
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.

Ore. Sen. Again Delays Vote On $4.3B Transportation Tax Hike
For the second time, Oregon lawmakers delayed the final vote on a transportation bill with $4.3 billion in tax and fee increases, as Senate Democrats await the return of a lawmaker facing health issues whose vote may be needed for passage.

HMRC Tightens Tax Rules For Umbrella Companies
Recruiters and their clients in the U.K. will be jointly liable for tax avoidance by businesses using umbrella companies to pay temporary workers, Britain's tax authority said in guidance issued Wednesday.
Federal More
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 constitutio... (more story)
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 o... (more story)
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 recu... (more story)
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 t... (more story)
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... (more story)
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.
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 penal... (more story)
State & Local More
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 const... (more story)
CarMax Distorted Business Activity, SC Tells Appeals Court
CarMax used intercompany transactions to distort an entity's business activity and its tax burden in South Carolina, the state's tax agency told an appeals court, urging it to uphold the finding of an administ... (more story)
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 ... (more story)
Arby's Sale Produced Business Income, Ark. Justices Told
A trial court employed the wrong test in deciding a defunct corporation that was the largest Arby's franchisee didn't earn business income in Arkansas when it sold the brand, the Arkansas tax department told t... (more story)
Loeb & Loeb Opens DC-Area Office With Ex-Reed Smith Attys
Loeb & Loeb LLP announced Tuesday the opening of a new office in Virginia, along with the arrival of an eight-person private client and tax controversy staff formerly of Reed Smith LLP.
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 hel... (more story)
Mass. Bill Seeks Graduated Real Estate Transfer Tax
Massachusetts would boost taxes on most real estate transfers with a graduated rate to raise revenue for affordable housing efforts under legislation heard Monday by a joint legislative panel.
Kingsley Napley Bags Private Client Pro To Head Tax Desk
Kingsley Napley LLP said Monday that it has hired Paul Davidoff to head its international tax desk as the firm deals with a surge in work connected with tax and trusts amid an exodus of high-net-worth individu... (more story)
Justices' Tariff-Suit Review Halts Case In Texas Federal Court
A Texas federal court has postponed further proceedings in a suit challenging President Donald Trump's emergency tariffs until the U.S. Supreme Court considers matters involving similar claims that were taken ... (more story)
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 const... (more story)
CarMax used intercompany transactions to distort an entity's business activity and its tax burden in South Carolina, the state's tax agency told an appeals court, urging it to uphold the finding of an administ... (more story)
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 ... (more story)
A trial court employed the wrong test in deciding a defunct corporation that was the largest Arby's franchisee didn't earn business income in Arkansas when it sold the brand, the Arkansas tax department told t... (more story)
Loeb & Loeb LLP announced Tuesday the opening of a new office in Virginia, along with the arrival of an eight-person private client and tax controversy staff formerly of Reed Smith LLP.
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 hel... (more story)
Massachusetts would boost taxes on most real estate transfers with a graduated rate to raise revenue for affordable housing efforts under legislation heard Monday by a joint legislative panel.
Kingsley Napley LLP said Monday that it has hired Paul Davidoff to head its international tax desk as the firm deals with a surge in work connected with tax and trusts amid an exodus of high-net-worth individu... (more story)
A Texas federal court has postponed further proceedings in a suit challenging President Donald Trump's emergency tariffs until the U.S. Supreme Court considers matters involving similar claims that were taken ... (more story)
International More
Cadwalader Hires Trans-Atlantic Katten Private Wealth Partner
An international private wealth partner from Katten Muchin Rosenman LLP has jumped to Cadwalader Wickersham & Taft LLP as a partner in the firm's London and New York offices, Cadwalader announced Tuesday.
US, China Agree On TikTok Ownership Transfer, Bessent Says
The U.S. and China established a commercial framework for a deal with video sharing giant TikTok to transfer ownership of the app to the U.S., just days before a deadline to sell the app or shut it down, U.S. ... (more story)
Court Urged To Block Offshore Asset Freeze In $28M Tax Row
The federal government's claim that a beneficiary of offshore trusts is likely to spend down assets to avoid a $28 million tax bill lacks evidence, the beneficiary argued in urging a Florida federal court not ... (more story)
Employers Expect Budget Reform On Pension Salary Sacrifice
Nine out of 10 U.K. employers expect the government to ditch tax breaks on pension salary-sacrifice arrangements when it unveils its autumn Budget, a survey has found.
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, a... (more story)
Taxation With Representation: Felesky Flynn, Gibson, Kirkland
In this week's Taxation With Representation, copper mining companies Anglo American and Teck Resources plan to merge, EchoStar agrees to sell spectrum licenses to SpaceX, and Diversified Energy acquires fellow... (more story)
French Court Rejects Challenge To Digital Services Tax
France's digital services tax is consistent with the country's constitution, the country's Constitutional Council said Friday in a decision that rejected arguments put forward by several companies concerning t... (more story)
An international private wealth partner from Katten Muchin Rosenman LLP has jumped to Cadwalader Wickersham & Taft LLP as a partner in the firm's London and New York offices, Cadwalader announced Tuesday.
The U.S. and China established a commercial framework for a deal with video sharing giant TikTok to transfer ownership of the app to the U.S., just days before a deadline to sell the app or shut it down, U.S. ... (more story)
The federal government's claim that a beneficiary of offshore trusts is likely to spend down assets to avoid a $28 million tax bill lacks evidence, the beneficiary argued in urging a Florida federal court not ... (more story)
Nine out of 10 U.K. employers expect the government to ditch tax breaks on pension salary-sacrifice arrangements when it unveils its autumn Budget, a survey has found.
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, a... (more story)
In this week's Taxation With Representation, copper mining companies Anglo American and Teck Resources plan to merge, EchoStar agrees to sell spectrum licenses to SpaceX, and Diversified Energy acquires fellow... (more story)
France's digital services tax is consistent with the country's constitution, the country's Constitutional Council said Friday in a decision that rejected arguments put forward by several companies concerning t... (more story)