Federal
-
November 24, 2025
Trusts' Identical $2M Tax Bills Don't Add Up, Tax Court Told
A pair of related trusts challenged nearly $2 million each in taxes and penalties, telling the U.S. Tax Court that the Internal Revenue Service had asserted identical deficiencies despite making different adjustments to the respective tax returns.
-
November 21, 2025
Judge Halts IRS-ICE Info-Sharing Agreement
A D.C. federal judge temporarily stopped the IRS on Friday from sharing confidential taxpayer addresses with immigration enforcement officials, saying the agency's disclosures of addresses in August under an information-sharing deal were unlawful.
-
November 21, 2025
IRS Finalizes Stock Buyback Tax Regs Without 'Funding Rule'
The Internal Revenue Service released final regulations Friday for the excise tax on corporations' stock buybacks and similar transactions without what is known as the funding rule, which would apply the levy to a U.S. subsidiary of a foreign parent company.
-
November 21, 2025
Bill Proposes Bitcoin Tax Payments To Build Crypto Reserve
A House Republican introduced a bill that would allow Americans to pay federal taxes in bitcoin and direct the government to use all bitcoin tax payments to build the Strategic Bitcoin Reserve.
-
November 21, 2025
Justices Urged To Uphold $268M Tax Break For Truck Co.
The U.S. Supreme Court should let stand the denial of $268 million in excise tax exemptions for a Tennessee truck company, the federal government urged, saying the case doesn't meet any of the traditional requirements for high court review and raises an isolated issue.
-
November 21, 2025
IRS Issues Guidelines For Claiming Tip Tax Relief In 2025
The Internal Revenue Service published guidance Friday for taxpayers looking to claim the new tax deductions for tips and overtime in 2025, as relevant tax forms haven't yet been updated to more easily account for them.
-
November 21, 2025
Ga. Tax Worker Granted Interest On Chrisley Slander Verdict
A Georgia tax official will collect interest on top of a $755,000 slander verdict she won from former reality TV personality and convicted felon Todd Chrisley after a jury found he falsely accused her of unethical and illegal behavior, a Georgia federal judge said.
-
November 21, 2025
Key Issues Facing The IRS Amid Looming Budget Cuts
The Internal Revenue Service is facing steep budget cuts in 2026, raising concerns about the agency's ability to handle taxpayer services and enforcement operations that are crucial for bringing in revenue and maintaining compliance with the voluntary system. Here, Law360 looks at the key areas where resource constraints are expected to hamper the IRS and what practitioners can do in response.
-
November 21, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included updated rules allowing investment and grantor trusts to stake their digital assets without losing their tax benefits as long as they meet certain requirements.
-
November 20, 2025
Importers Left With Uncertainty After US-China Trade Truce
U.S. importers have welcomed the latest trade truce with China and the ability to obtain key minerals without new licensing requirements for the next year, but continue to have questions about how commitments in the bilateral agreement will be met and concerns about risks of escalation.
-
November 20, 2025
Treasury To Curtail Tax Credits For Unauthorized Immigrants
The U.S. Department of the Treasury plans to propose rules that would bar unauthorized immigrants from receiving popular refundable individual tax credits such as the earned income tax credit, the department announced Thursday.
-
November 20, 2025
6th Circ. Urged To Affirm High Bar For Donor Reporting Rule
A libertarian organization urged the Sixth Circuit to affirm a finding that the federal government must meet a relatively high bar before it can force nonprofits to reveal the identities of their donors, saying the standard acknowledges the burden of the disclosures on First Amendment rights.
-
November 20, 2025
FBAR Penalty Against Ex-Prof Is Constitutional, Court Says
A former professor must pay the entire nearly $438,000 penalty the Internal Revenue Service assessed against him for his failure to timely disclose foreign bank accounts, a California magistrate judge held, finding the amount is not unconstitutionally excessive and declining to reduce it.
-
November 20, 2025
Trump Pardons Nursing Home Owner In $39M Tax Fraud
President Donald Trump granted clemency to a nursing home operator who had been sentenced to three years in prison for a $39 million employment tax fraud scheme involving care centers he owned across the country.
-
November 20, 2025
IRS Unveils Interim Rules For Tax Perk For Rural Loan Interest
The IRS released temporary guidance Thursday on a new incentive that would exclude from taxable income 25% of interest from loans secured by a rural or agricultural property, including the definition of an eligible loan and the determination of the property's fair market value.
-
November 19, 2025
Judge Unlikely To Find Eaton's Debt To Parent Wasn't Real
A U.S. Tax Court judge said Wednesday that he's unlikely to find that the intercompany debt U.S.-based Eaton Inc. owed its Irish parent was unreal and should be recharacterized as equity, all but dismissing an alternative argument raised by the Internal Revenue Service.
-
November 19, 2025
Senate GOP Resists Extending Expanded ACA Tax Premiums
Senate Finance Committee Democrats on Wednesday urged their Republican counterparts to extend the enhanced tax credits for the Affordable Care Act, which is set to expire at the end of the year, but Republicans said they were looking for other options to address rising healthcare costs.
