Federal

  • June 03, 2025

    Precedent Does Apply To $6.6M Microcaptive Case, Court Told

    A captive insurance program operator challenging $6.6 million in tax fraud penalties told a Pennsylvania federal court that the government boldly and incorrectly claimed that the U.S. Supreme Court's landmark ruling requiring a jury to make certain fraud findings doesn't apply to its case.

  • June 02, 2025

    Budget Bill Would Deepen Residential Solar's Woes

    A Sunnova unit's bankruptcy declaration — the latest among dozens of solar companies that have struggled to stay afloat — adds to evidence of a floundering residential solar industry, which now faces further diminishing prospects under the federal budget reconciliation bill.

  • June 02, 2025

    1st Circ. Largely Backs Convictions For Cop Union Kickbacks

    The First Circuit on Monday mostly upheld the convictions of a former Massachusetts state police union president and a Beacon Hill lobbyist who were found guilty of running a kickback scheme, but ordered new sentencing hearings for them after vacating some of the guilty findings.

  • June 02, 2025

    IRS Issues Interim Regs To Simplify Corp. AMT Determination

    The Internal Revenue Service released temporary regulations Monday that offered a simplified method for large companies seeking to determine whether the 15% corporate alternative minimum tax applies to them, as well as penalty relief for those that underpaid the levy this year.

  • June 02, 2025

    Justices Urged To Reject Bid Disputing IRS Crypto Summons

    The U.S. Supreme Court should not take up the case of a bitcoin investor who claimed the IRS violated his privacy when it seized his records from the cryptocurrency exchange, the government argued, saying the case is a poor vehicle for addressing concerns about digital-era transactions.

  • June 02, 2025

    4 Mass. Rulings You May Have Missed In May

    Massachusetts judges grappled with accusations of fraud in the sale of a struggling life sciences company and gave the benefit of the doubt to a vendor who allegedly sold the state gallons of ineffective hand sanitizer, among other notable rulings last month.

  • June 02, 2025

    Tax Court Finds No Abuse By IRS In Rejecting Man's Tax Offer

    The Internal Revenue Service did not abuse its discretion in rejecting a man's offer in compromise for the balance on a $400,000 tax bill, the U.S. Tax Court ruled Monday, saying the agency properly considered cash in the man's bank account and his current wages.

  • June 02, 2025

    Halliburton Wants IRS To Release Docs In $35M Tax Dispute

    The Internal Revenue Service should be ordered to comply with Halliburton's discovery requests in a dispute over a $35 million deduction for payments the company said it made to a foreign government to protect its employees from harassment, the company told a Texas federal court.

  • June 02, 2025

    Tax Court Cuts $21M Off Former Ga. Quarry's Deduction Value

    A donated 85-acre land plot in Georgia originally valued at nearly $22 million should have been valued around $193,000, the U.S. Tax Court found Monday, agreeing with the Internal Revenue Service.

  • June 02, 2025

    Vanguard, Investors Renegotiating After $40M Tax Deal Axed

    Vanguard and investors have scrapped a $40 million class action deal in a case over surprise tax bills from a fund restructuring and will resume settlement discussions after a Pennsylvania federal judge recently found that the deal could have saddled investors with attorney fees.

  • June 02, 2025

    Feds Want 12½ Years For Ex-Ill. Speaker Convicted Of Bribery

    Prosecutors are urging an Illinois federal judge to sentence former state House Speaker Michael Madigan to prison for 12½ years for bribery, conspiracy and fraud, saying his conduct adds "another sordid chapter to Illinois' storied reputation of corruption" while Madigan, armed with more than 200 letters of support, seeks only probation.

  • June 02, 2025

    Foley & Lardner Opens In Nashville With 3 Holland & Knight Attys

    Foley & Lardner LLP has chosen Nashville as the location for its 27th office worldwide, bringing on three attorneys who had been at Holland & Knight LLP to work on regulatory, tax and transactional matters, the firm announced Monday.

  • June 02, 2025

    Ex-Atty In $7B Tax Fraud Tells 7th Circ. IRS Can't Collect

    A former attorney sentenced to prison in connection with a $7 billion tax fraud told the Seventh Circuit that the Internal Revenue Service lacks the power to collect his court-ordered $371 million restitution, calling the agency's claims against him "wild and scurrilous."

  • June 02, 2025

    Ex-Par Funding CFO Sentenced To 5½ Years, Must Pay $303M

    Joseph Cole Barleta, the last of the triumvirate behind the $404 million Par Funding investment scam to be sentenced, was handed a 66-month prison term Monday, along with a staggering $303 million restitution order.

  • June 02, 2025

    IRS To Hold Hearing On Sourcing Cloud Transaction Income

    The Internal Revenue Service and U.S. Treasury Department will hold a hearing July 17 on proposed rules on the source of income from cloud transactions, they said Monday.

  • May 30, 2025

    Split 9th Circ. Won't Unblock Trump's Gov't Overhaul

    A split Ninth Circuit on Friday refused to lift a California federal judge's preliminary block of President Donald Trump's executive order directing layoffs at federal agencies, handing a win to a coalition of unions, nonprofits and cities that argue the order exceeded the president's authority.

  • May 30, 2025

    US-China Trade Talks Could Resume After Stall Over Minerals

    Stalled trade talks between the U.S. and China could resume with a phone call between the countries' leaders as early as this week, a Trump economic adviser said Sunday.

