Federal
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June 04, 2025
Tax Court Rejects Frivolous Wage Classification Argument
A woman's wages from her job at Fidelity Investments should have been reported as income on her and her husband's joint tax return, the U.S. Tax Court affirmed Wednesday, upholding the IRS' deficiency finding and also hit the couple with a penalty.
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June 04, 2025
Mother-Son Car Co. Owners Owe Penalties, Tax Court Says
A mother and son who owned a used car business owe tax penalties for failing to report corporate dividends, the U.S. Tax Court ruled Wednesday, saying the pair couldn't back up their claim that the state of California had seized the records they needed to defend themselves.
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June 04, 2025
Satellite Co. Execs Released In $250M Fraud, Evasion Case
Two more satellite company executives facing charges of tricking investors out of $250 million are being released after their leader, who was additionally accused of tax crimes, was deemed a flight risk, according to D.C. federal court documents.
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June 04, 2025
Loeb & Loeb Trusts And Estates Head Jumps To Proskauer
Proskauer Rose LLP has hired the former chair of Loeb & Loeb LLP's international trusts and estates practice group to represent ultra-high-net-worth individuals and families.
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June 03, 2025
DC Circ. Rejects Tipster's Bid To Reverse IRS Award Denial
The D.C. Circuit refused to reinstate a tipster's petition for a whistleblower award before the U.S. Tax Court claiming his former employer intentionally misclassified him as an independent contractor, ruling Tuesday the Tax Court lacked jurisdiction since he failed to show the agency acted on his tip.
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June 03, 2025
NY Family Partnership Fights $4.5M Income Shift In Tax Court
A New York family partnership challenged an Internal Revenue Service determination that it formed mainly to reduce the tax liability of one of its limited partners, telling the U.S. Tax Court that the agency wrongly shifted $4.5 million in income taxable to him.
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June 03, 2025
WTO Useful For China Enforcement, US Trade Nominee Says
The U.S. should work with partners at the World Trade Organization to apply further trade pressure on China, making sure the country is complying with rules and trading fairly, a Skadden partner nominated by President Donald Trump to represent the U.S. at the WTO told lawmakers Tuesday.
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June 03, 2025
OECD Predicts Growth Slowdown From US Tariffs, Responses
Trade barriers — most notably U.S. tariffs and other countries' reciprocal measures — could result in a slowdown in global economic growth, the Organization for Economic Cooperation and Development said Tuesday, projecting a dip over the next two years.
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June 03, 2025
Senate Panel Advances Trump's Pick To Lead IRS
The Senate Finance Committee approved President Donald Trump's selection of former U.S. Rep. Billy Long to serve as commissioner of the IRS on Tuesday, sending the nomination to the full Senate.
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June 03, 2025
Irish Court Says US Co.'s Irish Units Not Owed Treaty Benefits
Three Irish subsidiaries cannot benefit from the U.S.-Ireland tax treaty's provision of equally favorable treatment between U.S. and Irish residents because their ultimate parent entity, a Delaware financial firm, is disregarded for U.S. tax purposes, Ireland's Court of Appeal said in a judgment.
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June 03, 2025
The Law360 400: A Look At The Top 100 Firms
A rebound in client work sent the nation’s largest law firms into growth mode last year, driving a wave of hiring, mergers and strategic moves that reshaped the top tier of the Law360 400. Here's a preview of the 100 firms with the largest U.S. attorney headcounts.
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June 03, 2025
Precedent Does Apply To $6.6M Microcaptive Case, Court Told
A captive insurance program operator challenging $6.6 million in tax fraud penalties told a Pennsylvania federal court that the government boldly and incorrectly claimed that the U.S. Supreme Court's landmark ruling requiring a jury to make certain fraud findings doesn't apply to its case.
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June 02, 2025
Budget Bill Would Deepen Residential Solar's Woes
A Sunnova unit's bankruptcy declaration — the latest among dozens of solar companies that have struggled to stay afloat — adds to evidence of a floundering residential solar industry, which now faces further diminishing prospects under the federal budget reconciliation bill.
