Federal
-
November 14, 2025
Liquidated Captive Insurer Fights IRS Bill In Tax Court
A captive insurance company that was later dissolved challenged $800,000 in taxes and penalties in the U.S. Tax Court, saying the Internal Revenue Service wrongly claimed the company had $3 million in unreported long-term capital gains.
-
November 14, 2025
US Expatriations Rise To 1,600 In 3rd Quarter, IRS Says
The number of people who lost or renounced their U.S. citizenship totaled 1,600 in the third quarter as logged by the U.S. Treasury Department, a 50% increase from the previous quarter, the IRS said Friday.
-
November 14, 2025
Ala. Partnerships Say IRS Erred Rejecting Easement Breaks
The Internal Revenue Service unlawfully denied a pair of Alabama partnerships' $40 million charitable tax deduction on a conservation easement they donated in 2020, the partnerships told the U.S. Tax Court, arguing the agency offered no sufficient explanation for its determination.
-
November 14, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service released its weekly internal revenue bulletin Friday, which included guidance for group health plans and health insurers to calculate out-of-network healthcare coverage for 2026.
-
November 13, 2025
Eaton Witnesses Probed About Data Used For Credit Analysis
An accounting expert and a former Eaton Corp. official both advised the U.S. Tax Court on Thursday about the data used to establish the financial position of the U.S. company after its acquisition of Irish-based Cooper Industries in 2012.
-
November 13, 2025
Clean Energy Cos. Tap Private Cash To Beat Tax Credit Clock
Clean energy developers are increasingly looking to privately held investors to ensure they can do enough work to keep their projects fully eligible for tax credits that start phasing out next year, energy development attorneys told Law360.
-
November 13, 2025
Latin American Trade Deals With US Include Zero Tariff Rates
Latin American countries including El Salvador, Guatemala, Ecuador and Argentina committed to nontariff reductions for U.S. producers in exchange for a zero tariff rate on many imports not readily available in the U.S., under details of framework trade agreements the White House unveiled Thursday.
-
November 13, 2025
Tax Court Lets Oil Co. Split Losses In $72M Carryback Dispute
An oil and gas company was allowed to give up the normal carryback period for its net operating losses without waiving the 10-year period for $72 million in specified liability losses, a divided U.S. Tax Court ruled Thursday, with two judges saying the rules aren't so flexible.
-
November 13, 2025
Tax Court Upholds Levy Action For $186K Deficiency In Ala.
The U.S. Tax Court affirmed an Internal Revenue Service decision to collect an Alabama couple's $186,000 tax debt, ruling Thursday that despite sympathy for the wife's severe medical condition, the husband had failed to participate in proceedings to make his case.
-
November 13, 2025
High Court's Tariff Ruling May Trigger Refunds, Reimposition
Importers are being advised to prepare for potential refunds in the event the U.S. Supreme Court rules President Donald Trump's emergency tariffs are unlawful, leaving questions about how a refund process might play out and whether the duties would be reimposed.
-
November 13, 2025
Tax Court Denies Couple's EITC Claim Over Lack Of Proof
An Alabama couple who claimed a $3,600 earned income tax credit did not prove that they are entitled to it, the U.S. Tax Court said Thursday, ruling that the pair are not eligible to claim the credit for the wife's sister.
-
November 13, 2025
MVP: Kirkland's Adam Kool
Adam Kool, a tax partner at Kirkland & Ellis LLP, spent the past year advising on high-profile, industry-transforming transactions. Kool's work on AbbVie's $63 billion acquisition of the pharmaceutical giant Allergan, GTCR's pending $24.25 billion sale of global payment processing company Worldpay and other billion-dollar transactions has earned him a spot as one of the 2025 Law360 Tax MVPs.
-
November 13, 2025
Trump Org. Pushes DC Circ. To Back IRS Leaker's Sentence
President Donald Trump's private business organization said it opposes any reduction to the five-year prison sentence of the former IRS contractor who leaked Trump's tax returns and thousands of others, telling the D.C. Circuit the leaker has been shown enough leniency.
