Federal
-
November 25, 2025
IRS To Propose Regs On Repeal Of CFC Tax Year Deferral
The IRS intends to issue proposed regulations that address the repeal of a provision that allowed a controlled foreign corporation to begin its tax year one month earlier than its majority shareholder in the U.S., the agency said Tuesday.
-
November 25, 2025
Senator Admits To Owing $5M In Delinquent Taxes
West Virginia Sen. Jim Justice and his wife have admitted they owe more than $5 million in back taxes, settling a government lawsuit that accused them of failing to pay off their bill for the last decade, according to federal court filings.
-
November 24, 2025
Tax Court Upholds Nix Of $1.9M Deduction Post-Chevron
A Texas couple cannot claim a $1.9 million tax break for farming, the U.S. Tax Court affirmed Monday, saying a U.S. Supreme Court ruling overturning long-standing deference to federal agencies did not invalidate regulations at issue in the case.
-
November 24, 2025
$34M Historic Easement Tax Break Wrongly Denied, Court Told
A partnership that donated an easement to protect historic school buildings in Cleveland challenged the IRS' denial of its $34 million charitable donation deduction in the U.S. Tax Court, saying the agency didn't explain why the donation didn't qualify for the tax break.
-
November 24, 2025
IRS Ticket Tax Fails After Loper Bright, 6th Circ. Told
The Internal Revenue Service no longer has the discretion to apply a 7.5% ticket tax on membership fees collected by a private jet-sharing operator, the company told the Sixth Circuit, citing the U.S. Supreme Court's landmark decision in Loper Bright.
-
November 24, 2025
IRS Updates Corp. Bond Monthly Yield Curve For October
The Internal Revenue Service updated Monday the corporate monthly yield curve used in calculations for defined benefit plans for October as well as corresponding segment rates and other related provisions.
-
November 24, 2025
AICPA Urges Allowing Barred Foreign Losses For Use In US
Losses that aren't allowed to reduce tax liabilities abroad should be accepted in the U.S. under rules surrounding dual consolidated losses because they don't cause the dual deductions that those rules aim to prevent, the American Institute of Certified Public Accountants said Monday.
-
November 24, 2025
G20 Countries Working To Address Pillar 2 Concerns
Group of 20 nations are negotiating with countries at the Organization for Economic Cooperation and Development to address concerns regarding the 15% global minimum tax agreement known as Pillar Two, G20 leaders announced during their Johannesburg summit.
-
November 24, 2025
Federal Claims Court Claws Back Couple's $444K Refund
The Internal Revenue Service erroneously issued a Florida couple a $444,000 refund after they misrepresented facts to the agency, the U.S. Court of Federal Claims said.
-
November 24, 2025
Trusts' Identical $2M Tax Bills Don't Add Up, Tax Court Told
A pair of related trusts challenged nearly $2 million each in taxes and penalties, telling the U.S. Tax Court that the Internal Revenue Service had asserted identical deficiencies despite making different adjustments to the respective tax returns.
-
November 21, 2025
Judge Halts IRS-ICE Info-Sharing Agreement
A D.C. federal judge temporarily stopped the IRS on Friday from sharing confidential taxpayer addresses with immigration enforcement officials, saying the agency's disclosures of addresses in August under an information-sharing deal were unlawful.
-
November 21, 2025
IRS Finalizes Stock Buyback Tax Regs Without 'Funding Rule'
The Internal Revenue Service released final regulations Friday for the excise tax on corporations' stock buybacks and similar transactions without what is known as the funding rule, which would apply the levy to a U.S. subsidiary of a foreign parent company.
-
November 21, 2025
Bill Proposes Bitcoin Tax Payments To Build Crypto Reserve
A House Republican introduced a bill that would allow Americans to pay federal taxes in bitcoin and direct the government to use all bitcoin tax payments to build the Strategic Bitcoin Reserve.
-
November 21, 2025
Justices Urged To Uphold $268M Tax Break For Truck Co.
The U.S. Supreme Court should let stand the denial of $268 million in excise tax exemptions for a Tennessee truck company, the federal government urged, saying the case doesn't meet any of the traditional requirements for high court review and raises an isolated issue.
-
November 21, 2025
IRS Issues Guidelines For Claiming Tip Tax Relief In 2025
The Internal Revenue Service published guidance Friday for taxpayers looking to claim the new tax deductions for tips and overtime in 2025, as relevant tax forms haven't yet been updated to more easily account for them.
