Federal

  • August 22, 2025

    Liberty Global $240M Foreign Tax Credit Bid Fails At 10th Circ.

    Liberty Global cannot claim $240 million in foreign tax credits for the sale of a Japanese affiliate, the Tenth Circuit ruled Friday, rejecting the telecommunications giant's contention that a statutory provision allows it to recharacterize the proceeds as overseas income.

  • August 22, 2025

    Canada To Toss Tariffs On US Goods Under USMCA

    The Canadian government will remove retaliatory tariffs on U.S. goods that comply with the United States-Mexico-Canada Agreement, excluding steel, aluminum and automobiles, in a move aimed at jump-starting trade talks akin to an exemption made by the U.S. government, Canada's prime minister said Friday.

  • August 22, 2025

    Tribe Member Can't Discharge Tax Debt, 10th Circ. Affirms

    An Oklahoma federal court correctly affirmed a bankruptcy court's refusal to reopen a case brought by a member of the Muscogee Creek Nation who claimed his tax debt should have been discharged in bankruptcy, the Tenth Circuit said.

  • August 22, 2025

    Taxation With Representation: Kirkland, Weil, Fried Frank

    In this week's Taxation With Representation, private equity firm Thoma Bravo buys human resources software provider Dayforce Inc. in a take-private deal, Lowe's buys Foundation Building Materials, Nexstar Media Group Inc. acquires fellow media company Tegna Inc., and Soho House & Co. Inc. inks a take-private deal with hotel operator MCR.

  • August 22, 2025

    Michigan Judge Gives Initial OK To Tax Foreclosure Deal

    A Michigan federal judge has granted preliminary approval to a settlement that would allow former property owners to receive the surplus profits they allege county treasurers made selling their tax-delinquent properties.

  • August 22, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included proposed rules that would change its system of business classification for employees hoping to exclude fringe benefits and employee discounts from their gross income.

  • August 22, 2025

    Treasury Doubles Statutory Value Of Clean Energy Credit

    The U.S. Department of the Treasury is nearly doubling the statutory value of an income tax credit for producing electricity in line with a regularly scheduled increase tied to inflation, according to a Friday notice.

  • August 22, 2025

    IRS Guidance Sparks Mixed Reaction For Solar, Wind Projects

    The IRS recently narrowed the way large solar and wind energy development projects can set their construction start dates to qualify for certain tax credits, a change offering relief for some developers but new hurdles for others depending on the stage, type and size of the project.

  • August 21, 2025

    Tax Court Says Civil Fraud Penalty Cases Don't Require Juries

    The U.S. Tax Court rejected Thursday a Mississippi partnership's bid, based on the Supreme Court's landmark 2024 decision requiring a jury to adjudicate common law fraud penalties, to dismiss civil fraud penalties the IRS imposed on a conservation easement transaction.

  • August 21, 2025

    Man Who Hid Account From Wife Owes FBAR Fines, US Says

    A claim by the owner of a check-cashing business that he only meant to hide a foreign bank account from his wife during divorce proceedings doesn't excuse his failure to report the money to the Internal Revenue Service, the U.S. told a California federal court.

  • August 21, 2025

    EU, US Agree To Eliminate Industrial Tariffs

    The European Union and the U.S. have agreed on new terms to the trade agreement to eliminate EU tariffs on U.S. industrial products and implement a 15% U.S. tariff cap for most other sectors, according to a joint statement issued Thursday.

  • August 21, 2025

    Treasury Gets New Acting International Tax Counsel

    A deputy international tax counsel for the U.S. Department of the Treasury has been elevated to serve as acting counsel, he said in a post on LinkedIn.

  • August 21, 2025

    IRS Asks For Input On Free Filing Programs

    The Internal Revenue Service is surveying the public on tax preparation and filing as part of efforts to prepare a report for Congress on key issues surrounding free tax filing options, the agency said Thursday.

  • August 21, 2025

    Gov't Shrugs Off Sentencing Errors, IRS Leaker Tells DC Circ.

    The IRS contractor appealing his five-year prison sentence for leaking thousands of wealthy people's tax returns to the media accused the U.S. of glossing over sentencing errors that unfairly burdened him with "the harshest sentence possible," he told the D.C. Circuit.

  • August 21, 2025

    G7 Deal May Undermine Global Minimum Tax Enforcement

    The U.S. government's agreement with the Group of Seven nations to effectively exempt American companies from the 15% global minimum tax may hollow out enforcement of the international regime, in part because other multinational corporations may pursue similar treatment.

  • August 20, 2025

    Gov't Asks 8th Circ. To Ignore 2nd Circ. Tax Deadline Ruling

    A government attorney seeking to stop a couple from challenging their tax bill in the U.S. Tax Court urged the Eighth Circuit not to follow the Second Circuit's recent determination that the 90-day petition filing deadline is flexible, saying that decision split from long-held precedent.

  • August 20, 2025

    Fla. Man Who Evaded $7M In Federal Taxes Gets Probation

    A Florida investor who admitted to cheating the Internal Revenue Service out of $7 million in taxes was sentenced Wednesday to probation after telling a federal judge he suffers from serious health issues, including Stage 4 kidney cancer and early-onset dementia.