-
November 13, 2025
Tax Interest Rates To Hold Steady In 1st Quarter
The Internal Revenue Service's interest rates for overpayments and underpayments of tax will remain the same for the calendar quarter beginning Jan. 1, the agency said Thursday.
-
November 13, 2025
IRS Increases Retirement Fund Contribution Limits
The Internal Revenue Service on Thursday announced the increased limit for contributions to various retirement accounts, including upping the 401(k) limit to $24,500.
-
November 13, 2025
In-House Tax Controversy Director Joins Miller & Chevalier
The former director of tax controversy at Cleveland, Ohio-based real estate company GBX Group LLC has moved to Miller & Chevalier Chtd.'s Washington, D.C., office, where she'll continue working on a range of tax-related matters.
-
November 12, 2025
Ports Warn USTR Against China Ship Fees, Crane Tariffs
The U.S. Trade Representative should reconsider tariffs on Chinese cranes and fees on Chinese and other foreign ships while those measures are suspended for the next year as part of a trade truce between China and the U.S., according to comments recently submitted by a U.S. port industry association.
-
November 12, 2025
Doctor Owes Penalties Over Microcaptives, Tax Court Affirms
The U.S. Tax Court on Wednesday affirmed economic substance and accuracy-related penalties pinned on an eye doctor and his wife over their microcaptive insurance arrangement.
-
November 12, 2025
FERC Can't Order Refund Of Extra Tax Costs, DC Circ. Told
The Federal Energy Regulatory Commission requiring an Energy Transfer LP unit to refund customers extra costs tacked onto its rates for deferred federal income tax reasons was unlawful retroactive ratemaking, the subsidiary told the D.C. Circuit, urging a reversal of the commission's order.
-
November 12, 2025
MVP: Eversheds Sutherland's Maria Todorova
Eversheds Sutherland's Maria Todorova secured a pivotal win for Duke Energy by successfully arguing that South Carolina's investment tax credit statute allowed the company to claim $20 million for qualifying investments, earning her a spot as one of the 2025 Law360 Tax MVPs.
-
November 12, 2025
DOJ Fights Claim That IRS Unlawfully Shared Info With ICE
The Trump administration has said the IRS complied with regulations when considering information requests from immigration enforcement officials, urging a D.C. federal judge to deny advocacy groups' request to submit a supplemental filing asserting that documents it turned over show otherwise.
-
November 12, 2025
DC Circ. Affirms Toss Of Tax Tipster's Award Challenge
The U.S. Tax Court correctly dismissed a man's claim to a whistleblower award for tips he gave the IRS about businesses he alleged had skipped employment taxes, the D.C. Circuit ruled Wednesday, saying the IRS didn't take any action against the taxpayers.
-
November 12, 2025
8th Circ. Denies Medtronic's Bid To Rethink Pricing Ruling
The Eighth Circuit denied healthcare tech company Medtronic's request to reconsider the court's approach for pricing a licensing agreement with a Puerto Rican affiliate, leaving in place Wednesday a ruling that directed the U.S. Tax Court to give the Internal Revenue Service's method another look.
-
November 12, 2025
6th Circ. Asked To Rethink Tax Court Filing Deadline Ruling
The Sixth Circuit should rethink its decision that the 90-day deadline to file a U.S. Tax Court petition is flexible and can be extended sometimes, the U.S. argued, saying the ruling widens a circuit split on an issue critical to tax administration.
-
November 10, 2025
Law360 MVP Awards Go To Top Attorneys From 76 Firms
The attorneys chosen as Law360's 2025 MVPs have distinguished themselves from their peers by securing significant achievements in high-stakes litigation, complex global matters and record-breaking deals.
Expert Analysis
-
Making The Case For Rest In The Legal Profession
For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.
-
Mitigating Tariff Risks For Healthcare In US And Canada
Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.
-
4 Ways Women Attorneys Can Build A Legal Legacy
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
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
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
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
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
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
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
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
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
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
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.