Federal

  • November 06, 2025

    Tax Court Says IRS Took Too Long To Ax Easement Deduction

    The Internal Revenue Service failed to timely disallow a charitable deduction related to a company's conservation easement donation, the U.S. Tax Court said, throwing out a partnership adjustment by the agency.

  • November 06, 2025

    2nd Circ. Orders New Look At Trump's Hush Money Case

    In a published opinion, the Second Circuit on Thursday ordered a federal district judge to take a fresh look at President Donald Trump's attempt to move his New York hush money conviction to federal court, citing the U.S. Supreme Court's 2024 presidential immunity ruling as grounds for reconsidering the case.

  • November 05, 2025

    Judge Questions Transfer Of Eaton's $14B Foreign Asset

    A U.S. Tax Court judge questioned a former Eaton Corp. official Wednesday about the company's decision to restructure the ownership of a valuable foreign subsidiary when it inverted in 2012, noting that the move placed a $14 billion asset out of the U.S. company's reach.

  • November 05, 2025

    IRS Direct File Will Not Be Offered In 2026, States Confirm

    State revenue agencies confirmed Wednesday that the Internal Revenue Service has informed them that its free online tax preparation tool, Direct File, will not be offered for the 2026 filing season and potentially other years.

  • November 05, 2025

    IRS Layoffs Include Over 500 Exam Employees, Docs Show

    The federal workers laid off during the government shutdown include more than 500 people in the exam and collections section of the IRS responsible for enforcing tax laws, a federal employee told a California federal court in a lawsuit over the firings.

  • November 05, 2025

    Docs Show IRS Improperly Shared Data With ICE, Groups Say

    Documents submitted by the U.S. government to a D.C. federal court show the IRS violated taxpayer privacy laws by sharing individuals' addresses with ICE despite its requests lacking required information and by accepting an unreasonable explanation about why the information was requested, several groups said.

  • November 05, 2025

    Ex-Mashpee Tribal Leader Gets 3.5 Years For Casino Bribes

    The former chair of the Mashpee Wampanoag Tribe on Wednesday was sentenced to a 42-month prison term for orchestrating a bribery scheme tied to the tribe's $1 billion casino project, as a Massachusetts federal judge chastised him for characterizing his yearslong conduct as "mistakes."

  • November 05, 2025

    Fed. Circ. Skeptical Of Family Trusts' Tax Fraud Case

    The Federal Circuit seemed skeptical Wednesday of an $80 million tax challenge by a group of family trusts that claimed they were unfairly stuck with tax liabilities after being duped into selling assets to a fraudster who then engaged in abusive tax shelter transactions behind their backs.

  • November 05, 2025

    Justices Skeptical About Trump's Emergency Tariff Authority

    Several U.S. Supreme Court justices asked the government to defend why well-established judicial doctrines shouldn't limit President Donald Trump's tariffs imposed under the International Emergency Economic Powers Act during oral arguments Wednesday, casting doubt on whether they believe the law provides that kind of authority.

  • November 05, 2025

    IRS Provides Penalty Relief For 2025 Tips, OT Reporting

    The Internal Revenue Service will treat the 2025 tax year as a transition period for enforcement and administration of the information reporting requirements for the new deductions for tips and overtime, according to guidance released Wednesday.

  • November 04, 2025

    Malawi Asks Judge To Undo Halt Of Gem Export Tax Probe

    Malawi asked a Washington federal judge to reconsider his recent decision to bar the country from pursuing discovery against a gemstone company that it alleges partnered with a mining outfit to dodge billions of dollars in taxes and export royalties.

  • November 04, 2025

    Former Eaton CFO Says Bond Investors Needed Reassurance

    Eaton Corp.'s former chief financial officer chronicled on Tuesday the company's efforts to finance its 2012 acquisition of Ireland-based Cooper Industries, describing an atmosphere of leery bond investors after the Great Recession of 2008, on the second day of the company's U.S. Tax Court trial.

  • November 04, 2025

    Tax Court Blocks Ariz. Salesman's Business Deductions

    The U.S. Tax Court on Tuesday rejected a series of business deductions claimed by an Arizona man working in outside sales and affirmed penalties against him for substantially understating his taxes.

  • November 04, 2025

    3M Ruling Highlights Loper Bright's Reach In Axing Tax Regs

    A U.S. Supreme Court ruling that gutted deference to agencies took center stage in the Eighth Circuit's recent decision that backed 3M's challenge to transfer pricing rules, signaling the strict statutory analysis that courts may now apply to tax regulations.

  • November 04, 2025

    Ga. Biz Asks Tax Court To Block IRS Easement Changes

    A Georgia company asked the U.S. Tax Court to reverse the Internal Revenue Service's adjustments to a claimed noncash charitable contribution for a $61 million conservation easement donation and rule that the company's filing was accurate, according to a petition released Tuesday.

  • November 04, 2025

    Developer Seeks To Restore Nixed $29M Easement Deduction

    The Internal Revenue Service failed to explain its rejection of a $29 million charitable tax deduction claim for an Alabama-based developer's 2016 conservation easement donation to a regional water district, the developer told the U.S. Tax Court as it challenged the decision.

