Federal

  • May 06, 2025

    Eversheds Sutherland Brings On EY Tax Pro In Atlanta

    Eversheds Sutherland has added a former EY senior manager of international tax and transaction services to its Atlanta office, further strengthening its tax practice after adding a dozen tax controversy attorneys from Chamberlain Hrdlicka White Williams & Aughtry PC in March, the firm announced Tuesday.

  • May 06, 2025

    4th Circ. Seems Split On BofA's Post-Merger Tax Offset Claims

    The Fourth Circuit seemed split Tuesday on whether Bank of America should be able to use its tax overpayments to offset interest on tax underpayments by companies that merged into it, with one judge pressing the government to respond to what he described as the bank's "common sense" argument in the $163 million case.

  • May 05, 2025

    Credit Suisse To Pay Feds $510.6M For Helping Hide Assets

    Credit Suisse Services AG has agreed to shell out more than $510 million under agreements with federal prosecutors in which the company admitted to helping customers hide more than $4 billion from the IRS in hundreds of offshore accounts, the U.S. Department of Justice announced Monday.

  • May 05, 2025

    Feds Say Calif. Tribe's Challenge To Cig Ruling Is 'Fruitless'

    The federal government is urging a California federal court not to pause a ruling affirming the Bureau of Alcohol, Tobacco, Firearms and Explosives' decision to place a native tribe on a noncompliance list over cigarette sales, saying the tribe shouldn't be able to upend the status quo as it pursues a "fruitless" appeal to the Ninth Circuit.

  • May 05, 2025

    Trump Seeks 100% Tariff On Foreign-Made Movies

    President Donald Trump asked his administration to place a 100% tariff on foreign-made movies, with a spokesperson telling Law360 on Monday that a final decision on the plan hadn't been made.

  • May 05, 2025

    Minn. Tribe Looks To Weigh In On 3,000-Acre Land Trust Row

    The Mille Lacs Band of Ojibwe has asked a Minnesota federal judge to let it file a friend of the court brief in a county's case claiming the U.S. government wrongly accepted more than 3,000 acres of land into trust for the tribe.

  • May 05, 2025

    Trump Admin Defends Tariff Power In Toy-Makers' Challenge

    President Donald Trump's administration urged a D.C. federal court to deny a request by toy companies to halt global tariffs, arguing the government is authorized to impose trade measures under the International Emergency Economic Powers Act.

  • May 05, 2025

    IRS Audit Staff Slashed From Layoffs, Voluntary Resignations

    Layoffs and voluntary resignations at the Internal Revenue Service have significantly reduced the agency's revenue agents responsible for conducting audits, the Treasury Inspector General for Tax Administration said Monday.

  • May 05, 2025

    Tax Evader Can't Fight Related Taxes, Court Says

    A South Dakota business owner who admitted to hiding income from the Internal Revenue Service cannot challenge the $120,000 the agency claims he owes in additional taxes for fraudulently failing to file returns, the U.S. Tax Court ruled Monday.

  • May 05, 2025

    Clifford Chance Adds Paul Weiss Exec Compensation Atty In NY

    Clifford Chance LLP has added a Paul Weiss Rifkind Wharton & Garrison LLP transactional attorney in New York as co-chair of its U.S. executive compensation practice, the firm announced Monday.

  • May 05, 2025

    Tax Court Tosses Grandmother's Levy Challenge

    The U.S. Tax Court tossed Monday a levy challenge by an Alabama woman who said she was the sole caregiver for her five grandchildren, ruling that she had already received the tax relief she sought when the IRS decided not to collect her overdue taxes.

  • May 05, 2025

    Co. Urges Ending IRS Cost-Sharing Rule After Justices' Ruling

    A controversial rule requiring U.S. companies to include employee stock-based compensation in cost-sharing agreements with offshore affiliates should be scrapped following the U.S. Supreme Court's revocation of required judicial deference to agencies, a drug distributor told a Texas federal court in seeking a nearly $10 million tax refund.

  • May 05, 2025

    Novelist Owes $715K In FBAR Penalties, US Says

    A Japanese author with U.S. citizenship faces penalties exceeding $715,000 for failing to report accounts she held at a Swiss bank, the U.S. government told a California federal court.

  • May 02, 2025

    Tax Case Can Proceed Despite Late Name Change, Court Says

    The owner of a mail-order medical equipment company can move forward with his lawsuit against the federal government seeking to deduct a $5 million settlement payment, even though he didn't technically add his name to the case until after the deadline, the Court of Federal Claims said.

  • May 02, 2025

    Money Laundering, Tax Charges Nixed Vs. Crypto Operator

    An Indiana federal judge dismissed the U.S. government's cases against a man accused of operating an unlicensed money transmitting business, laundering proceeds through cryptocurrency transactions and failing to file tax returns after finding his business was not subject to registration requirements, as the government had maintained.