  • May 30, 2025

    Convicted Crypto Investor's Wife Says Gov't Can't Seize Funds

    The wife of a bitcoin investor sentenced to prison for concealing millions of dollars from the IRS asked a Texas federal court Friday to stop the federal government from taking her money to help make up for $1 million in restitution stemming from his cryptocurrency sales.

  • May 30, 2025

    IRS Failed To Alert Thousands To Contractor's Data Breach

    Approximately 12,200 letters the Internal Revenue Service sent to individuals and businesses whose tax information was stolen by a former agency contractor were undeliverable for issues such as not having complete addresses, the Treasury Inspector General for Tax Administration said.

  • May 30, 2025

    IRS Slow To Convert Nontax Forms To Digital, TIGTA Says

    Only 12% of the Internal Revenue Service's 280 nontax paper forms that require one or more signatures have been converted to digital formats, though plans have been made to speed the process, the Treasury Inspector General for Tax Administration reported.

  • May 30, 2025

    Pa. Couple Should Pay $1.77M Tax Bill, Judge Says

    A Pennsylvania couple who purchased a Maserati and a Porsche and took trips to international destinations while owing the Internal Revenue Service $1.77 million should be required to pay those tax debts, a Pennsylvania federal magistrate judge found.

  • May 30, 2025

    Ohio Judge Slams Eaton For Ongoing IRS Disclosure Fight

    An Ohio federal judge denied Eaton Corp.'s bid to withhold foreign employee evaluations from the IRS, ruling Friday that the power management multinational's "astounding amount of effort" to fight disclosure has been a poor use of judicial resources.

  • May 30, 2025

    Taxation With Representation: Kirkland, Cravath, Latham

    In this week's Taxation With Representation, WiseTech completes a $2.1 billion merger with E2open, Acrisure buys a payroll management company for $1.1 billion and Hailey Bieber sells her Rhode skincare and makeup company to e.l.f. beauty for $1 billion.

  • May 30, 2025

    Tax 'Magician' Gets 4 Years For $145M Return Fraud

    A tax preparer who falsified returns to the tune of $145 million in tax losses to the federal government was sentenced to four years in prison — half of what prosecutors had pushed for — after telling a New York federal court that he meant to help poor customers.

  • May 30, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included updated interest rates for overpayments and underpayments of tax for the quarter beginning in July.

Expert Analysis

  • 4 Ways Women Attorneys Can Build A Legal Legacy

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    This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.

  • A Judge's Pointers For Adding Spice To Dry Legal Writing

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    U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.

  • Why NY May Want To Reconsider Its LLC Transparency Law

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    Against the backdrop of the myriad challenges to the federal Corporate Transparency Act, it may be prudent for New York to reconsider its adoption of the LLC Transparency Act, since it's unclear whether the Empire State's "baby-CTA" statute is still necessary or was passed prematurely, say attorneys at Pillsbury.

  • IRS Scrutiny May Underlie Move Away From NIL Collectives

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    The University of Colorado's January announcement that it was severing its partnership with a name, image and likeness collective is part of universities' recent push to move NIL activities in-house, seemingly motivated by tax implications and increased scrutiny by the Internal Revenue Service, say attorneys at Buchanan Ingersoll.

  • 7 Tips For Associates To Thrive In Hybrid Work Environments

    Excerpt from Practical Guidance
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    As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.

  • IRS Should Revise Overbroad Microcaptive Regs

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    Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.

  • Terraform Case May Be Bellwether For Crypto Enforcement

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    The prosecution of crypto company Terraform Labs and its CEO, Do Kwon, offers a unique test of the line between lawful and unlawful conduct in digital transactions, and the Trump administration’s posture toward the case will provide clues about its cryptocurrency enforcement agenda in the years to come, say attorneys at Brooks Pierce.

  • How Law Firms Can Counteract The Loneliness Epidemic

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    The legal industry is facing an urgent epidemic of loneliness, affecting lawyer well-being, productivity, retention and profitability, and law firm leaders should take concrete steps to encourage the development of genuine workplace connections, says Michelle Gomez at Littler and Gwen Mellor Romans at Herald Talent.

  • Texas Fraud Case Shows Dangers Of Faulty Crypto Reporting

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    The recent sentencing of a man who failed to properly report capital gains from bitcoin sales is a reminder that special attention must be given to the IRS' reporting requirements in order to stay out of the government's crosshairs, says Saverio Romeo at Fox Rothschild.

  • Potential Impacts Of IRS' $1M Affiliate Pay Deduction Cap

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    If finalized, a recent Internal Revenue Service proposal expanding Section 162(m) of the Internal Revenue Code to include the highly compensated employees of affiliates would make tracking which executives may be subject to the limit from year to year far more complex, say attorneys at Debevoise.

  • 5 Keys To Building Stronger Attorney-Client Relationships

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    Attorneys are often focused on being seen as the expert, but bonding with clients and prospects by sharing a few key personal details provides the basis for a caring, trusted and profoundly deeper business relationship, says Deb Feder at Feder Development.

  • Notable Q4 Updates In Insurance Class Actions

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    In a continuation of trends in property and casualty insurance class actions, last quarter insurers struggled with defending the merits and class certification of sales tax and fee suits, and labor depreciation cases, but succeeded in dismissing privacy class actions at the pleading stages, says Mathew Drocton at BakerHostetler.

  • Attorneys Must Act Now To Protect Judicial Independence

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    Given the Trump administration's recent moves threatening the independence of the judiciary, including efforts to impeach judges who ruled against executive actions, lawyers must protect the rule of law and resist attempts to dilute the judicial branch’s authority, says attorney Bhavleen Sabharwal.

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