Federal
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May 09, 2025
'Proud' Judge Says No Prison For $1.3B Tax Fraud Witnesses
A Georgia federal judge handed down a pair of what he called "stunningly lenient" no-prison sentences Friday to two brothers who served as key cooperating witnesses in a first-of-its-kind federal case against a sprawling, $1.3 billion tax fraud scheme.
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May 09, 2025
PL 86-272 Expansion May Face Rocky Path Through Congress
The fate of an element of a House budget reconciliation bill that would broaden state income tax protections for businesses may rest with the Senate parliamentarian's view on whether the provision passes muster under reconciliation rules.
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May 09, 2025
Tariffs And Tax Breaks Offer Risky Lifeline To US Film Industry
President Donald Trump's call for a 100% tariff on films made outside the U.S. has potential to improve a struggling domestic industry if it is considered in conjunction with new federal tax incentives to restore production, but the idea hasn't yet gathered support in Congress, according to lawyers who spoke to Law360.
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May 09, 2025
IRS Cuts May Hinder Prep For 2026 If TCJA Is Renewed
Internal Revenue Service staff cuts and retirements could hamper planning for next year's filing season if Congress renews the 2017 tax overhaul this year as planned while withholding resources needed to modernize the agency's systems, a former agency commissioner warned Friday.
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May 09, 2025
US Seeking A Global Minimum Tax Carveout, Official Says
The U.S. tax system is "robust enough" for other countries to refrain permanently from applying the 15% global minimum tax to any income that the U.S. taxes or monitors, but an arrangement must be struck before a safe harbor expires, a Treasury Department official said Friday.
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May 09, 2025
Express Scripts To Appeal Denied Tax Break In $43M Suit
Express Scripts is appealing rulings denying it a $43 million tax refund for domestic production activities after a Missouri federal court said the company did not qualify because it did not grant licenses to pharmacy benefit plan sponsors who used its software, the pharmacy benefit manager said Friday.
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May 09, 2025
Tax Exemption Case May Bring Sweeping Impact, Attys Say
A U.S. Supreme Court case considering a religious exemption to unemployment taxes sought by a charity could have implications across a broad swath of organizations, tax practitioners said Friday.
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May 09, 2025
Souter's Clerks Remember Him As Humble, Kind And Caring
Former clerks of retired U.S. Supreme Court Justice David H. Souter are heartbroken over the death of a man many of them remember more for his conscientiousness, humility, kindness and disdain for the spotlight than for his undeniable brilliance as a jurist.
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May 09, 2025
Hiker And 'Raconteur': Atty Recalls 50-Year Bond With Souter
Behind a towering legal legacy was a man who loved to hike mountains, could recall details of things he read decades ago and was always there for those he cared about, a New Hampshire attorney said as he reflected on a lifelong friendship with U.S. Supreme Court Justice David Souter.
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May 09, 2025
A Look At David Souter's Most Significant Opinions
The retired Justice David Souter defied simple definition, viewed as a staunch conservative until he co-wrote an opinion upholding abortion rights in 1992. He did not hew to partisan lines, but reshaped the civil litigation landscape and took an unexpected stand in an extraordinarily close presidential election.
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May 09, 2025
McKernan Out As Trump's CFPB Pick, In For Treasury Role
President Donald Trump will pull Jonathan McKernan's nomination to run the Consumer Financial Protection Bureau and tap him instead for a top domestic finance job at the U.S. Treasury Department, a White House official confirmed to Law360 on Friday.
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May 09, 2025
IRS To Loosen Tax-Free Spinoff Regs, Cut Ordinary Biz Rule
The Internal Revenue Service plans to loosen proposed regulations for corporate separation transactions, known as spinoffs, that the agency approves as tax-free ahead of time, in part by eliminating a standard considering whether actions are taken in the ordinary course of business, officials said Friday.
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May 09, 2025
Family Denies Knowledge Of $81M Tax Avoidance Scheme
The government's claims that members of a deceased theater businessman's family knew or should have known their company stock sale was part of an $81 million purported tax avoidance scheme are baseless, the family members said in a filing in New York federal court.
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May 09, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the reference price for enhanced oil recovery tax credits for calendar year 2024.
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May 09, 2025
Justice Souter Was An Unexpected Force Of Moderation
Justice David Souter, who saw the high court as a moderating force apart from the messiness of politics, subverted the expectations of liberals and conservatives alike during his 19 years on the bench.
