The Fifth Circuit has issued a long-awaited opinion holding that partners with limited liability under state law qualify for an exclusion from the self-employment tax, and the decision offers five notable takeaways that experts said may shed light on the potential fate of partnership taxation and compliance.
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Analysis

5 Takeaways From 5th Circ.'s Limited Partner Tax Decision

By Kat Lucero

The Fifth Circuit has issued a long-awaited opinion holding that partners with limited liability under state law qualify for an exclusion from the self-employment tax, and the decision offers five notable takeaways that experts said may shed light on the potential fate of partnership taxation and compliance.

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IRS Urges Tax Court To Cut $315M From Siemens Deduction

By Natalie Olivo

The Internal Revenue Service defended its slashing of $315 million from a tax deduction that medical giant Siemens claimed on payments from overseas, telling the U.S. Tax Court that rule writers had congressional backing to issue the regulations underpinning the adjustment.

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Goldstein Accountant Admits Tax Return Errors

By Jared Foretek

A star government witness and the top outside accountant for SCOTUSblog founder Thomas Goldstein and his law firm admitted to making mistakes on Goldstein's tax returns and offering the grand jury erroneous testimony, under cross-examination in the U.S. Supreme Court lawyer's tax fraud trial Wednesday.

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Dem Sens. Press Treasury, AG Over $10B Trump Tax Leak Suit

By Asha Glover

Two Senate Finance Committee Democrats pressed Treasury Secretary Scott Bessent and Attorney General Pam Bondi on whether Treasury was working with President Donald Trump to secure him a settlement in his $10 billion taxpayer privacy lawsuit against the IRS, according to a letter released Wednesday.

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Tax Group Of The Year: Davis Polk

By Sanjay Talwani

Davis Polk & Wardwell LLP scored a significant victory for Exxon Mobil in litigation concerning the tax treatment of a major partnership with Qatar and oversaw several other complex, high-stakes transactions, earning it recognition as a 2025 Law360 Tax Practice Group of the Year.

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Law360 Seeks Members For Its 2026 Editorial Boards

Law360 is looking for avid readers of our publications to serve as members of our 2026 editorial advisory boards.

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LITIGATION

Tax Court Urged To Restore $43M Break For Historic Buildings

By Anna Scott Farrell

A partnership argued for restoring its $43 million tax deduction for protecting historic property in Kentucky that included a 19th century post office, telling the U.S. Tax Court that the IRS had arbitrarily rejected its claim.

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Trump Bid To Move NY Appeal Faces 'Fatal' Error, Judge Says

By Frank G. Runyeon

A Manhattan federal judge on Wednesday repeatedly aired doubts that President Donald Trump can upend the pending New York state appeal of his hush-money conviction by moving the case to federal court.

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TAX POLICY

US House Votes To Overturn DC Tax Code Changes

By Maria Koklanaris

A Washington, D.C., local law that uncouples elements of the city's tax code from federal tax law would be repealed under a resolution passed in the U.S. House of Representatives on Wednesday.

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COMMENTS ON REGULATIONS

Walmart Wants Relief In CFC Tax Year Deferral

By Anna Scott Farrell

Walmart asked the U.S. Department of the Treasury to temporarily allow certain taxpayers to file a single 13-month return, instead of two separate returns, in the wake of filing changes regarding controlled foreign corporations, according to a letter released Wednesday.

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Law360 Tax Authority Map

LAW FIRMS IN TODAY'S NEWS

Akerman LLP

Akin Gump

Davis Polk

Dentons

Goldstein & Russell

Kirkland & Ellis

Latham & Watkins

Munger Tolles

Rosenberg Freedman

Sullivan & Cromwell

COMPANIES IN TODAY'S NEWS

3M Co.

Booz Allen Hamilton Holding Corp.

Comcast Corp.

Denham Capital Management LP

Exxon Mobil Corp.

Ferrero International SA

Kellanova Co.

Kellogg Co.

Managed Funds Association

Mars Inc.

New York University

Parabellum Capital LLC

S&P Global Inc.

Sirius Solutions LLLP

The New York Times Co.

Trump Organization Inc.

Walmart Inc.

GOVERNMENT AGENCIES IN TODAY'S NEWS

Internal Revenue Service

Manhattan District Attorney's Office

Social Security Administration

U.S. Attorney's Office for the District of Maryland

U.S. Department of Justice

U.S. Department of the Treasury

U.S. District Court for the District of Maryland

U.S. District Court for the Northern District of Texas

U.S. District Court for the Southern District of New York

U.S. House of Representatives

U.S. Senate

U.S. Supreme Court

U.S. Tax Court