Federal

  • October 23, 2025

    Fed. Circ. Affirms No Tax Refunds For Retired United Pilots

    United Airlines pilots who said they overpaid payroll taxes because of the early termination of their retirement plan in the company's bankruptcy can't get partial refunds, the Federal Circuit affirmed Thursday, saying procedural issues doomed their case.

  • October 23, 2025

    Tech Co. Goes After $1.4M IRS Adjustments In Tax Court

    An internet platform company that helps video game developers launch their games challenged $1.4 million in IRS adjustments to its tax return in the U.S. Tax Court, alleging the agency incorrectly told the company to report its software development costs as capital expenses.

  • October 23, 2025

    US Oil Cos. Pay More Tax Abroad Than At Home, Report Says

    American oil and gas companies with foreign extraction operations paid more than 80% of their total taxes abroad in recent years despite producing more oil and gas in the U.S. than everywhere else combined, a corporate transparency group said Thursday.

  • October 23, 2025

    IRS To Float Sourcing Rules For Certain Securities Loans

    The Internal Revenue Service said Thursday it intends to propose regulations that would have it look to the borrower of certain securities, rather than the lender, when determining whether related payments are sourced from the United States.

  • October 23, 2025

    IRS FAQs Include $20K Payment Reporting Requirement

    The Internal Revenue Service updated its FAQs on Thursday to include the budget reconciliation bill's reversal of a law requiring peer-to-peer payment platforms such as Venmo and PayPal to report aggregate payments of $600 or more.

  • October 23, 2025

    Court Won't Rethink 'Survivor' Winner's $3M Tax Bill

    A Rhode Island federal judge won't reconsider his opinion that the first winner of reality show "Survivor" must pay $3.3 million in taxes, maintaining that it is unclear whether the federal government can take his sister's property to pay down the debt.

  • October 23, 2025

    Eaton To Defend Interest Rates, Fees Paid After 2012 Inversion

    Eaton is preparing to defend the interest rates and guarantee fees paid by entities in the U.S. to their newly formed Irish parent after the company's 2012 acquisition and inversion at a U.S. Tax Court trial scheduled to start Nov. 3.

  • October 22, 2025

    Tax Co.'s Push To Escape Sex Harassment Verdict Falls Short

    An Idaho federal judge rejected a tax business's bid Wednesday to escape potential liability for a $111,000 sexual harassment verdict won by a worker who claimed that the tax company acquired her former employer so that her ex-boss could avoid paying out on her lawsuit.

  • October 22, 2025

    US Among Few Places With Amount B Rules, OECD Reports

    The U.S. is a significant exception to a swath of countries, including China, Japan and the U.K., that lack domestic rules allowing companies to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, the OECD reported Wednesday.

  • October 22, 2025

    Innocent Spouse Claim Is Barred, Tax Court Says

    The wife of a man who failed to report overseas income is on the hook for the couple's shared tax liabilities, the U.S. Tax Court ruled Wednesday, rejecting her request to be cleared under a provision protecting spouses who are unaware of a partner's dealings.

  • October 22, 2025

    Tax Court Judge Warns Against Unchecked AI Use In Filings

    A U.S. Tax Court judge cautioned attorneys Wednesday against relying on artificial intelligence to write filings without verifying the information it generates, saying recent "unfortunate incidents" have prompted the court to double down on accuracy in using such tools.

  • October 22, 2025

    IRS Releases FAQs For Employee Retention Credits

    The IRS issued answers Wednesday to a set of frequently asked questions related to the limitations for the fraud-riddled employee retention tax credit program that were implemented under the budget reconciliation law.

  • October 22, 2025

    'The Right Facts' Can Reduce Cos.' Tariff Impacts, Atty Says

    Multinational companies with U.S. distributors that typically bear fewer business risks and earn low profit margins may be able to mitigate the effect of U.S. tariffs on their business as a whole by having a foreign principal bear the tariff costs, an attorney said Wednesday.

  • October 22, 2025

    Belgian Gov't Looks To Overturn US Tax Data Transfer Ruling

    Belgium's data privacy watchdog was wrong to rule that the transfer of personal tax information to the U.S. breaks European Union law, the Belgian government told a Brussels court Wednesday, because the practice was established before the EU's data protection law took effect.

  • October 22, 2025

    Presidential Firing Limits Fight Builds At High Court

    The ousted U.S. Merit Systems Protection Board chair has encouraged the U.S. Supreme Court to include a caveat for "legislative courts" if it overturns precedent that empowers Congress to limit the president's authority to fire certain agency officials, but opponents of independent agencies want a clean break from the status quo. 

  • October 22, 2025

    Senate Sends IRS Clerical Error Correction Bill To Trump

    A bill that would allow the IRS to adjust tax assessments to correct mathematical or clerical errors is headed to President Donald Trump's desk for his signature after the Senate approved the legislation, a senator who co-sponsored a related bill said Wednesday.

  • October 22, 2025

    Trade Court OKs $235K Tax Bill On Korean Soju Imports

    South Korean alcoholic beverages were improperly classified upon entering the U.S., and U.S. Customs and Border Protection correctly calculated a nearly $235,000 bill in unpaid federal excise taxes plus interest, according to the U.S. Court of International Trade.