  • November 04, 2025

    Tax Court Affirms Rejection Of Co.'s Settlement Offer

    The Internal Revenue Service did not abuse its discretion in rejecting an offer from a small business to settle its tax debt, the U.S. Tax Court said Tuesday, finding that the company never submitted financial documents the agency needed to accept the deal.

  • November 04, 2025

    Shutdown Leaves Tax Pros Few Options To Find Clients Relief

    The IRS has been beset by worsening delays in addressing taxpayers' cases, driven by widespread furloughs and a wave of retirements, and the ongoing government shutdown has compounded the issue by bringing federal district courts to a halt, leaving tax practitioners few options to seek relief for clients.

  • November 04, 2025

    DC Circ. Skeptical Of IRS Data Leaker's Qualms About Judge

    The D.C. Circuit seemed unlikely Tuesday to grant a request for resentencing by an IRS contractor serving prison time for leaking the tax returns of President Donald Trump and others to the media, suggesting his judge did nothing wrong in giving him the maximum term.

  • November 03, 2025

    Eaton Debt Analysis Must Trace Distinct Steps, Tax Court Told

    An attorney for Eaton Corp. told the U.S. Tax Court on Monday that the interest rates and guarantee fees the company paid to its newly formed Irish parent in 2012 must be analyzed as a set of distinct steps, beginning with determining a standalone credit rating for the U.S. company — an analysis a government attorney said was "needlessly elaborate."

  • November 03, 2025

    4 Ways Justices' Jarkesy Ruling Could Affect Tax Controversy

    As lower courts have begun to weigh the U.S. Supreme Court’s 2024 ruling that the SEC’s imposition of civil penalties without a jury trial was unconstitutional, attorneys say the decision could reshape tax disputes and potentially force the IRS to reconsider its approach to enforcement. Here, Law360 examines potential ways the Jarkesy precedent could influence tax controversy.

  • November 03, 2025

    'No Basis In Reality' In $10M Easement Claim, Tax Court Says

    A U.S. Tax Court judge rejected a partnership's claim that its donation of a conservation easement over 200 acres in Georgia was worth a $10 million tax deduction, saying in an opinion Monday that it "has no basis in reality."

  • November 03, 2025

    2 Doctrines Likely To Direct Justices' Review Of Trump Tariffs

    When the U.S. Supreme Court hears oral arguments Wednesday over whether President Donald Trump can impose tariffs under the International Emergency Economic Powers Act, it will likely test two doctrines the justices have recently considered: the major questions and nondelegation doctrines.

  • November 03, 2025

    Tribes Push Supreme Court To Overturn Okla. Tax Ruling

    The Oklahoma Supreme Court incorrectly ruled that a member of the Muscogee Creek Nation owes Oklahoma income tax, groups representing Native American tribes told the U.S. Supreme Court, asking the justices to hear the case and reverse the ruling.

  • November 03, 2025

    Veteran Tax Controversy Atty Moves Team To Kostelanetz

    A longtime New Jersey tax attorney and three of his associates have joined Kostelanetz LLP, the boutique tax firm announced Monday, saying it expected them to bolster its tax controversy practice and add to its commitment to volunteer work and legal education.

Expert Analysis

  • What To Expect As Trump's 401(k) Order Materializes

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    Following the Trump administration’s recent executive order on 401(k) plan investments in alternative assets like cryptocurrencies and real estate, the U.S. Department of Labor and the U.S. Securities and Exchange Commission will need to answer several outstanding questions before any regulatory changes are implemented, say attorneys at Cleary.

  • Demystifying The Civil Procedure Rules Amendment Process

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    Every year, an advisory committee receives dozens of proposals to amend the Federal Rules of Civil Procedure, most of which are never adopted — but a few pointers can help maximize the likelihood that an amendment will be adopted, says Josh Gardner at DLA Piper.

  • Parenting Skills That Can Help Lawyers Thrive Professionally

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    As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.

  • Unpacking The New Opportunity Zone Tax Incentive Program

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    The One Big Beautiful Bill Act brought several improvements to the opportunity zone tax incentive program that should boost investments in qualified funds, including making it permanent, increasing federal income tax benefits in rural areas, redesignating the qualified zones, and requiring more in-depth reporting, says Marc Schultz at Snell & Wilmer.

  • Trump Tax Law's Most Impactful Energy Changes

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    The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.

  • Adapting To Private Practice: From Texas AUSA To BigLaw

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    As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.

  • Advice For 1st-Gen Lawyers Entering The Legal Profession

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    Nikki Hurtado at The Ferraro Law Firm tells her story of being a first-generation lawyer and how others who begin their professional journeys without the benefit of playbooks handed down by relatives can turn this disadvantage into their greatest strength.

  • UK's 1st ICSID Claim Shows Bilateral Investment Treaty Reach

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    For the first time, the U.K. is facing a claim under the International Centre for Settlement of Investment Disputes Convention, underscoring the broader reality that treaty protections are no longer confined to investors in emerging markets, says Philipp Kurek at Signature Litigation.

  • Trump Tax Law's Most Impactful Corp. And Individual Changes

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    The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.

  • From Clerkship To Law Firm: 5 Transition Tips For Associates

    Excerpt from Practical Guidance
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    Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.

  • Trump Tax Law's Most Consequential International Changes

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    The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.

  • Associates Can Earn Credibility By Investing In Relationships

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    As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.

  • Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling

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    The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.

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