Federal
-
April 18, 2025
Taxation With Representation: Davis Polk, Simpson Thacher
In this week's Taxation With Representation, Global Payments Inc. buys Worldpay from GTCR and FIS, Intel Corp. sells a stake in its Altera business to Silver Lake, KKR acquires OSTTRA from S&P Global and CME Group, and Canada's Capital Power Corp. nabs two U.S. natural gas power plants.
-
April 18, 2025
IRS Outlines Plan To Advance Whistleblower Program
The Internal Revenue Service released an operating plan for its whistleblower program Friday, saying it aims to enhance the claim submission process, safeguard whistleblower information and keep whistleblowers informed on the status of their claims.
-
April 17, 2025
IRS Plans To End Partnership Basis-Shifting Regs
The Internal Revenue Service said Thursday it plans to revoke partnership basis-shifting regulations, which were finalized in early January to compel businesses engaged in such potentially abusive tax avoidance strategies to report them under the threat of penalty.
-
April 17, 2025
Tax Court Upholds IRS Collection Actions Against Couple
The U.S. Tax Court upheld Thursday the Internal Revenue Service's proposed collection actions against a couple, saying that an agency settlement officer did not abuse her discretion in sustaining a lien.
-
April 17, 2025
Man's Deportation Looms After Tax Evasion Plea Stands
A Connecticut federal judge denied a man's attempt to vacate his guilty plea for tax evasion, despite accepting that his lawyers had misled him into believing that if he received no prison time he could avoid mandatory detention and likely deportation by U.S. Immigration and Customs Enforcement.
-
April 17, 2025
Harvard Says No Grounds For IRS To Deny Tax-Exempt Status
Harvard University said Thursday that there is no legal basis to rescind its tax-exempt status amid an investigation by President Donald Trump's administration into whether the university has violated the terms of that status.
-
April 17, 2025
Tax Court Denies Horse Breeders' Claimed Losses
A Louisiana couple who bred, boarded and trained horses were correctly denied $867,000 in loss deductions over six years, the U.S. Tax Court said Thursday, because their activities weren't done for profit.
-
April 17, 2025
Judge Refuses To Recuse Himself In Ga. Defamation Case
A Georgia federal judge on Thursday refused to disqualify himself from presiding over a defamation case arising from a family dispute related to a tax preparation business, while also rejecting a bid to transfer the matter to a federal court in California.
-
April 16, 2025
Tax Court Says Hedge Fund Basket Options Abused Tax Perks
A Connecticut-based hedge fund has engaged in a complex stock-selling strategy using option contracts that the Internal Revenue Service had determined to be an abusive scheme to avoid paying high taxes on the capital gains, the U.S. Tax Court said Wednesday.
-
April 16, 2025
Plans To Shelve IRS Direct File Draw Democrats' Ire
The Trump administration's decision to shutter the Internal Revenue Service's Direct File pilot program was criticized heavily by congressional Democrats, who argued on Wednesday that the program was remarkably successful.
-
April 16, 2025
Union Denied More Time In Feds' Bid To Bless CBA Rebuke
A Kentucky federal judge has refused to delay an approaching hearing on the U.S. Department of the Treasury's bid to nullify its workers' union contracts, despite a union's assertion that it's been given little time to prepare for a consequential case and that it has yet to be served.
-
April 16, 2025
DC Judge Considers Bid To Block IRS Info Sharing With ICE
A D.C. federal judge on Wednesday questioned whether immigrant advocacy groups have standing to block a tax information-sharing agreement between the IRS and immigration enforcement agencies, but she also outlined concerns that the agreement could be abused.
-
April 16, 2025
Cannabis Co. Drops Back Taxes Case Against 2 Payroll Firms
A Washington cannabis company has dropped claims against a pair of payroll services providers accused of leaving the cannabis company with a $172,500 tax bill after failing to pay the Internal Revenue Service on its behalf.
-
April 16, 2025
IRS Owes Worker A Refund On 401(k) Loan, Suit Says
The IRS is refusing to send money back to a worker who said a paid-off 401(k) loan was mistakenly counted as income in his tax return, according to a suit filed in Missouri federal court.
-
April 16, 2025
IRS Publishes 2025 Average Residence Purchase Price Data
The Internal Revenue Service published data Wednesday on the average purchase price for U.S. residences in different areas, which is used to determine whether bond interest can be excluded from gross income.
-
April 16, 2025
3rd Circ. Affirms 51 Months For False Tax Return Filings
The Third Circuit affirmed Wednesday a 51-month sentence of a woman who embezzled more than $1.6 million from her employer and pled guilty to wire fraud and filing false tax returns, rejecting her claim that the U.S. government breached her plea agreement.
-
April 16, 2025
China's Long-Term Prospects Unfazed By Tariffs, Official Says
China's long-term prospects are unfazed by U.S. tariffs because of its industrial resilience, diversified trade and shift toward domestic consumption, a Chinese government official said Wednesday as the country posted 5.4% year-on-year growth in gross domestic product during the first quarter of 2025.