-
November 19, 2025
Tax Court Upholds Rejection Of Tax Tipster's Award
The IRS did not improperly reject a man's claim to a whistleblower award for tips he claimed helped the agency collect money from a foreign financial institution that he said held secret accounts for U.S. citizens, the U.S. Tax Court said Wednesday.
-
November 19, 2025
$24M Tax Case Against Couple Tossed For Missing Deadline
The federal government's effort to collect on what it claimed was a couple's $24 million tax bill came too late, a North Carolina federal judge ruled, saying the U.S. didn't show why a 10-year collections deadline should be extended.
-
November 19, 2025
Tax Court Substance Ruling Offers Silver Lining For Taxpayers
Even though the U.S. Tax Court upheld stiff penalties under the economic substance doctrine against an eye doctor's microcaptive arrangements, the opinion generally favored taxpayers by clarifying that the IRS faces limits on when it can invoke the doctrine to audit transactions.
-
November 19, 2025
Doctor, Husband Admit $16M Healthcare Fraud, Tax Evasion
A physician and her husband admitted to committing more than $16 million in healthcare fraud and tax evasion as part of a scheme that injected sick patients with the wrong medications or dosages, according to their plea agreements in Alaska federal court.
-
November 19, 2025
OECD Releases Model Tax Treaty Updates For Amount B
The Organization for Economic Cooperation and Development released updates Wednesday to its model bilateral tax treaty, including language that incorporates a simplified transfer pricing approach under an international tax framework known as Amount B.
-
November 19, 2025
Trump's Global Tariffs Curtailed Trade, Data Shows
U.S. imports dropped by 5.1% in August, the month when many of President Donald Trump's global tariffs took effect, according to data released Wednesday by the Bureau of Economic Analysis.
-
November 18, 2025
Conn. Tobacco Wholesaler Gets Prison Time For $1.2M Fraud
A Connecticut-based tobacco wholesaler who admitted defrauding the state out of $1.2 million in tax revenue was sentenced Tuesday to nearly two years in federal prison.
-
November 18, 2025
Shutdown Puts '26 Filing Season In Danger, Ex-IRS Chiefs Say
The longest government shutdown in U.S. history likely disrupted critical Internal Revenue Service preparation for the 2026 filing season and could force the agency to delay opening day, slow refund processing and deliver poor basic taxpayer services, three former IRS commissioners warned Tuesday.
Expert Analysis
-
Bill Leaves Renewable Cos. In Dark On Farmland Reporting
A U.S. Senate bill to update disclosure requirements for foreign control of U.S. farmland does not provide much-needed guidance on how to report renewable energy development on agricultural property, leaving significant compliance risks for project developers, say attorneys at Hodgson Russ.
-
Adapting To Private Practice: From US Rep. To Boutique Firm
My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.
-
IRS Should Work With Industry On Microcaptive Regs
The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.
-
CARES Act Fraud Enforcement Is Unlikely To Slow Down
In the five years since the passage of the Coronavirus Aid, Relief and Economic Security Act, the federal government has devoted massive resources to investigating CARES Act fraud — and all signs suggest the U.S. Department of Justice will continue vigorous enforcement in this area, say attorneys at Kostelanetz.
-
Spinoff Transaction Considerations For Biotech M&A
Amid current market challenges, boards and management teams of biotech companies can consider several strategies for maximizing value should a spinoff opportunity arise, but not without significant advance planning and careful implementation, particularly in cases that might qualify as tax-free, say attorneys at Paul Hastings.
-
Senate's 41% Litigation Finance Tax Would Hurt Legal System
The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.
-
Drawbacks For Taxpayers From Justices' Levy Dispute Ruling
The Supreme Court's June decision in Commissioner v. Zuch, holding the Tax Court lacks jurisdiction to resolve disputes where the IRS has stopped pursuing a levy, may require taxpayers to explore new tactics for mitigating the increased difficulty of appealing their liability via collection due process hearings, says Matthew Roberts at Meadows Collier.
-
How Energy Cos. Can Prepare For Potential Tax Credit Cuts
The Senate Finance Committee's version of the One Big Beautiful Bill act would create a steep phaseout of renewable energy tax credits, which should prompt companies to take several actions, including conduct a project review to discern which could begin construction before the end of the year, say attorneys at Husch Blackwell.
-
DOJ Has Deep Toolbox For Corporate Immigration Violations
With the U.S. Department of Justice now offering rewards to whistleblowers who report businesses that employ unauthorized workers, companies should understand the immigration enforcement landscape and how they can reduce their risk, say attorneys at McDermott.
-
Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs
In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.
-
Del. Dispatch: General Partner Discretion In Valuing Incentives
In Walker v. FRP Investors, the Delaware Court of Chancery recently held that the general partner of a limited partnership breached its obligations when determining the threshold value of newly issued incentive units, highlighting the court's willingness to reconstruct what a reasonable determination of value by a general partner should have been, say attorneys at Fried Frank.
-
Move Beyond Surface-Level Edits To Master Legal Writing
Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.
-
9th Circ. Has Muddied Waters Of Article III Pleading Standard
District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.