  • August 20, 2025

    Texas Plastics Co. Says Captive Insurance Program Legit

    A plastics manufacturer's captive insurance program to cover itself from various industrial and commercial risks was set up for legitimate reasons, the company told a Texas federal court in a bid to restore a tax deduction the IRS had denied on its premiums.

  • August 20, 2025

    Morris Manning Faces $5M Ga. RICO Suit Over Tax Strategy

    Morris Manning & Martin LLP is facing allegations of racketeering and tax fraud in a suit brought in Georgia state court by three investors that names a number of professional services firms.

  • August 20, 2025

    IRS To Nix Recent Rules On Disregarded Foreign Payments

    The U.S. Treasury Department and IRS said Wednesday that they're planning to remove rules issued in January that would have forced companies to recognize income from payments that are disregarded for U.S. taxes yet reduce income in a foreign jurisdiction, a move prompted by criticism from businesses.

  • August 20, 2025

    Nutter Welcomes Tax Atty In NY From Fox Horan

    Less than a month after announcing it had grown its ranks by 8% with the addition of 13 attorneys in three states, Nutter McClennen & Fish LLP said earlier this week that it has hired a New York-based tax attorney from Fox Horan & Camerini LLP.

  • August 20, 2025

    IRS Lost Lien In Bankruptcy, Man Says In $28M Tax Battle

    The Internal Revenue Service jettisoned any federal tax lien it claims to have against a man by filing an unsecured claim in his bankruptcy case, he told a Florida federal court Wednesday in response to the government's $28 million lawsuit against him.

  • August 19, 2025

    IRS To Float Rules Aimed At Easing Corporate Moves To US

    The IRS announced plans Tuesday to propose regulations that would make it easier for publicly traded foreign corporations that own U.S. real estate to move their official base to the U.S. without facing unexpected tax issues.

  • August 19, 2025

    IRS Told To Explain Granting $142M Contract Without Bids

    The IRS must explain why it thinks an executive order mandating electronic tax payments required it to skip the competitive bidding process in awarding a $142 million contract for scanning and digitizing incoming tax filings, the Court of Federal Claims said.

  • August 19, 2025

    Reasoning For IRS Firings Clashes With Reality, TIGTA Says

    Probationary workers at the Internal Revenue Service who were told earlier this year that they were fired for performance had been rated highly or had not been there long enough to be evaluated, according to a report Tuesday by the Treasury Inspector General for Tax Administration.

Expert Analysis

  • How To Accelerate Your Post-Attorney Career Transition

    Author Photo

    Professionals seeking to transition to nonattorney careers may encounter skepticism as nontraditional candidates, but there are opportunities for thought leadership and to leverage speaking and writing to accelerate a post-attorney career transition, say Janet Falk at Falk Communications and Evgeny Efremkin at Toronto Metropolitan University.

  • Tariffs And FCA Create Perfect Storm For Importers

    Author Photo

    The Trump administration's aggressive tariff policies pose a high risk to certain importation practices that are particularly likely to trigger False Claims Act enforcement, say attorneys at Jeffer Mangels.

  • US Reassessment Of OECD Tax Deal Is Right Move

    Author Photo

    The wholesale U.S. reevaluation of the Organization for Economic Cooperation and Development's global tax deal ordered by President Donald Trump is a positive step that could ultimately create a more durable international tax system, says Anne Gordon at the National Foreign Trade Council.

  • Measuring And Mitigating Harm From Discriminatory Taxes

    Author Photo

    In response to new tariffs and other recent "America First Trade Policy" pronouncements, corporations should assess and take steps to minimize their potential exposure to discriminatory and reciprocal tax measures that are likely to come, say economists at Charles River Associates.

  • Adapting To Private Practice: From DOJ Leadership To BigLaw

    Author Photo

    The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.

  • How The CRE Industry Is Adapting To Tariff Uncertainty

    Author Photo

    Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.

  • Law Firm Executive Orders Create A Legal Ethics Minefield

    Author Photo

    Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.

  • Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike

    Author Photo

    The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.

  • Firms Must Embrace Alternative Billing Models Or Fall Behind

    Author Photo

    As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.

  • How Attorneys Can Master The Art Of On-Camera Presence

    Author Photo

    As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.

  • Adapting To Private Practice: From Fed. Prosecutor To BigLaw

    Author Photo

    Making the jump from government to private practice is no small feat, but, based on my experience transitioning to a business-driven environment after 15 years as an assistant U.S. attorney, it can be incredibly rewarding and help you become a more versatile lawyer, says Michael Beckwith at Dickinson Wright.

  • Justices' False Statement Ruling Curbs Half-Truth Liability

    Author Photo

    The U.S. Supreme Court’s recent Thompson v. U.S. decision clarified that a federal statute used to prosecute false statements made to bank regulators only criminalizes outright falsehoods, narrowing prosecutors’ reach and providing defense counsel a stronger basis to challenge indictments of merely misleading statements, says Tamara de Silva at De Silva Law Offices.

  • Perfecting Security Interests In Renewable Energy Tax Credits

    Author Photo

    The ability to transfer renewable energy tax credits has created new opportunities for developers, investors and lenders, but it also raises important questions regarding when and how the security interests in these credits are perfected — questions that must be answered definitively to protect credit claims and transactions, says Harry Teichman at Stinson.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.