-
April 16, 2025
Applicable Federal Rates To Continue Nosedive In May
Applicable federal rates for income tax purposes are set to mostly decrease in May for the third month in a row, the Internal Revenue Service said Wednesday.
-
April 16, 2025
Hunter Biden Tax Probe Critic Named Acting IRS Chief
An Internal Revenue Service special agent who accused the U.S. Department of Justice of misconduct in an investigation of former President Joe Biden's son Hunter has been named the acting IRS commissioner, a U.S. Treasury Department spokesperson confirmed Wednesday.
-
April 15, 2025
No Appeal For Green Energy Co. CEO In $40M Investor Suit
The CEO of a company purportedly funded by a green energy outfit can't appeal a judge's determination in a proposed investor class action that found the executive is subject to the Tennessee federal court's jurisdiction, saying he failed to meet the requirements for such an appeal.
-
April 15, 2025
Bill To Ax Church Politics Ban Reignites Free-Speech Debate
More than a dozen congressional Republicans support what they characterize as free-speech legislation to overturn a 1954 tax law barring churches from endorsing candidates, despite warnings from some lawmakers and others that it could weaken church-state separation and flood politics with a new source of dark money.
-
April 15, 2025
Late Filing Dooms Jeweler's Employment Case In Tax Court
The window to file a U.S. Tax Court petition for businesses challenging IRS employment tax determinations can be slackened in some cases, but a jewelry company's bid to extend its own filing deadline doesn't pass muster, the court said Tuesday.
-
April 15, 2025
9th Circ. Backs Ex-Tax Office Worker's $110K Harassment Win
The Ninth Circuit declined to undo sanctions leveled against a tax and accounting company or reduce a $110,000 jury win handed to a former worker who claimed the business's owner sexually harassed her, ruling the company's arguments fell flat against a lower court's orders.
-
April 15, 2025
Tax Court Rejects Kentucky Man's 'Frivolous Arguments'
A Kentucky man owes over $25,000 in taxes and additional penalties, the U.S. Tax Court found Tuesday, rejecting his "frivolous arguments" that he isn't a taxpayer and that his more than $141,000 in earnings weren't income.
-
April 15, 2025
Senate Dems Call For Probe Into IRS Nominee's Business Ties
The IRS needs to investigate companies associated with President Donald Trump's nominee for IRS commissioner that are suspected of promoting a scheme to sell nonexistent tribal tax credits to investors, two Senate Finance Committee Democrats said in a letter published Tuesday.
Expert Analysis
-
Congress Can And Must Enact A Supreme Court Ethics Code
As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.
-
What To Make Of Dueling Corporate Transparency Act Rulings
Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.
-
The Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan
Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.
-
State Of The States' AI Legal Ethics Landscape
Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.
-
8 Childhood Lessons That Can Help You Be A Better Attorney
A new school year is underway, marking a fitting time for attorneys to reflect on some fundamental life lessons from early childhood that offer a framework for problems that no legal textbook can solve, say Chris Gismondi and Chris Campbell at DLA Piper.
-
How The 2025 Tax Policy Debate Will Affect The Energy Sector
Regardless of the outcome of the upcoming U.S. election, 2025 will bring a major tax policy debate that could affect the energy sector more than any other part of the economy — so stakeholders who could be affected should be engaging now to make sure they understand the stakes, say attorneys at Mayer Brown.
-
This Election, We Need To Talk About Court Process
In recent decades, the U.S. Supreme Court has markedly transformed judicial processes — from summary judgment standards to notice pleadings — which has, in turn, affected individuals’ substantive rights, and we need to consider how the upcoming presidential election may continue this pattern, says Reuben Guttman at Guttman Buschner.
-
Mental Health First Aid: A Brief Primer For Attorneys
Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.
-
The Trade And Tax Issues Behind US-Canada Digital Tax Clash
The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.
-
Litigation Inspiration: Honoring Your Learned Profession
About 30,000 people who took the bar exam in July will learn they passed this fall, marking a fitting time for all attorneys to remember that they are members in a specialty club of learned professionals — and the more they can keep this in mind, the more benefits they will see, says Bennett Rawicki at Hilgers Graben.
-
AI May Limit Key Learning Opportunities For Young Attorneys
The thing that’s so powerful about artificial intelligence is also what’s most scary about it — its ability to detect patterns may curtail young attorneys’ chance to practice the lower-level work of managing cases, preventing them from ever honing the pattern recognition skills that undergird creative lawyering, says Sarah Murray at Trialcraft.
-
A Look At How De Minimis Import Rules May Soon Change
The planned implementation of executive actions focused on the de minimis rule as it applies to shipments means companies should use this interval to evaluate the potential applicability and impact of Section 301, Section 201 or Section 232 duties on their products, say attorneys at Holland & Knight.
-
Ruling On Foreign Dividend Break Offers 2 Tax Court Insights
In Varian v. Commissioner, the U.S. Tax Court allowed a taxpayer's deduction for dividends from foreign subsidiaries, providing clarity on how the U.S. Supreme Court’s Loper Bright decision may affect challenges to Treasury regulations, and revealing a potential disallowance of foreign tax credits, say attorneys at Davis Polk.