Federal

  • November 06, 2025

    IRS Microcaptive Reporting Rules Suit Can Move Forward

    A global tax services provider can move forward with its suit against the IRS to vacate tax reporting rules for microcaptive insurance companies, a Texas federal court said, finding the company had a stake in the challenge and a right to bring the case.

  • November 06, 2025

    No $22M Break For Real Estate Partnership, 6th Circ. Affirms

    An Ohio real estate partnership cannot claim a $22 million charitable tax deduction on a 2016 preservation easement, the Sixth Circuit found, affirming the U.S. Tax Court and Internal Revenue Service's conclusions that the partnership grossly misstated the value of the donated historic building.

  • 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.

Expert Analysis

  • 5 Ways To Create Effective Mock Assignments For Associates

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    In order to effectively develop associates’ critical thinking skills, firms should design mock assignments that contain a few key ingredients, from messy fact patterns to actionable feedback, says Abdi Shayesteh at AltaClaro.

  • Congress Should Pass Sex Abuse Settlement Tax Exemptions

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    The proposed Survivor Justice Tax Prevention Act would expand tax exemptions more clearly for sexual abuse cases, and finally remove the stigma around compensation for emotional and psychological damage, says Rocco Strangio at Milestone & Co.

  • What's Next For Accounting Enforcement After SEC's Big 2024

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    The U.S. Securities and Exchange Commission under the Trump administration will likely continue to focus enforcement efforts on many of the same accounting and auditing issues that it pursued over the past year — but other areas, such as ESG, internal controls and cryptocurrency cases, may fall out of focus, say attorneys at Debevoise.

  • Mentorship Resolutions For The New Year

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    Attorneys tend to focus on personal achievements or career milestones when they set yearly goals, but one important area often gets overlooked in this process — mentoring relationships, which are some of the most effective tools for professional growth, say Kelly Galligan at Rutan & Tucker and Andra Greene at Phillips ADR.

  • Coaching Little League Makes Me A Better Lawyer

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    While coaching poorly played Little League Baseball early in the morning doesn't sound like a good time, I love it — and the experience has taught me valuable lessons about imperfection, compassion and acceptance that have helped me grow as a person and as a lawyer, says Alex Barnett at DiCello Levitt.

  • 5 Litigation Funding Trends To Note In 2025

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    Lawyers and their clients must be prepared to navigate an evolving litigation funding market in 2025, made more complicated by a new administration and the increasing overall cost of litigation, says Jeffery Lula at GLS Capital.

  • Rethinking Litigation Risk And What It Really Means To Win

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    Attorneys have a tendency to overestimate litigation risk before summary judgment and underestimate risk after it, but an eight-stage litigation framework can clarify risk at different points and help litigators reassess what true success looks like in any particular case, says Joshua Libling at Arcadia Finance.

  • Small Biz Caught In Corporate Transparency Act Crossfire

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    Despite compliance being put on hold due to a nationwide preliminary injunction, small businesses have been caught in the middle of the legal battle over the Corporate Transparency Act — and confusion over the law's requirements could result in major penalties, say attorneys at Snell & Wilmer.

  • No, Litigation Funders Are Not 'Fleeing' The District Of Del.

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    A recent study claimed that litigation funders have “fled” Delaware federal court due to a standing order requiring disclosure of third-party financing, but responsible funders have no problem litigating in this jurisdiction, and many other factors could explain the decline in filings, say Will Freeman and Sarah Tsou at Omni Bridgeway.

  • Hydrogen Regs Will Provide More Certainty — If They Survive

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    Newly finalized regulations implementing the Section 45V clean hydrogen tax credit allow producers more flexibility, and should therefore help put the industry on more solid footing — but the incoming Trump administration and Republican Congress will have multiple options for overturning or altering the regulations, say attorneys at Steptoe.

  • 5 E-Discovery Predictions For 2025 And Beyond

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    In the year to come, e-discovery will be shaped by new and emerging trends, from the adoption of artificial intelligence provisions in protective orders, to the proliferation of emojis as a source of evidence in contemporary litigation, say attorneys at Littler.

  • What's Ahead As Transparency Act Comes To A Crossroads

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    Synthesizing the contrasting federal district and appellate court rulings on the Corporate Transparency Act’s validity reveals several main areas of debate that will likely remain at issue as challenges to the law continue winding through the courts, say attorneys at Farella Braun.

  • Final Hydrogen Tax Credit Regs Add Flexibility For Producers

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    The recently released final regulations implementing the Inflation Reduction Act's clean hydrogen production tax credit offer taxpayers greater flexibility, reducing risk and creating more certainty for investments in the industry, thus diminishing — but not eliminating — the risk of legal challenges to the regulations, say attorneys at Steptoe.

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