Federal
-
September 17, 2025
Partners Barred From Fighting Deal In $54M Easement Suit
Dozens of investment partners were barred from challenging a settlement with the IRS over their disputed $54 million conservation easement deduction under a U.S. Tax Court ruling Wednesday that found they waited until the last minute and didn't show why they should be allowed to participate in proceedings.
-
September 17, 2025
Spencer Fane Adds Corporate, RE Attys In The Midwest
Spencer Fane LLP announced the addition of two new attorneys in the Midwest this week — a partner joining its corporate and business transactions group and a counsel joining its real estate group.
-
September 17, 2025
11th Circ. Finds Couple On Hook For Penalty On Back Taxes
A couple who owed $1.7 million in back taxes is on the hook for a penalty after the Eleventh Circuit rejected their dual claims that an Internal Revenue Service supervisor failed to correctly approve the penalty and that U.S. Tax Court judges have unconstitutional job protections.
-
September 17, 2025
IRS Spent $40M On Outdated Computer Systems, TIGTA Says
A decade-old plan at the Internal Revenue Service to consolidate dozens of computer systems has made little progress, the Treasury Inspector General for Tax Administration said Wednesday, reporting that the agency spent nearly $40 million last year on maintaining outdated systems.
-
September 16, 2025
$300M Hyatt Rewards Tax Ruling Criticized By 7th Circ. Judge
A Seventh Circuit judge took issue Tuesday with a U.S. Tax Court's finding that Hyatt should report $300 million in rewards program fund revenue, saying the decision seemed to focus on a factor that was shot down by decades-old legal precedent.
-
September 16, 2025
Avalara Investors' Claims Pass Muster After 9th Circ. Revival
A Washington federal judge has allowed a proposed class action to proceed accusing tax software company Avalara Inc. of misleading investors ahead of an $8.4 billion deal to take the company private, but said the suit failed to adequately allege negligence by individual board members, giving investors one week to amend those claims.
-
September 16, 2025
Tax-Exempt Hospitals Face Financial Duress, Panel Hears
The nation's nonprofit hospitals are under growing financial stress due to cutbacks in federal funding, an aging population and unnecessary spending on programs unrelated to providing healthcare to their communities, industry experts told lawmakers Tuesday at a congressional hearing.
-
September 16, 2025
Tax Court's Petition Deadline Is Flexible, 1st Circ. Told
A taxpayer advocacy group urged the First Circuit on Tuesday to become the fourth appellate court to find that the deadline for filing a petition in the U.S. Tax Court can be extended to create fairness, arguing that the deadline is not a jurisdictional bar.
-
September 16, 2025
Loeb & Loeb Opens DC-Area Office With Ex-Reed Smith Attys
Loeb & Loeb LLP announced Tuesday the opening of a new office in Virginia, along with the arrival of an eight-person private client and tax controversy staff formerly of Reed Smith LLP.
-
September 16, 2025
House Panel To Weigh Greater Subpoena Power For Tax Court
House lawmakers are scheduled to consider a bill Wednesday that would grant the U.S. Tax Court the power to issue subpoenas without connection to a scheduled hearing and would apply mandatory recusal rules to its judges, the Joint Committee on Taxation reported Tuesday.
-
September 16, 2025
Brewer Denounces Gov't Home Distilling Ban In 6th Circ.
A brewery owner challenging the U.S. tax code's ban on home distilleries criticized the government's claim that he isn't hurt enough by the prohibition to warrant a suit, telling the Sixth Circuit that the ban prevents him from making whiskey at home and renders him ineligible for a distilling permit.
-
September 16, 2025
IRS Adds 39 Items To Taxable Chemical Substances
The Internal Revenue Service added 39 chemical substances to its list of those subject to Superfund excise taxes assessed to importers, the agency said Tuesday.
-
September 15, 2025
IRS Finalizes Retirement Savings Catch-Up Rules
The IRS released final regulations Monday that would allow workers reaching retirement age to catch up on their savings by making additional contributions above the annual limits to their employer-sponsored retirement plans, including a requirement for high earners to designate those additional funds as Roth contributions.
