Federal

  • April 29, 2025

    IRS Shouldn't Elect To Use OECD Pricing Method, AICPA Says

    The IRS shouldn't unilaterally apply the Organization for Economic Cooperation and Development's streamlined approach to price-related companies' baseline distribution and marketing costs and should give companies a wide berth to choose the approach, the American Institute of Certified Public Accountants told the agency.

  • April 28, 2025

    Court Urged To Reconsider Jurisdiction In Tribal Tariff Row

    Blackfeet Nation members are asking a Montana federal judge to reconsider an order to transfer their challenge against President Donald Trump's tariffs on imports from Canada and abroad to the U.S. Court of International Trade, saying the decision is based on the constitutional question of the Indian commerce clause.

  • April 28, 2025

    NC Dentist Acquitted Of $3M Fraud, Tax Evasion Charges

    A North Carolina dentist was acquitted of wire fraud and tax evasion charges on the fourth day of a federal jury trial in which prosecutors had alleged the dentist submitted false loan applications to the Small Business Administration and failed to pay income taxes.

  • April 28, 2025

    Feds Urged To Drop Crypto Mixer Charges After DOJ Memo

    Federal prosecutors are weighing whether to continue pursuing a criminal case against two executives of crypto mixing service Samourai Wallet in light of a recent U.S. Department of Justice memo limiting certain digital asset prosecutions.

  • April 28, 2025

    Tax Services Provider Andersen Files Confidential IPO Plans

    Tax and legal services provider Andersen Group Inc. said Monday it confidentially filed for an initial public offering, marking a first step toward going public amid market volatility that has largely frozen IPOs in recent weeks.

  • April 28, 2025

    Board Game Co., 11 Others Say Trump Tariffs Unconstitutional

    President Donald Trump's tariffs exceed the constitutional authority of the executive branch, argued 12 American companies, including a manufacturer of tabletop games that are printed in China, urging a federal court to halt them.

  • April 28, 2025

    Car Dealer Can't Duck Fines For Cash Reporting Failures

    The U.S. Tax Court upheld more than $118,000 in penalties Monday against an Arizona-based car dealership, rejecting its argument that third-party tax software errors were to blame for its failures to report cash transactions of over $10,000 for 2016.

  • April 28, 2025

    2nd Circ. Upholds Clinic Manager's Repeat Charges For Fraud

    A decision that allowed the federal government to reindict a health clinic manager for a Medicare and tax fraud scheme can stand, a Second Circuit panel found Monday, agreeing with the lower court that his offenses were serious enough to permit it.

  • April 28, 2025

    No Harm Shown Over DOGE Access To Tax Data, US Says

    The U.S. government asked a D.C. federal court to throw out four organizations' bid to keep the White House's Department of Government Efficiency from accessing confidential taxpayer data, saying their suit fails to show injury to the groups' members.

  • April 28, 2025

    Feds No Longer Want Convicted Ex-Ill. Speaker To Forfeit $3M

    The federal government has reversed course on a bid for former Illinois House Speaker Michael Madigan to forfeit more than $3 million in the wake of his partial conviction on public corruption, saying it stands by its legal arguments but was backing off as "a matter of discretion."

  • April 28, 2025

    Latham Advises REIT's $340M Stock Offering

    Retail-focused real estate investment trust Agree Realty Corp. signed a forward sale agreement in which the REIT made a more than $340 million public offering of 4.5 million shares of its common stock for the price of $75.70 apiece, in a deal guided by Latham & Watkins LLP, the law firm announced.

  • April 28, 2025

    Miami Tax Prep Owner Barred From Work For 3 Years

    A Miami tax preparation business and its owner are barred from doing any tax work for three years and must pay $446,000 in client fees to the government for preparing false returns the government claims caused a $500,000 tax loss, a Florida federal court said Monday.

  • April 28, 2025

    High Court Passes On Dell Worker's Income Tax Case

    The U.S. Supreme Court declined Monday to review a decision that nearly $300,000 in income earned by an employee of Dell Techologies Inc. is taxable, letting stand a Fifth Circuit ruling that additionally upheld a penalty against the man for making frivolous arguments.

  • April 25, 2025

    Judge Blocks Trump Order Limiting Fed. Worker Bargaining

    A Washington, D.C., federal judge on Friday blocked President Donald Trump's order last month seeking to end collective bargaining for workers at more than a dozen federal agencies with national security roles, two days after suggesting during oral arguments that Trump's order was retaliatory.

  • April 25, 2025

    Feds Say Tariff Fight Belongs In International Trade Court

    The Trump administration wants to litigate a challenge to its tariffs in a federal trade court, not the D.C. district court, arguing that the U.S. Court of International Trade is the only venue with jurisdiction to hear the case.

