland has added a former EY senior manager of international tax and transaction services to its Atlanta office, further strengthening its tax practice after adding a dozen tax controversy attorneys from Chamberlain Hrdlicka White Williams & Aughtry PC in March, the firm announced Tuesday.

  • May 06, 2025

    4th Circ. Seems Split On BofA's Post-Merger Tax Offset Claims

    The Fourth Circuit seemed split Tuesday on whether Bank of America should be able to use its tax overpayments to offset interest on tax underpayments by companies that merged into it, with one judge pressing the government to respond to what he described as the bank's "common sense" argument in the $163 million case.

  • May 05, 2025

    Credit Suisse To Pay Feds $510.6M For Helping Hide Assets

    Credit Suisse Services AG has agreed to shell out more than $510 million under agreements with federal prosecutors in which the company admitted to helping customers hide more than $4 billion from the IRS in hundreds of offshore accounts, the U.S. Department of Justice announced Monday.

  • May 05, 2025

    Feds Say Calif. Tribe's Challenge To Cig Ruling Is 'Fruitless'

    The federal government is urging a California federal court not to pause a ruling affirming the Bureau of Alcohol, Tobacco, Firearms and Explosives' decision to place a native tribe on a noncompliance list over cigarette sales, saying the tribe shouldn't be able to upend the status quo as it pursues a "fruitless" appeal to the Ninth Circuit.

  • May 05, 2025

    Trump Seeks 100% Tariff On Foreign-Made Movies

    President Donald Trump asked his administration to place a 100% tariff on foreign-made movies, with a spokesperson telling Law360 on Monday that a final decision on the plan hadn't been made.

  • May 05, 2025

    Minn. Tribe Looks To Weigh In On 3,000-Acre Land Trust Row

    The Mille Lacs Band of Ojibwe has asked a Minnesota federal judge to let it file a friend of the court brief in a county's case claiming the U.S. government wrongly accepted more than 3,000 acres of land into trust for the tribe.

  • May 05, 2025

    Trump Admin Defends Tariff Power In Toy-Makers' Challenge

    President Donald Trump's administration urged a D.C. federal court to deny a request by toy companies to halt global tariffs, arguing the government is authorized to impose trade measures under the International Emergency Economic Powers Act.

  • May 05, 2025

    IRS Audit Staff Slashed From Layoffs, Voluntary Resignations

    Layoffs and voluntary resignations at the Internal Revenue Service have significantly reduced the agency's revenue agents responsible for conducting audits, the Treasury Inspector General for Tax Administration said Monday.

  • May 05, 2025

    Tax Evader Can't Fight Related Taxes, Court Says

    A South Dakota business owner who admitted to hiding income from the Internal Revenue Service cannot challenge the $120,000 the agency claims he owes in additional taxes for fraudulently failing to file returns, the U.S. Tax Court ruled Monday.

  • May 05, 2025

    Clifford Chance Adds Paul Weiss Exec Compensation Atty In NY

    Clifford Chance LLP has added a Paul Weiss Rifkind Wharton & Garrison LLP transactional attorney in New York as co-chair of its U.S. executive compensation practice, the firm announced Monday.

  • May 05, 2025

    Tax Court Tosses Grandmother's Levy Challenge

    The U.S. Tax Court tossed Monday a levy challenge by an Alabama woman who said she was the sole caregiver for her five grandchildren, ruling that she had already received the tax relief she sought when the IRS decided not to collect her overdue taxes.

  • May 05, 2025

    Co. Urges Ending IRS Cost-Sharing Rule After Justices' Ruling

    A controversial rule requiring U.S. companies to include employee stock-based compensation in cost-sharing agreements with offshore affiliates should be scrapped following the U.S. Supreme Court's revocation of required judicial deference to agencies, a drug distributor told a Texas federal court in seeking a nearly $10 million tax refund.

  • May 05, 2025

    Novelist Owes $715K In FBAR Penalties, US Says

    A Japanese author with U.S. citizenship faces penalties exceeding $715,000 for failing to report accounts she held at a Swiss bank, the U.S. government told a California federal court.

  • May 02, 2025

    Tax Case Can Proceed Despite Late Name Change, Court Says

    The owner of a mail-order medical equipment company can move forward with his lawsuit against the federal government seeking to deduct a $5 million settlement payment, even though he didn't technically add his name to the case until after the deadline, the Court of Federal Claims said.

  • May 02, 2025

    Money Laundering, Tax Charges Nixed Vs. Crypto Operator

    An Indiana federal judge dismissed the U.S. government's cases against a man accused of operating an unlicensed money transmitting business, laundering proceeds through cryptocurrency transactions and failing to file tax returns after finding his business was not subject to registration requirements, as the government had maintained.

  • May 02, 2025

    Nixon Peabody Appoints Finance, Tax Partner As DC Leader

    Nixon Peabody LLP has appointed a more than 20-year veteran of the firm as its Washington, D.C., office managing partner, who focuses his practice on a range of corporate, finance and real estate matters, according to a Thursday announcement.

  • May 02, 2025

    Groups Seek Order Halting Trump's Restructuring Of Gov't

    A California district court must stop federal agencies from moving ahead with President Donald Trump's directive to reorganize and terminate government workers, unions and other groups argued, calling for a temporary restraining order based on alleged harms from the administration's "radical restructuring."

  • May 02, 2025

    White House Budget Seeks $2.5B Cut From IRS Funding

    The Internal Revenue Service's budget would be cut by nearly $2.5 billion compared with 2025 under the 2026 budget request released Friday by President Donald Trump's administration.

  • May 02, 2025

    IRS Updates Rates For Foreign Insurance Company Equations

    The Internal Revenue Service on Friday published updated domestic asset/liability and yields percentages for 2024 that foreign life insurance companies and foreign property and liability insurance companies need to compute their minimum effectively connected net investment income.

  • May 02, 2025

    Taxation With Representation: Goodwin, Haynes Boone

    In this week's Taxation With Representation, Merck buys SpringWorks Therapeutics, Novartis AG acquires Regulus Therapeutics Inc., Sabre Corp. sells its Hospitality Solutions business to private equity shop TPG, and TWG Global and Mubadala Capital team up to bolster their investments.

  • May 02, 2025

    Community Groups Accept Pause In CTA Litigation

    A group of community associations has told the Fourth Circuit they aren't opposed to a government motion to pause litigation over the Corporate Transparency Act, even as they maintained the information disclosure law aimed at small businesses still carries constitutional flaws.

  • May 02, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included its announcement of plans to revoke partnership basis-shifting regulations that were finalized earlier this year.

  • May 01, 2025

    IRS Successfully Targeting Rich Nonfilers, But Can Improve

    The Internal Revenue Service's targeted sweeps of so-called high-income nonfilers have largely been successful in closing cases and collecting revenue, but the agency could do more to target certain areas and collect tracking data better, the Treasury Inspector General for Tax Administration said.

  • May 01, 2025

    Multinationals Grapple With Tariff-Induced Pricing Issues

    President Donald Trump's flurry of tariff actions since taking office has created new questions for multinationals and their transfer pricing tax planners, including how to properly account for cost increases associated with new duties in related party transactions.

Expert Analysis

  • Perfecting Security Interests In Renewable Energy Tax Credits

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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
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    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.

  • IRS Should Revise Overbroad Microcaptive Regs

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    Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.

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