Judge Says Eaton Moved $14B Subsidiary For Tax Purposes

By Molly Moses

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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IRS To Revamp Voluntary Disclosure Program

By Kat Lucero

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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DOJ Shake-Up Keeps Criminal Tax Meetings, Ex-Official Says

By Kat Lucero

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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Treasury Issues Final Rules For Taxing Foreign Gov't Income

By Kevin Pinner

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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Nonprofits Face Uncertainty Over Political Activity Rules

Two federal court decisions suggesting that the Internal Revenue Service's rules for 501(c)(4) organizations' political activity may be too vague to survive constitutional scrutiny leave nonprofit organizations caught between constitutional limits on government regulation of speech and tax limits on their exempt status, say attorneys at BakerHostetler.

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Opinion

Supreme Court Term Limits Would Carry Hidden Risk

While proposals for limiting the terms of U.S. Supreme Court justices are popular, a steady stream of relatively young, highly marketable ex-justices with unique knowledge and influence entering the marketplace of law and politics could create new problems, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.

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Tariffs And Trade Volatility Drove 2025 Bankruptcy Wave

The Trump administration's tariff regime has reshaped the commercial restructuring landscape this year, with an increased number of bankruptcy filings showing how tariffs are influencing first‑day narratives, debtor-in-possession terms and case strategies, say attorneys at Thompson Hine.

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New Scholarship Tax Credit Plan Open To States, IRS Says

By Michael Nunes

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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IRS Sets 2026 Wage Base For Covered Compensation

By Michael Nunes

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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Treasury Withdraws Proposed Regs On Spousal Tax Liability

By Kevin Pinner

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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Weekly Internal Revenue Bulletin

By Jack McLoone

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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Roundup

Taxation With Representation: Cravath, Skadden, Debevoise

By Zak Kostro

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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