-
September 15, 2025
Tainted Evidence Sank Atty's Tax Court Case, 6th Circ. Told
The U.S. Tax Court relied on tainted evidence from the IRS when it affirmed the agency's denial of an Ohio attorney's attempt to deduct a theft loss and related legal expenses, he told the Sixth Circuit, urging it to reverse the lower court's ruling.
-
September 15, 2025
IRS Updates Corp. Bond Monthly Yield Curve For September
The IRS on Monday updated the corporate bond monthly yield curve used in calculations for defined benefit plans for September, as well as corresponding segment rates and other related provisions.
-
September 15, 2025
US, China Agree On TikTok Ownership Transfer, Bessent Says
The U.S. and China established a commercial framework for a deal with video sharing giant TikTok to transfer ownership of the app to the U.S., just days before a deadline to sell the app or shut it down, U.S. Treasury Secretary Scott Bessent told reporters at a press conference in Madrid on Monday.
-
September 15, 2025
McKesson Too Late To Fight IRS Cost-Share Rules, Gov't Says
Pharmaceutical giant McKesson waited too long to challenge transfer pricing regulations that cover cost-sharing arrangements as part of its $10 million tax refund bid, the U.S. government told a Texas federal court, arguing the statutory window to seek invalidation has closed.
-
September 15, 2025
Applicable Federal Rates Set To Drop For A Third Month
Applicable federal rates for income tax purposes are slated to drop in October, falling for a third month after a rebound in July, the Internal Revenue Service said Monday.
-
September 15, 2025
Court Urged To Block Offshore Asset Freeze In $28M Tax Row
The federal government's claim that a beneficiary of offshore trusts is likely to spend down assets to avoid a $28 million tax bill lacks evidence, the beneficiary argued in urging a Florida federal court not to freeze his accounts.
-
September 15, 2025
OIRA Concludes Review Of Tipped Occupations
The Office of Information and Regulatory Affairs has concluded its review of a proposed regulation concerning guidance on occupations that will be subject to President Donald Trump's policy of no tax on tips, the office said.
-
September 15, 2025
Kingsley Napley Bags Private Client Pro To Head Tax Desk
Kingsley Napley LLP said Monday that it has hired Paul Davidoff to head its international tax desk as the firm deals with a surge in work connected with tax and trusts amid an exodus of high-net-worth individuals from Britain.
-
September 12, 2025
Justices' Tariff-Suit Review Halts Case In Texas Federal Court
A Texas federal court has postponed further proceedings in a suit challenging President Donald Trump's emergency tariffs until the U.S. Supreme Court considers matters involving similar claims that were taken under review earlier this week.
-
September 12, 2025
Family Of Businessman Must Face $80M Tax Scheme Claims
A theater businessman's descendants and extended family cannot avoid claims by the U.S. accusing them of knowingly engaging in an $80 million tax shelter scheme to sell their shares of the family holding company, a New York federal judge ruled, declining to toss the suit.
-
September 12, 2025
BEPS At 10: The Global Tax Revamp That's Still Unfolding
The OECD's project against base erosion and profit shifting didn't upend the international tax landscape overnight, but a decade later, the project's fingerprints have emerged on major policies that materially changed corporate behavior, including the 2017 U.S. tax overhaul.
-
September 12, 2025
Taxation With Representation: Felesky Flynn, Gibson, Kirkland
In this week's Taxation With Representation, copper mining companies Anglo American and Teck Resources plan to merge, EchoStar agrees to sell spectrum licenses to SpaceX, and Diversified Energy acquires fellow energy operator Canvas.
Expert Analysis
-
Tariff Strategies For The US Renewable Energy Sector
The Trump administration's tariff actions over the last few months are challenging for the renewable energy industry — but there are strategies for contending with the uncertainty, including diversifying supply chains, seeking certification about equipment origins, and adding tariff-related language to supply contracts and offtake agreements, say attorneys at Sheppard Mullin.
