Federal
-
July 18, 2025
Western Union Says IRS Used Flawed Rule To Hike Income
The Internal Revenue Service erroneously included more than $8.2 million in foreign income in Western Union Co.'s foreign tax calculation based on an agency rule that was passed without properly notifying the public, the company told the U.S. Tax Court.
-
July 18, 2025
Taxation With Representation: Wachtell, Slaughter And May
In this week's Taxation With Representation, Blackstone pours billions into data centers and related infrastructure, Waters Corp. and Becton Dickinson look to form a new life sciences powerhouse, Reckitt sells 70% of its Essential Home business to private equity firm Advent, and Chevron completes its acquisition of Hess following a favorable arbitral award.
-
July 18, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the withdrawal of plans to eliminate a safe harbor that allows some businesses an expanded use of net operating losses.
-
July 18, 2025
IRS Issues 2026 Table For Premium Tax Credit Calculations
The Internal Revenue Service published the table used to determine the 2026 premium tax credit Friday.
-
July 17, 2025
Canada Mulling Changes To Ability To Rewrite Transactions
Canada's Department of Finance is considering changes to legislation that outlines the tax authority's power to recharacterize transactions set forth in contracts between related parties when their behavior doesn't match what the contract says, an official said Thursday.
-
July 17, 2025
IRS Leaker Asks DC Circ. To Bar Comments By Ex-Employer
A tech worker appealing a five-year sentence for leaking tax returns while on the job at the IRS through contractor Booz Allen asked the D.C. Circuit on Thursday to block his former employer from weighing in, saying the company's opinion that he should finish his prison term is irrelevant.
-
July 17, 2025
5th Circ. Affirms Nix Of Doctor's Captive Insurance Deductions
The owner of a Texas urgent care network is not entitled to $1 million in tax deductions for insurance premiums he paid to inside companies, the Fifth Circuit ruled, affirming the U.S. Tax Court's decision that the payments were not actually for insurance.
-
July 17, 2025
US Challenge To Belgian Minimum Tax Rules Heads To ECJ
A Belgian court said Thursday it has asked the European Union's highest court to weigh in on a U.S. industry group's challenge to the country's global minimum tax rules.
-
July 17, 2025
GAO Urges IRS To Hone Method For Gauging Better Service
The Internal Revenue Service should establish an evidence-based approach to assessing the results of its efforts to improve taxpayers' experience with the agency, the U.S. Government Accountability Office said Thursday.
-
July 16, 2025
Attys Tout 3 Real Estate Investment Wins In Federal Budget
Real estate investors can breathe a collective sigh of relief seeing the final version of the "One, Big, Beautiful Bill Act" that President Donald Trump signed into law this month, as it is largely favorable to the industry and keeps several much-admired tax breaks alive.
-
July 16, 2025
House Panel Urged To Modernize Tax Rules For Digital Assets
Congress needs to create tax rules for digital assets such as cryptocurrency and nonfungible tokens because the current regime is burdensome for businesses and pushing development out of the U.S., industry representatives told a House Ways and Means Committee subcommittee Wednesday.
-
July 16, 2025
OECD Mulling Tweaks To Arm's-Length Range Guidance
The Organization for Economic Cooperation and Development's guidance on the arm's-length range is an area ripe for simplification because the resources needed to calculate and make adjustments to the range are sometimes out of proportion with the amount in dispute, an official said Wednesday.
-
July 16, 2025
No Tax Refund For Uncashed Retirement Checks, IRS Says
The Internal Revenue Service said Wednesday that an employer administering a retirement plan cannot get a tax refund or tax adjustment when it cuts a distribution check to an individual who had not made a withholding election and did not cash the check.
-
July 16, 2025
Tax Losses Back Retired Prof's FBAR Penalties, US Says
A retired professor's admission in U.S. Tax Court that his failure to report his foreign bank accounts caused tax losses shows that a California federal court should affirm tax penalties against him of more than $400,000, the U.S. government said.
-
July 16, 2025
Speaker's Aide Won't Rule Out 'Secure 3.0' Retirement Bill
An aide to House Speaker Mike Johnson told tax attorneys in Washington, D.C., Wednesday that he's not ruling out Congress passing a retirement policy overhaul that's known informally as Secure 3.0, though exact timing on such an effort remains unclear because of the busy year-end schedule.
-
July 16, 2025
Cheesesteak Maker Gets 2 Mos. Sliced From Prison Sentence
A member of the family behind the popular Tony Luke's cheesesteak shop in South Philadelphia was re-sentenced Wednesday to 18 months in prison, marking a two-month reduction of the original term he'd received for paying employees under the table.
-
July 15, 2025
Trump Admin Seeks Win In Harvard $2B Funding Freeze Case
The Trump administration urged a Massachusetts federal judge Monday to grant it summary judgment in Harvard University's lawsuit challenging the government's effort to freeze $2.2 billion in funding, arguing the dispute is a contract fight that belongs in the Federal Claims Court and the allegations fail on the merits.
-
July 15, 2025
Trump Says US Has Struck Trade Deal With Indonesia
President Donald Trump announced Tuesday that the U.S. has reached a trade deal with Indonesia that includes a 19% tariff on all goods exported by the Southeast Asian country to the U.S., while American goods exported there will be free of tariffs.
-
July 15, 2025
IRS Rates Dip Slightly In August After July Rebound
Applicable federal rates for income tax purposes are set to decline in August, easing slightly after July's increases, the Internal Revenue Service said Tuesday.
-
July 15, 2025
Tax Return Preparer Cops To Role In $25M Fraud Scheme
A tax return preparer pled guilty in a California federal court for his role in a fraud scheme that involved submitting fake federal income tax returns to claim $25 million in refunds.
-
July 15, 2025
Tax Court Warns Attys In Denying $20M Easement Deduction
The U.S. Tax Court threatened Tuesday to force attorneys for a Georgia partnership to personally pay court costs after they had argued at trial for a $20 million tax deduction for a conservation easement donation, an amount the court said was over 100 times the land's value.
-
July 15, 2025
Tax Court Denies Exclusion To Reduce Estate's Value
The estate of one deceased spouse did not file its return in time for the estate of another deceased spouse to use an exclusion to reduce the value of the second estate, the U.S. Tax Court said in a decision Tuesday.
-
July 15, 2025
Tax Court Denies Equitable Tolling To Firm In Collection Action
A North Dakota law firm that convinced the U.S. Supreme Court three years ago that federal courts can extend equitable tolling for nonjurisdictional deadlines was not able to sway the U.S. Tax Court to extend the time for the firm to file a collection action case against the IRS, according to a bench opinion.
-
July 15, 2025
IRS Updates Corp. Bond Monthly Yield Curve For July
The Internal Revenue Service updated Tuesday the corporate bond monthly yield curve used in calculations for defined benefit plans for July, as well as corresponding segment rates and other related provisions.
-
July 15, 2025
IRS To Provide Transition Relief For Tips And OT Tax Breaks
The IRS will provide guidance for new deductions for tips, overtime pay and car loan interest that will include transition relief for taxpayers claiming those deductions and employers subject to associated reporting requirements, according to a fact sheet released by the agency.
Expert Analysis
-
Law School's Missed Lessons: Communicating With Clients
Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.
-
Bill Leaves Renewable Cos. In Dark On Farmland Reporting
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
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
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
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
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
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
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
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
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
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
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
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.