  • April 25, 2025

    Sen. Crapo Calls Exec Session For Commerce, Treasury Noms

    U.S. Senate Finance Committee Chairman Mike Crapo, R-Idaho, announced Friday that it will hold an executive session Tuesday to consider President Donald Trump's picks for roles at the U.S. Department of Commerce and U.S. Department of the Treasury.

  • April 25, 2025

    US Seeks To Block Refund For Captive Insurance Penalties

    A Pennsylvania federal court should reject a company's bid for an immediate penalty refund for operating what the IRS claimed is an abusive tax shelter through its microcaptive insurance program, the government argued Friday, saying the company is seeking protection in an unrelated U.S. Supreme Court ruling.

  • April 25, 2025

    IRS Says Docs In Captive Insurance Case Are Privileged

    The IRS defended its refusal to release information to a tax services company seeking audit records of its captive insurance program, telling a Texas federal court that the agency's redactions of the requested records are protected by attorney-client privilege and other exceptions to the Freedom of Information Act.

  • April 25, 2025

    Takeaways From Justices' Questioning In Tax Collection Suit

    The U.S. Supreme Court heard oral arguments this past week in a nearly 11-year-old case that could redefine taxpayers' challenges of Internal Revenue Service determinations to collect tax debts. Here, Law360 examines tax practitioners' key takeaways from the justices' remarks.

  • April 25, 2025

    Taxation With Representation: Dechert, Brown Rudnick

    In this week's Taxation With Representation, Boeing sells parts of its digital aviation solutions business to Thoma Bravo, Baker Tilly and Moss Adams join forces, Mobico sells its U.S. school bus business to I Squared Capital, and Apollo commits to a joint venture with Bullrock Energy Ventures.

  • April 25, 2025

    5 Issues Benefits Attys Want The Gov't To Shed Light On

    The first three months of President Donald Trump's administration have left lawyers who represent employers and benefit plans hungry for clarity on issues like cryptocurrency as a 401(k) investment and coverage for gender-affirming care. Here, Law360 looks at five areas where attorneys are hoping for guidance or regulations.

  • April 25, 2025

    No Weekly Internal Revenue Bulletin Articles For April 28

    The Internal Revenue Service's weekly bulletin, issued Friday, said there were no articles to be published for April 28.

  • April 24, 2025

    Union Challenges Treasury's Suit Over CBA Executive Order

    A National Treasury Employees Union affiliate urged a Kentucky federal judge Thursday not to find the U.S. Department of the Treasury can lawfully terminate its labor contracts with the national union, arguing the district court does not have jurisdiction and the agency can't request an advisory opinion.

  • April 24, 2025

    Gov't Stands By $1.7M In FBAR Penalties Against Texan

    Constitutional law does not stop the U.S. from imposing $1.7 million in penalties against a Texan for failure to report foreign bank accounts, the U.S. told a federal court in arguing against the "myriad" of arguments she has made to dismiss the case.

  • April 24, 2025

    Silicon Valley Bank Liquidators Fight $41M Bill In Tax Court

    The trust responsible for liquidating assets of the shuttered Silicon Valley Bank told the U.S. Tax Court that the IRS has wrongly charged the bank's operator more than $41 million in additional taxes by claiming it didn't substantiate losses and research activities in the years leading up to its bankruptcy.

Expert Analysis

  • How To Accelerate Your Post-Attorney Career Transition

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    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

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    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

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    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

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    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.

  • Adapting To Private Practice: From DOJ Leadership To BigLaw

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    The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.

  • How The CRE Industry Is Adapting To Tariff Uncertainty

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    Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.

  • Law Firm Executive Orders Create A Legal Ethics Minefield

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    Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.

  • Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike

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    The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.

  • Firms Must Embrace Alternative Billing Models Or Fall Behind

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    As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.

  • How Attorneys Can Master The Art Of On-Camera Presence

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    As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.

  • Adapting To Private Practice: From Fed. Prosecutor To BigLaw

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    Making the jump from government to private practice is no small feat, but, based on my experience transitioning to a business-driven environment after 15 years as an assistant U.S. attorney, it can be incredibly rewarding and help you become a more versatile lawyer, says Michael Beckwith at Dickinson Wright.

  • Justices' False Statement Ruling Curbs Half-Truth Liability

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    The U.S. Supreme Court’s recent Thompson v. U.S. decision clarified that a federal statute used to prosecute false statements made to bank regulators only criminalizes outright falsehoods, narrowing prosecutors’ reach and providing defense counsel a stronger basis to challenge indictments of merely misleading statements, says Tamara de Silva at De Silva Law Offices.

  • Perfecting Security Interests In Renewable Energy Tax Credits

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    The ability to transfer renewable energy tax credits has created new opportunities for developers, investors and lenders, but it also raises important questions regarding when and how the security interests in these credits are perfected — questions that must be answered definitively to protect credit claims and transactions, says Harry Teichman at Stinson.

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