Federal

  • October 24, 2025

    Partnership Fights For $15M Easement Deduction In Tax Court

    The Internal Revenue Service didn't explain its determinations and therefore violated administrative law when it denied an Alabama partnership a $14.8 million deduction for donating a conservation easement in 2020, the partnership told the U.S. Tax Court.

  • October 23, 2025

    Legislation May Fix Tax Court Jurisdiction Feud, Judge Says

    Senate legislation to expand the U.S. Tax Court's authority to order refunds and credits in collection cases could settle a long-running dispute revived by the U.S. Supreme Court's decision to limit the tax tribunal's jurisdiction, a judge said Thursday.

  • October 23, 2025

    Fed. Circ. Affirms No Tax Refunds For Retired United Pilots

    United Airlines pilots who said they overpaid payroll taxes because of the early termination of their retirement plan in the company's bankruptcy can't get partial refunds, the Federal Circuit affirmed Thursday, saying procedural issues doomed their case.

  • October 23, 2025

    Tech Co. Goes After $1.4M IRS Adjustments In Tax Court

    An internet platform company that helps video game developers launch their games challenged $1.4 million in IRS adjustments to its tax return in the U.S. Tax Court, alleging the agency incorrectly told the company to report its software development costs as capital expenses.

  • October 23, 2025

    US Oil Cos. Pay More Tax Abroad Than At Home, Report Says

    American oil and gas companies with foreign extraction operations paid more than 80% of their total taxes abroad in recent years despite producing more oil and gas in the U.S. than everywhere else combined, a corporate transparency group said Thursday.

  • October 23, 2025

    IRS To Float Sourcing Rules For Certain Securities Loans

    The Internal Revenue Service said Thursday it intends to propose regulations that would have it look to the borrower of certain securities, rather than the lender, when determining whether related payments are sourced from the United States.

  • October 23, 2025

    IRS FAQs Include $20K Payment Reporting Requirement

    The Internal Revenue Service updated its FAQs on Thursday to include the budget reconciliation bill's reversal of a law requiring peer-to-peer payment platforms such as Venmo and PayPal to report aggregate payments of $600 or more.

  • October 23, 2025

    Court Won't Rethink 'Survivor' Winner's $3M Tax Bill

    A Rhode Island federal judge won't reconsider his opinion that the first winner of reality show "Survivor" must pay $3.3 million in taxes, maintaining that it is unclear whether the federal government can take his sister's property to pay down the debt.

  • October 23, 2025

    Eaton To Defend Interest Rates, Fees Paid After 2012 Inversion

    Eaton is preparing to defend the interest rates and guarantee fees paid by entities in the U.S. to their newly formed Irish parent after the company's 2012 acquisition and inversion at a U.S. Tax Court trial scheduled to start Nov. 3.

  • October 22, 2025

    Tax Co.'s Push To Escape Sex Harassment Verdict Falls Short

    An Idaho federal judge rejected a tax business's bid Wednesday to escape potential liability for a $111,000 sexual harassment verdict won by a worker who claimed that the tax company acquired her former employer so that her ex-boss could avoid paying out on her lawsuit.

  • October 22, 2025

    US Among Few Places With Amount B Rules, OECD Reports

    The U.S. is a significant exception to a swath of countries, including China, Japan and the U.K., that lack domestic rules allowing companies to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, the OECD reported Wednesday.

  • October 22, 2025

    Innocent Spouse Claim Is Barred, Tax Court Says

    The wife of a man who failed to report overseas income is on the hook for the couple's shared tax liabilities, the U.S. Tax Court ruled Wednesday, rejecting her request to be cleared under a provision protecting spouses who are unaware of a partner's dealings.

  • October 22, 2025

    Tax Court Judge Warns Against Unchecked AI Use In Filings

    A U.S. Tax Court judge cautioned attorneys Wednesday against relying on artificial intelligence to write filings without verifying the information it generates, saying recent "unfortunate incidents" have prompted the court to double down on accuracy in using such tools.

  • October 22, 2025

    IRS Releases FAQs For Employee Retention Credits

    The IRS issued answers Wednesday to a set of frequently asked questions related to the limitations for the fraud-riddled employee retention tax credit program that were implemented under the budget reconciliation law.

  • October 22, 2025

    'The Right Facts' Can Reduce Cos.' Tariff Impacts, Atty Says

    Multinational companies with U.S. distributors that typically bear fewer business risks and earn low profit margins may be able to mitigate the effect of U.S. tariffs on their business as a whole by having a foreign principal bear the tariff costs, an attorney said Wednesday.

  • October 22, 2025

    Belgian Gov't Looks To Overturn US Tax Data Transfer Ruling

    Belgium's data privacy watchdog was wrong to rule that the transfer of personal tax information to the U.S. breaks European Union law, the Belgian government told a Brussels court Wednesday, because the practice was established before the EU's data protection law took effect.