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May 09, 2025
Taxation With Representation: Paul Weiss, Weil, V&E, Torys
In this week's Taxation With Representation, 3G Capital takes Skechers private, Sunoco LP buys Parkland Corp., and BCE Inc. and the Public Sector Pension Investment Board launch a wholesale network provider called Network FiberCo.
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May 09, 2025
Retired Supreme Court Justice David Souter Dies At 85
Retired Justice David H. Souter, who served on the U.S. Supreme Court from 1990 to 2009, has died at 85, the court announced Friday.
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May 08, 2025
Trump Admin Defends Gov't Restructuring As Lawful
The Trump administration defended what it says is a lawful executive order looking to reorganize agencies and terminate workers, telling a California federal judge that unions, nonprofits and local governments "waited far too long" to seek a temporary restraining order.
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May 08, 2025
Hyatt's $300M From Reward Program Is Income, 7th Circ. Told
Hyatt Hotels should have to report nearly $300 million in revenue from a rewards program fund because it benefited from spending the money, including through advertising for its properties, the U.S. government told the Seventh Circuit on Thursday, defending a U.S. Tax Court ruling.
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May 08, 2025
NFTC Warns US Against Tariffs On Semiconductors, Pharma
The Trump administration should work to avoid using tariffs to address the perceived threat to national security caused by importing semiconductors and pharmaceuticals, the National Foreign Trade Council said, calling for extreme caution.
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May 08, 2025
Widow Says Husband's Estate Liable For $2M FBAR Fines
A nonagenarian widow told an Idaho federal court Thursday that her husband's estate — not she — should be liable for more than $2 million in penalties for his unreported foreign accounts, calling the government's attempt to penalize her an unprecedented overreach.
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May 08, 2025
Milbank Hires King & Spalding Tax Planning Atty In DC
Milbank LLP has added a former King & Spalding LLP tax attorney as a partner in its global project, energy and infrastructure finance group in Washington, D.C.
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May 07, 2025
Bessent Defends Cuts To Community Fund Amid Scrutiny
U.S. Treasury Secretary Scott Bessent on Wednesday defended the Trump administration's proposal to significantly slash the fund that operates the new markets tax credit, which is meant to boost investment in poor communities, telling lawmakers that a new $100 million program would better support affordable financing in rural areas.
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May 07, 2025
Favorable Tax Cut Baseline Won't Fool Lenders, House Told
If Congress uses a current policy baseline to permanently extend the 2017 tax overhaul's provisions, it will be a red flag to institutional investors, such as hedge funds, mutual funds and endowments, panelists told the House Budget Committee on Wednesday.
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May 07, 2025
Tax Court Rejects Couple's Case For Lacking Evidence
A couple who challenged what the Internal Revenue Service said was their more than $650,000 in tax debt provided no evidence that the number was wrong, the U.S. Tax Court said in a bench opinion released Wednesday.
GOP Unveils Plan To Cement 2017 Tax Cuts, Expand Biz Relief
House Republicans plan to meet Tuesday to deliberate a sweeping extension of their 2017 tax overhaul that would lock in low individual rates and deduction limits, expand child care and estate tax breaks, and make permanent tax incentives for small pass-through businesses and U.S. multinational corporations.
11th Circ. Judge Frowns On New Arguments In Easement Case
An Eleventh Circuit judge disapproved of a Georgia partnership raising new arguments on appeal as it pursues a tax deduction for a conservation easement donation, saying Thursday that perhaps "we wouldn't be here" if the partnership had argued the points before the lower court.
6th Circ. Skeptical Of US In Tax Court Deadline Case
Sixth Circuit judges expressed skepticism of the U.S. government's claim that the 90-day deadline to petition the U.S. Tax Court is inflexible, with one judge saying during oral arguments Wednesday in a woman's case challenging the rule that the U.S. Supreme Court seemed to back her.
GOP Unveils Plan To Cement 2017 Tax Cuts, Expand Biz Relief
House Republicans plan to meet Tuesday to deliberate a sweeping extension of their 2017 tax overhaul that would lock in low individual rates and deduction limits, expand child care and estate tax breaks, and make permanent tax incentives for small pass-through businesses and U.S. multinational corporations.
11th Circ. Judge Frowns On New Arguments In Easement Case
An Eleventh Circuit judge disapproved of a Georgia partnership raising new arguments on appeal as it pursues a tax deduction for a conservation easement donation, saying Thursday that perhaps "we wouldn't be here" if the partnership had argued the points before the lower court.