  • May 02, 2025

    Nixon Peabody Appoints Finance, Tax Partner As DC Leader

    Nixon Peabody LLP has appointed a more than 20-year veteran of the firm as its Washington, D.C., office managing partner, who focuses his practice on a range of corporate, finance and real estate matters, according to a Thursday announcement.

  • May 02, 2025

    Groups Seek Order Halting Trump's Restructuring Of Gov't

    A California district court must stop federal agencies from moving ahead with President Donald Trump's directive to reorganize and terminate government workers, unions and other groups argued, calling for a temporary restraining order based on alleged harms from the administration's "radical restructuring."

  • May 02, 2025

    White House Budget Seeks $2.5B Cut From IRS Funding

    The Internal Revenue Service's budget would be cut by nearly $2.5 billion compared with 2025 under the 2026 budget request released Friday by President Donald Trump's administration.

  • May 02, 2025

    IRS Updates Rates For Foreign Insurance Company Equations

    The Internal Revenue Service on Friday published updated domestic asset/liability and yields percentages for 2024 that foreign life insurance companies and foreign property and liability insurance companies need to compute their minimum effectively connected net investment income.

  • May 02, 2025

    Taxation With Representation: Goodwin, Haynes Boone

    In this week's Taxation With Representation, Merck buys SpringWorks Therapeutics, Novartis AG acquires Regulus Therapeutics Inc., Sabre Corp. sells its Hospitality Solutions business to private equity shop TPG, and TWG Global and Mubadala Capital team up to bolster their investments.

  • May 02, 2025

    Community Groups Accept Pause In CTA Litigation

    A group of community associations has told the Fourth Circuit they aren't opposed to a government motion to pause litigation over the Corporate Transparency Act, even as they maintained the information disclosure law aimed at small businesses still carries constitutional flaws.

  • May 02, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included its announcement of plans to revoke partnership basis-shifting regulations that were finalized earlier this year.

  • May 01, 2025

    IRS Successfully Targeting Rich Nonfilers, But Can Improve

    The Internal Revenue Service's targeted sweeps of so-called high-income nonfilers have largely been successful in closing cases and collecting revenue, but the agency could do more to target certain areas and collect tracking data better, the Treasury Inspector General for Tax Administration said.

  • May 01, 2025

    Multinationals Grapple With Tariff-Induced Pricing Issues

    President Donald Trump's flurry of tariff actions since taking office has created new questions for multinationals and their transfer pricing tax planners, including how to properly account for cost increases associated with new duties in related party transactions.

  • May 01, 2025

    Trump Picks Tax Controversy Pro For IRS Chief Counsel Spot

    President Donald Trump has tapped a former Internal Revenue Service chief counsel to return to the role, and if he is confirmed, it will represent the second time in his career that the veteran tax controversy professional will be the agency's top attorney.

Expert Analysis

  • Takeaways From The IRS' Crypto Doc Summons Win

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    A recent First Circuit decision holding that taxpayers do not have a Fourth Amendment reasonable expectation of privacy in cryptocurrency transaction records should prompt both taxpayers and exchanges to take stock of past transactions and future plans, say attorneys at BakerHostetler.

  • How Judiciary Can Minimize AI Risks In Secondary Sources

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    Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.

  • How Attorneys Can Break Free From Career Enmeshment

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    Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.

  • Ex-Chicago Politician's Case May Further Curb Fraud Theories

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    The U.S. Supreme Court recently agreed to hear Thompson v. U.S. to determine whether a statement that is misleading but not false still violates federal law, potentially heralding the court’s largest check yet on prosecutors’ expansive fraud theories, with significant implications for sentencing, say attorneys at the Law Offices of Alan Ellis.

  • Lawyers With Disabilities Are Seeking Equity, Not Pity

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    Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.

  • Judicial Committee Best Venue For Litigation Funding Rules

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    The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.

  • The Strategic Advantages Of Appointing A Law Firm CEO

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    The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.

  • Tariffs' Economic Downsides Outweigh Potential Revenue

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    Import tariffs proposed by the campaign of former president Donald Trump would generate revenue like other taxes, but policymakers must consider the net-negative impact of associated consumer and downstream-industry costs, harm to exporters, potential foreign retaliation and reduction in economic output, says Erica York at the Tax Foundation.

  • Navigating The Last Leg Of The Worker Retention Tax Credit

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    Whether a business has applied for the pandemic-era employee retention tax credit, received a denial letter or is still considering making a claim before the April 15 deadline, it should examine recent developments significantly affecting the program before planning next steps, say attorneys at Nixon Peabody.

  • How Cos. Can Build A Strong In-House Pro Bono Program

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    During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.

  • Home Canning Makes Me A Better Lawyer

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    Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.

  • Use The Right Kind Of Feedback To Help Gen Z Attorneys

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    Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.

  • Congress Can And Must Enact A Supreme Court Ethics Code

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    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.

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