-
November 21, 2025
Ga. Tax Worker Granted Interest On Chrisley Slander Verdict
A Georgia tax official will collect interest on top of a $755,000 slander verdict she won from former reality TV personality and convicted felon Todd Chrisley after a jury found he falsely accused her of unethical and illegal behavior, a Georgia federal judge said.
-
November 21, 2025
Key Issues Facing The IRS Amid Looming Budget Cuts
The Internal Revenue Service is facing steep budget cuts in 2026, raising concerns about the agency's ability to handle taxpayer services and enforcement operations that are crucial for bringing in revenue and maintaining compliance with the voluntary system. Here, Law360 looks at the key areas where resource constraints are expected to hamper the IRS and what practitioners can do in response.
-
November 21, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included updated rules allowing investment and grantor trusts to stake their digital assets without losing their tax benefits as long as they meet certain requirements.
-
November 20, 2025
Importers Left With Uncertainty After US-China Trade Truce
U.S. importers have welcomed the latest trade truce with China and the ability to obtain key minerals without new licensing requirements for the next year, but continue to have questions about how commitments in the bilateral agreement will be met and concerns about risks of escalation.
-
November 20, 2025
Treasury To Curtail Tax Credits For Unauthorized Immigrants
The U.S. Department of the Treasury plans to propose rules that would bar unauthorized immigrants from receiving popular refundable individual tax credits such as the earned income tax credit, the department announced Thursday.
-
November 20, 2025
6th Circ. Urged To Affirm High Bar For Donor Reporting Rule
A libertarian organization urged the Sixth Circuit to affirm a finding that the federal government must meet a relatively high bar before it can force nonprofits to reveal the identities of their donors, saying the standard acknowledges the burden of the disclosures on First Amendment rights.
-
November 20, 2025
FBAR Penalty Against Ex-Prof Is Constitutional, Court Says
A former professor must pay the entire nearly $438,000 penalty the Internal Revenue Service assessed against him for his failure to timely disclose foreign bank accounts, a California magistrate judge held, finding the amount is not unconstitutionally excessive and declining to reduce it.
-
November 20, 2025
Trump Pardons Nursing Home Owner In $39M Tax Fraud
President Donald Trump granted clemency to a nursing home operator who had been sentenced to three years in prison for a $39 million employment tax fraud scheme involving care centers he owned across the country.
-
November 20, 2025
IRS Unveils Interim Rules For Tax Perk For Rural Loan Interest
The IRS released temporary guidance Thursday on a new incentive that would exclude from taxable income 25% of interest from loans secured by a rural or agricultural property, including the definition of an eligible loan and the determination of the property's fair market value.
-
November 19, 2025
Judge Unlikely To Find Eaton's Debt To Parent Wasn't Real
A U.S. Tax Court judge said Wednesday that he's unlikely to find that the intercompany debt U.S.-based Eaton Inc. owed its Irish parent was unreal and should be recharacterized as equity, all but dismissing an alternative argument raised by the Internal Revenue Service.
Expert Analysis
-
Power To The Paralegals: The Value Of Unified State Licensing
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.
-
10 Soft Skills Every GC Should Master
As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.
-
An Unrestrained, Bright-Eyed View Of Legal AI's Future
Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.
-
Tracking The Evolution In Litigation Finance
Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.
-
E-Discovery Quarterly: The Perils Of Digital Data Protocols
Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.
-
Maximizing Exemptions Before TCJA Rides Into The Sunset
Excerpt from Practical Guidance
Individuals with taxable estates can optimize the benefits of estate planning strategies like spousal lifetime access trusts by setting them up before increases in estate and gift tax exemptions under the 2017 Tax Cuts and Jobs Act sunset in January, say attorneys at Katten.
-
A Cold War-Era History Lesson On Due Process
The landmark Harry Bridges case from the mid-20th century Red Scare offers important insights on why lawyers must be free of government reprisal, no matter who their client is, says Peter Afrasiabi at One LLP.
-
How BigLaw Executive Orders May Affect Smaller Firms
Because of the types of cases they take on, solo practitioners, small law firms and public interest attorneys may find themselves more dramatically affected by the collective impact of recent government action involving the legal industry than even the BigLaw firms named in the executive orders, says Reuben Guttman at Guttman Buschner.
-
Lawsuits Shouldn't Be Shadow Assets For Foreign Capital
Third-party litigation financing amplifies inefficiencies from litigation and facilitates national exposure to foreign influence in the U.S. justice system, so full disclosure of financing arrangements should be required as a matter of institutional integrity, says Roland Eisenhuth at the American Property Casualty Insurance Association.
-
How To Accelerate Your Post-Attorney Career Transition
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
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
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
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.