Federal

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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."

  • 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.

  • June 02, 2025

    IRS To Hold Hearing On Sourcing Cloud Transaction Income

    The Internal Revenue Service and U.S. Treasury Department will hold a hearing July 17 on proposed rules on the source of income from cloud transactions, they said Monday.

  • May 30, 2025

    Split 9th Circ. Won't Unblock Trump's Gov't Overhaul

    A split Ninth Circuit on Friday refused to lift a California federal judge's preliminary block of President Donald Trump's executive order directing layoffs at federal agencies, handing a win to a coalition of unions, nonprofits and cities that argue the order exceeded the president's authority.

  • May 30, 2025

    US-China Trade Talks Could Resume After Stall Over Minerals

    Stalled trade talks between the U.S. and China could resume with a phone call between the countries' leaders as early as this week, a Trump economic adviser said Sunday.

  • May 30, 2025

    Convicted Crypto Investor's Wife Says Gov't Can't Seize Funds

    The wife of a bitcoin investor sentenced to prison for concealing millions of dollars from the IRS asked a Texas federal court Friday to stop the federal government from taking her money to help make up for $1 million in restitution stemming from his cryptocurrency sales.

  • May 30, 2025

    IRS Failed To Alert Thousands To Contractor's Data Breach

    Approximately 12,200 letters the Internal Revenue Service sent to individuals and businesses whose tax information was stolen by a former agency contractor were undeliverable for issues such as not having complete addresses, the Treasury Inspector General for Tax Administration said.

  • May 30, 2025

    IRS Slow To Convert Nontax Forms To Digital, TIGTA Says

    Only 12% of the Internal Revenue Service's 280 nontax paper forms that require one or more signatures have been converted to digital formats, though plans have been made to speed the process, the Treasury Inspector General for Tax Administration reported.

  • May 30, 2025

    Pa. Couple Should Pay $1.77M Tax Bill, Judge Says

    A Pennsylvania couple who purchased a Maserati and a Porsche and took trips to international destinations while owing the Internal Revenue Service $1.77 million should be required to pay those tax debts, a Pennsylvania federal magistrate judge found.

  • May 30, 2025

    Ohio Judge Slams Eaton For Ongoing IRS Disclosure Fight

    An Ohio federal judge denied Eaton Corp.'s bid to withhold foreign employee evaluations from the IRS, ruling Friday that the power management multinational's "astounding amount of effort" to fight disclosure has been a poor use of judicial resources.

  • May 30, 2025

    Taxation With Representation: Kirkland, Cravath, Latham

    In this week's Taxation With Representation, WiseTech completes a $2.1 billion merger with E2open, Acrisure buys a payroll management company for $1.1 billion and Hailey Bieber sells her Rhode skincare and makeup company to e.l.f. beauty for $1 billion.

Expert Analysis

  • How Attys Can Use A Therapy Model To Help Triggered Clients

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    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.

  • 3 Steps For In-House Counsel To Assess Litigation Claims

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    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.

  • IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement

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    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.

  • Adapting To Private Practice: From DOJ Enviro To Mid-Law

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    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.

  • Legal Ethics Considerations For Law Firm Pro Bono Deals

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    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.

  • 10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks

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    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.

  • Notable Q1 Updates In Insurance Class Actions

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    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.

  • Power To The Paralegals: The Value Of Unified State Licensing

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    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.

  • 10 Soft Skills Every GC Should Master

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    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.

  • An Unrestrained, Bright-Eyed View Of Legal AI's Future

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    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.

  • Tracking The Evolution In Litigation Finance

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    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.

  • E-Discovery Quarterly: The Perils Of Digital Data Protocols

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    Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.

  • Maximizing Exemptions Before TCJA Rides Into The Sunset

    Excerpt from Practical Guidance
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    Individuals with taxable estates can optimize the benefits of estate planning strategies like spousal lifetime access trusts by setting them up before increases in estate and gift tax exemptions under the 2017 Tax Cuts and Jobs Act sunset in January, say attorneys at Katten.

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