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June 02, 2025
1st Circ. Largely Backs Convictions For Cop Union Kickbacks
The First Circuit on Monday mostly upheld the convictions of a former Massachusetts state police union president and a Beacon Hill lobbyist who were found guilty of running a kickback scheme, but ordered new sentencing hearings for them after vacating some of the guilty findings.
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June 02, 2025
IRS Issues Interim Regs To Simplify Corp. AMT Determination
The Internal Revenue Service released temporary regulations Monday that offered a simplified method for large companies seeking to determine whether the 15% corporate alternative minimum tax applies to them, as well as penalty relief for those that underpaid the levy this year.
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June 02, 2025
Justices Urged To Reject Bid Disputing IRS Crypto Summons
The U.S. Supreme Court should not take up the case of a bitcoin investor who claimed the IRS violated his privacy when it seized his records from the cryptocurrency exchange, the government argued, saying the case is a poor vehicle for addressing concerns about digital-era transactions.
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June 02, 2025
4 Mass. Rulings You May Have Missed In May
Massachusetts judges grappled with accusations of fraud in the sale of a struggling life sciences company and gave the benefit of the doubt to a vendor who allegedly sold the state gallons of ineffective hand sanitizer, among other notable rulings last month.
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June 02, 2025
Tax Court Finds No Abuse By IRS In Rejecting Man's Tax Offer
The Internal Revenue Service did not abuse its discretion in rejecting a man's offer in compromise for the balance on a $400,000 tax bill, the U.S. Tax Court ruled Monday, saying the agency properly considered cash in the man's bank account and his current wages.
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June 02, 2025
Halliburton Wants IRS To Release Docs In $35M Tax Dispute
The Internal Revenue Service should be ordered to comply with Halliburton's discovery requests in a dispute over a $35 million deduction for payments the company said it made to a foreign government to protect its employees from harassment, the company told a Texas federal court.
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June 02, 2025
Tax Court Cuts $21M Off Former Ga. Quarry's Deduction Value
A donated 85-acre land plot in Georgia originally valued at nearly $22 million should have been valued around $193,000, the U.S. Tax Court found Monday, agreeing with the Internal Revenue Service.
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June 02, 2025
Vanguard, Investors Renegotiating After $40M Tax Deal Axed
Vanguard and investors have scrapped a $40 million class action deal in a case over surprise tax bills from a fund restructuring and will resume settlement discussions after a Pennsylvania federal judge recently found that the deal could have saddled investors with attorney fees.
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June 02, 2025
Feds Want 12½ Years For Ex-Ill. Speaker Convicted Of Bribery
Prosecutors are urging an Illinois federal judge to sentence former state House Speaker Michael Madigan to prison for 12½ years for bribery, conspiracy and fraud, saying his conduct adds "another sordid chapter to Illinois' storied reputation of corruption" while Madigan, armed with more than 200 letters of support, seeks only probation.
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June 02, 2025
Foley & Lardner Opens In Nashville With 3 Holland & Knight Attys
Foley & Lardner LLP has chosen Nashville as the location for its 27th office worldwide, bringing on three attorneys who had been at Holland & Knight LLP to work on regulatory, tax and transactional matters, the firm announced Monday.
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June 02, 2025
Ex-Atty In $7B Tax Fraud Tells 7th Circ. IRS Can't Collect
A former attorney sentenced to prison in connection with a $7 billion tax fraud told the Seventh Circuit that the Internal Revenue Service lacks the power to collect his court-ordered $371 million restitution, calling the agency's claims against him "wild and scurrilous."
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June 02, 2025
Ex-Par Funding CFO Sentenced To 5½ Years, Must Pay $303M
Joseph Cole Barleta, the last of the triumvirate behind the $404 million Par Funding investment scam to be sentenced, was handed a 66-month prison term Monday, along with a staggering $303 million restitution order.
Expert Analysis
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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.
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Notable Q1 Updates In Insurance Class Actions
The first quarter of 2025 was filled with the refinement of old theories in the property and casualty space, including in vehicle valuation, time to seek appraisal and materials depreciation, says Mathew Drocton at BakerHostetler.
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Power To The Paralegals: The Value Of Unified State Licensing
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.
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10 Soft Skills Every GC Should Master
As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.
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An Unrestrained, Bright-Eyed View Of Legal AI's Future
Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.
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Tracking The Evolution In Litigation Finance
Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.