  • October 22, 2025

    Presidential Firing Limits Fight Builds At High Court

    The ousted U.S. Merit Systems Protection Board chair has encouraged the U.S. Supreme Court to include a caveat for "legislative courts" if it overturns precedent that empowers Congress to limit the president's authority to fire certain agency officials, but opponents of independent agencies want a clean break from the status quo. 

  • October 22, 2025

    Senate Sends IRS Clerical Error Correction Bill To Trump

    A bill that would allow the IRS to adjust tax assessments to correct mathematical or clerical errors is headed to President Donald Trump's desk for his signature after the Senate approved the legislation, a senator who co-sponsored a related bill said Wednesday.

  • October 22, 2025

    Trade Court OKs $235K Tax Bill On Korean Soju Imports

    South Korean alcoholic beverages were improperly classified upon entering the U.S., and U.S. Customs and Border Protection correctly calculated a nearly $235,000 bill in unpaid federal excise taxes plus interest, according to the U.S. Court of International Trade.

  • October 22, 2025

    Widow Not Liable For Husband's Tax Debt, 4th Circ. Told

    An 80-year-old widow whose husband was imprisoned after hiding more than $20 million from the IRS told the Fourth Circuit that he was "abusive and controlling" and that she shouldn't have to pay the millions of dollars they jointly owe, despite contrary claims by the government.

  • October 22, 2025

    Construction Co. Owner Hid Income, Tax Court Says

    A man who said he was a former officer of a California construction company was actually a 50% shareholder and failed to report income for 2016, including money diverted from a client to the purchase of a motor home, the U.S. Tax Court found.

  • October 21, 2025

    Nonprofits Face Pressure From GOP Tax Changes, Aides Say

    Nonprofit organizations, charities and universities face sweeping changes under the Republicans' 2025 tax overhaul, Capitol Hill staffers said Tuesday, pointing to higher taxes on executive pay and endowments alongside revamped limits and incentives for individuals and corporations claiming charitable deductions.

  • October 21, 2025

    Partnership Deadline To Dispute IRS Is Fixed, Tax Court Says

    A deadline to petition the U.S. Tax Court to challenge IRS adjustments to partnership returns is effectively fixed and cannot be extended, the court said Tuesday in a reviewed decision that denied an Alabama LLC's late bid to restore a $46 million deduction for donating to charity.

  • October 21, 2025

    Discovery Against Gem Company Halted In Malawi's Tax Probe

    Malawi's government can no longer proceed with discovery against a gemstone company that partnered with a mining outfit the country claims evaded billions of dollars in taxes and royalties on exported rubies and sapphires, a Washington federal judge ruled, vacating his own order.

  • October 21, 2025

    CPA Group Calls For Transition Relief For Tips, OT Deductions

    Internal Revenue Service guidance related to reporting requirements for the new deductions for tips and overtime should include a safe harbor for businesses for the 2025 tax year, the American Institute of Certified Public Accountants said in a letter released Tuesday.

Expert Analysis

  • Junior Attys Must Beware Of 5 Common Legal Brief Mistakes

    Excerpt from Practical Guidance
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    Junior law firm associates must be careful to avoid five common pitfalls when drafting legal briefs — from including every possible argument to not developing a theme — to build the reputation of a sought-after litigator, says James Argionis at Cozen O'Connor.

  • Digital Asset Report Opens Doors For Banks, But Risks Linger

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    A recent report from a White House working group discussing digital asset market structure signals how banks may elect to expand into digital asset custody, trading and related services in the years ahead, but the road remains layered with challenges, say attorneys at Foley & Lardner.

  • Power To The Paralegals: How And Why Training Must Evolve

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    Empowering paralegals through new models of education that emphasize digital fluency, interdisciplinary collaboration and human-centered lawyering could help solve workforce challenges and the justice gap — if firms, educators and policymakers get on board, say Kristine Custodio Suero and Kelli Radnothy.

  • 5 Real Estate Takeaways From Trump's Sweeping Tax Law

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    Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.

  • Evaluating The Current State Of Trump's Tariff Deals

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    As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.

  • How Hyperlinks Are Changing E-Discovery Responsibilities

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    A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.

  • Preserving Refunds As Tariffs Await Supreme Court Weigh-In

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    In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.

  • Revamped Opportunity Zones Can Aid Clean Energy Projects

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    The Qualified Opportunity Zone program, introduced in 2017 and reshaped in the One Big Beautiful Bill Act, offers investors federal tax incentives for development in low-income communities — incentives that are especially meaningful for clean energy projects, where capital-intensive infrastructure and long-term planning are essential, say attorneys at Dentons.

  • Writing Musicals Makes Me A Better Lawyer

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    My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.

  • How Fashion, Tech Can Maximize New Small Biz Tax Breaks

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    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 become eligible for expanded research and experimental expenditure credits and qualified small business stock incentives, says Aime Salazar at Olshan Frome.

  • Adapting To Private Practice: From Va. AUSA To Mid-Law

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    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 constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.

  • 7 Document Review Concepts New Attorneys Need To Know

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    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 help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.

  • Agentic AI Puts A New Twist On Attorney Ethics Obligations

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    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, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.

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