  • October 22, 2025

    Widow Not Liable For Husband's Tax Debt, 4th Circ. Told

    An 80-year-old widow whose husband was imprisoned after hiding more than $20 million from the IRS told the Fourth Circuit that he was "abusive and controlling" and that she shouldn't have to pay the millions of dollars they jointly owe, despite contrary claims by the government.

  • October 22, 2025

    Construction Co. Owner Hid Income, Tax Court Says

    A man who said he was a former officer of a California construction company was actually a 50% shareholder and failed to report income for 2016, including money diverted from a client to the purchase of a motor home, the U.S. Tax Court found.

  • October 21, 2025

    Nonprofits Face Pressure From GOP Tax Changes, Aides Say

    Nonprofit organizations, charities and universities face sweeping changes under the Republicans' 2025 tax overhaul, Capitol Hill staffers said Tuesday, pointing to higher taxes on executive pay and endowments alongside revamped limits and incentives for individuals and corporations claiming charitable deductions.

  • October 21, 2025

    Partnership Deadline To Dispute IRS Is Fixed, Tax Court Says

    A deadline to petition the U.S. Tax Court to challenge IRS adjustments to partnership returns is effectively fixed and cannot be extended, the court said Tuesday in a reviewed decision that denied an Alabama LLC's late bid to restore a $46 million deduction for donating to charity.

  • October 21, 2025

    Discovery Against Gem Company Halted In Malawi's Tax Probe

    Malawi's government can no longer proceed with discovery against a gemstone company that partnered with a mining outfit the country claims evaded billions of dollars in taxes and royalties on exported rubies and sapphires, a Washington federal judge ruled, vacating his own order.

  • October 21, 2025

    CPA Group Calls For Transition Relief For Tips, OT Deductions

    Internal Revenue Service guidance related to reporting requirements for the new deductions for tips and overtime should include a safe harbor for businesses for the 2025 tax year, the American Institute of Certified Public Accountants said in a letter released Tuesday.

  • October 21, 2025

    IRS Publishes Guidance For Car Loan Interest Reporting

    The Internal Revenue Service released transitional guidance Tuesday for businesses' reporting requirements under the budget reconciliation law's new deduction for car loan interest.

  • October 21, 2025

    'Revenge Tax' May Reappear If Pillar 2 Talks Stall, Pros Say

    Republican lawmakers are likely to revive what is commonly known as the revenge tax if countries are unable to flesh out a tentative agreement to effectively exempt U.S. companies from the 15% global corporate minimum tax regime known as Pillar Two, practitioners said Tuesday.

Expert Analysis

  • Bill Leaves Renewable Cos. In Dark On Farmland Reporting

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    A U.S. Senate bill to update disclosure requirements for foreign control of U.S. farmland does not provide much-needed guidance on how to report renewable energy development on agricultural property, leaving significant compliance risks for project developers, say attorneys at Hodgson Russ.

  • Adapting To Private Practice: From US Rep. To Boutique Firm

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    My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.

  • IRS Should Work With Industry On Microcaptive Regs

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    The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.

  • CARES Act Fraud Enforcement Is Unlikely To Slow Down

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    In the five years since the passage of the Coronavirus Aid, Relief and Economic Security Act, the federal government has devoted massive resources to investigating CARES Act fraud — and all signs suggest the U.S. Department of Justice will continue vigorous enforcement in this area, say attorneys at Kostelanetz.

  • Spinoff Transaction Considerations For Biotech M&A

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    Amid current market challenges, boards and management teams of biotech companies can consider several strategies for maximizing value should a spinoff opportunity arise, but not without significant advance planning and careful implementation, particularly in cases that might qualify as tax-free, say attorneys at Paul Hastings.

  • Senate's 41% Litigation Finance Tax Would Hurt Legal System

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    The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.

  • Drawbacks For Taxpayers From Justices' Levy Dispute Ruling

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    The Supreme Court's June decision in Commissioner v. Zuch, holding the Tax Court lacks jurisdiction to resolve disputes where the IRS has stopped pursuing a levy, may require taxpayers to explore new tactics for mitigating the increased difficulty of appealing their liability via collection due process hearings, says Matthew Roberts at Meadows Collier.

  • How Energy Cos. Can Prepare For Potential Tax Credit Cuts

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    The Senate Finance Committee's version of the One Big Beautiful Bill act would create a steep phaseout of renewable energy tax credits, which should prompt companies to take several actions, including conduct a project review to discern which could begin construction before the end of the year, say attorneys at Husch Blackwell.

  • DOJ Has Deep Toolbox For Corporate Immigration Violations

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    With the U.S. Department of Justice now offering rewards to whistleblowers who report businesses that employ unauthorized workers, companies should understand the immigration enforcement landscape and how they can reduce their risk, say attorneys at McDermott.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.

  • Del. Dispatch: General Partner Discretion In Valuing Incentives

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    In Walker v. FRP Investors, the Delaware Court of Chancery recently held that the general partner of a limited partnership breached its obligations when determining the threshold value of newly issued incentive units, highlighting the court's willingness to reconstruct what a reasonable determination of value by a general partner should have been, say attorneys at Fried Frank.

  • Move Beyond Surface-Level Edits To Master Legal Writing

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    Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.

  • 9th Circ. Has Muddied Waters Of Article III Pleading Standard

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    District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.

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