-
Ch. 7 Marshaling Ruling Rests On Shaky Legal Grounds
In its recent holding in a Chapter 7 bankruptcy case that marshaling may not be applied against the IRS, a Texas federal court misapplied a bankruptcy code section and case law, leaving a draconian decision that could limit the scope of a powerful equitable estate tool, says Brian Shaw at Cozen O'Connor.
-
3 Tax Issues Manufacturers Should Watch In 2025 Budget Bill
As Congress works toward a budget reconciliation bill, manufacturing companies should keep a keen eye on proposals to change bonus depreciation, the qualified business income deduction and energy tax credits, which could have a significant impact on capital-intensive industries, say attorneys at Frost Brown Todd.
-
$38M Law Firm Settlement Highlights 'Unworthy Client' Perils
A recent settlement of claims against law firm Eckert Seamans for allegedly abetting a Ponzi scheme underscores the continuing threat of clients who seek to exploit their lawyers in perpetrating fraud, and the critical importance of preemptive measures to avoid these clients, say attorneys at Lockton Companies.
-
Jurisdictional Issues At Play In 9th Circ.'s FCA Trade Case
A decision by the Ninth Circuit in Island Industries v. Sigma Corp. could result in the U.S. Court of International Trade’s exclusive jurisdiction over trade-related FCA cases, a big shift in the enforcement landscape just as tariffs take center stage in trade policy, say attorneys at Haynes Boone.
-
Evolving Federal Rules Pose Further Obstacles To NY LLC Act
Following the Financial Crimes Enforcement Network's recent changes to beneficial ownership information reporting under the federal Corporate Transparency Act — dramatically reducing the number of companies required to make disclosures — the utility of New York's LLC Transparency Act becomes less apparent, say attorneys at Pillsbury.
-
Alternative Business Structures Raise Ethics Questions
The new KPMG law firm, launched in Arizona following that state's repeal of the prohibition on fee sharing with nonlawyers, raises a number of important practice questions, both for the firm and those law firms seeking to partner with it, says Deborah Winokur at Cozen O’Connor.
-
The IRS Shouldn't Go To War Over Harvard's Tax Exemption
If the Internal Revenue Service revokes Harvard's tax-exempt status for violating established public policy — a position unsupported by currently available information — the precedent set by surviving the inevitable court challenge could undercut the autonomy and distinctiveness of the charitable sector, says Johnny Rex Buckles at Houston Law Center.
-
Mitigating Import Risks Around Southeast Asian Solar Cells
The U.S. Department of Commerce's recent final determinations in its antidumping and countervailing duty investigations into solar cells produced in certain Southeast Asian countries make it important for U.S. purchasers to consider risk mitigation strategies, including modifying supply chains and contractually assigning import responsibilities, say attorneys at Morgan Lewis.
-
Reassessing Corporate Separateness After Explosion Of LLCs
Following the dramatic increase of limited liability companies in the U.S., the Corporate Transparency Act's enactment and the Trump administration's subsequent narrowing of that law, it's worth revisiting the underlying legal principles that govern shell companies in order to remedy the problems that initially motivated the CTA, says Jeff Newton at Omni Bridgeway.
-
Crisis Management Lessons From The Parenting Playbook
The parenting skills we use to help our kids through challenges — like rehearsing for stressful situations, modeling confidence and taking time to reset our emotions — can also teach us the fundamentals of leading clients through a corporate crisis, say Deborah Solmor at the Wisconsin Alumni Research Foundation and Cara Peterman at Alston & Bird.
-
Immunity Waiver Ruling A Setback For Ch. 7 Trustees
While governmental units should welcome the U.S. Supreme Court's recent decision in U.S. v. Miller restricting the reach of the Bankruptcy Code's sovereign immunity waiver, Chapter 7 trustees now have a limited ability to maximize bankruptcy estates, says Dan Prieto at Jones Day.
-
Adapting To Private Practice: From NY Fed To BigLaw
While the move to private practice brings a learning curve, it also brings chances to learn new skills and grow your network, requiring a clear understanding of how your skills can complement and contribute to a firm's existing practice, and where you can add new value, says Meghann Donahue at Covington.