6th Circ. Skeptical Of US In Tax Court Deadline Case
Sixth Circuit judges expressed skepticism of the U.S. government's claim that the 90-day deadline to petition the U.S. Tax Court is inflexible, with one judge saying during oral arguments Wednesday in a woman's case challenging the rule that the U.S. Supreme Court seemed to back her.
Featured Stories
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PL 86-272 Expansion May Face Rocky Path Through Congress
The fate of an element of a House budget reconciliation bill that would broaden state income tax protections for businesses may rest with the Senate parliamentarian's view on whether the provision passes muster under reconciliation rules.
-
Tariffs And Tax Breaks Offer Risky Lifeline To US Film Industry
President Donald Trump's call for a 100% tariff on films made outside the U.S. has potential to improve a struggling domestic industry if it is considered in conjunction with new federal tax incentives to restore production, but the idea hasn't yet gathered support in Congress, according to lawyers who spoke to Law360.
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Souter's Clerks Remember Him As Humble, Kind And Caring
Former clerks of retired U.S. Supreme Court Justice David H. Souter are heartbroken over the death of a man many of them remember more for his conscientiousness, humility, kindness and disdain for the spotlight than for his undeniable brilliance as a jurist.
Expert Analysis
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Mitigating Import Risks Around Southeast Asian Solar Cells
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The U.S. Department of Commerce's recent final determinations in its antidumping and countervailing duty investigations into solar cells produced in certain Southeast Asian countries make it important for U.S. purchasers to consider risk mitigation strategies, including modifying supply chains and contractually assigning import responsibilities, say attorneys at Morgan Lewis.
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Reassessing Corporate Separateness After Explosion Of LLCs
Following the dramatic increase of limited liability companies in the U.S., the Corporate Transparency Act's enactment and the Trump administration's subsequent narrowing of that law, it's worth revisiting the underlying legal principles that govern shell companies in order to remedy the problems that initially motivated the CTA, says Jeff Newton at Omni Bridgeway.
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Crisis Management Lessons From The Parenting Playbook
The parenting skills we use to help our kids through challenges — like rehearsing for stressful situations, modeling confidence and taking time to reset our emotions — can also teach us the fundamentals of leading clients through a corporate crisis, say Deborah Solmor at the Wisconsin Alumni Research Foundation and Cara Peterman at Alston & Bird.
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Immunity Waiver Ruling A Setback For Ch. 7 Trustees
While governmental units should welcome the U.S. Supreme Court's recent decision in U.S. v. Miller restricting the reach of the Bankruptcy Code's sovereign immunity waiver, Chapter 7 trustees now have a limited ability to maximize bankruptcy estates, says Dan Prieto at Jones Day.
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Adapting To Private Practice: From NY Fed To BigLaw
While the move to private practice brings a learning curve, it also brings chances to learn new skills and grow your network, requiring a clear understanding of how your skills can complement and contribute to a firm's existing practice, and where you can add new value, says Meghann Donahue at Covington.
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Top 3 Litigation Finance Deal-Killers, And How To Avoid Them
Like all transactions, litigation finance deals can sometimes collapse, but understanding the most common reasons for failure, including a lack of trust or a misunderstanding of deal terms, can help both parties avoid problems, say Rebecca Berrebi at Avenue 33 and Boris Ziser at Schulte Roth.
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A 2-Step System For Choosing A Digital Asset Reporting Path
Under the Internal Revenue Service's new digital asset reporting regulation, each type of asset may have three potential reporting destinations, so a detailed testing framework can help to determine the appropriate path, says Keval Sonecha at Sonecha & Amlani.
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How Attys Can Use A Therapy Model To Help Triggered Clients
Attorneys can lean on key principles from a psychotherapeutic paradigm known as the "Internal Family Systems" model to help manage triggered clients and get settlement negotiations back on track, says Jennifer Gibbs at Zelle.
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3 Steps For In-House Counsel To Assess Litigation Claims
Before a potential economic downturn, in-house attorneys should investigate whether their company is sitting on hidden litigation claims that could unlock large recoveries to help the business withstand tough times, says Will Burgess at Hilgers Graben.
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IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement
Tax crimes are historically difficult to prosecute, but the Internal Revenue Services’ recent agreement with U.S. Immigration and Customs Enforcement to share taxpayer records of non-U.S. citizens could be used to enhance payroll tax-related enforcement against their employers, say attorneys at Holland & Knight.
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Adapting To Private Practice: From DOJ Enviro To Mid-Law
Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares their principles, values their experience and will invest in their transition, says John Cruden at Beveridge & Diamond.
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Legal Ethics Considerations For Law Firm Pro Bono Deals
If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.
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10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks
The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.