Federal
-
June 06, 2025
Taxation With Representation: Winston, Stibbe, Weil, Goodwin
In this week's Taxation With Representation, Chart Industries Inc. and Flowserve Corp. merge, Aedifica NV and Cofinimmo NV unite, Sanofi buys Blueprint Medicines Corp., and Kimberly-Clark Corp. sells a majority stake in its international tissue business to Suzano.
-
June 06, 2025
Lobbyist Seeks No Prison After Admitting $1.3M Tax Evasion
A Miami lobbyist who admitted to evading $1.3 million in taxes asked a Florida federal court not to sentence him to prison, saying he reported his tax obligations in full, even for the years when he didn't pay, and was overwhelmed by family expenses.
-
June 06, 2025
PE Firms Are Top Opportunity Zone Investors, Report Finds
A group tracking private equity activity said each of the 15 largest investors in the federal opportunity zone program are private equity firms, with Salt Lake City, Utah-based Bridge Investment Holdings topping the list with $3.7 billion in opportunity zone funds.
-
June 05, 2025
'Sparse' OPM Record On Mass Firings Backs Win, Unions Say
A "sparse and self-serving" record provided by the U.S. Office of Personnel Management still shows the agency unlawfully directed federal agencies to fire probationary employees en masse, so a California federal court can reach a final decision now and "unwind" those terminations, a coalition including unions and advocacy groups said Thursday.
-
June 05, 2025
Texas Plastics Co. Challenges IRS Over Microcaptive Rules
A Texas plastics company sued the IRS over regulations flagging microcaptive insurance plans as potentially abusive tax avoidance schemes, telling a Texas federal court that the agency exceeded its authority by imposing broad disclosure requirements that could penalize even legitimate arrangements.
-
June 05, 2025
Ex-Atty Says IRS Suit Over Property Sale Tactic Is Retaliatory
A former attorney has asked an Idaho federal court to toss the government's suit accusing him and his company of promoting an abusive tax scheme, arguing that the underlying property sale transactions were above board but the government targeted him as punishment for suing the IRS and to gain backdoor access into confidential business records.
-
June 05, 2025
Tax Court Upholds IRS' Proposed Tax Levy Against Neb. Man
The Internal Revenue Service did not abuse its discretion when sustaining a proposed levy against a Nebraska man aimed at collecting unpaid assessments for the 2006 and 2007 tax years, the U.S. Tax Court said Thursday, supporting the agency's determination.
-
June 05, 2025
'Longtime Tax Protester' Must Pay On $226K In Income
A Texas man characterized by the U.S. Tax Court as a "longtime tax protester" was incorrect when he claimed his more than $226,000 in wages and retirement distributions aren't taxable, a judge ruled Thursday, also hitting him with a penalty.
-
June 05, 2025
Trump Expects China Trade Talks To Resume After Xi Phone Call
President Donald Trump said he and Chinese President Xi Jinping spoke over the phone Thursday about an impasse in ongoing trade talks over U.S. claims China was slow-walking the exports of rare earths, with Trump saying he expects meetings between the countries' negotiating teams to resume.
-
June 05, 2025
9th Circ. Backs Denial Of Biz Owner's Bad Debt Deduction
A businessman cannot take a worthless debt deduction for millions of dollars he transferred between his companies and said were loans, the Ninth Circuit said Thursday, affirming a U.S. Tax Court ruling that he owed more than $5 million in taxes.
-
June 05, 2025
'Survivor' Winner Ordered To Pay $3.3M Tax Bill
The first winner of reality competition show "Survivor" must pay his $3.3 million tax bill, but the government is not allowed to enforce tax liens by forcing the sale of two properties, a Rhode Island federal court ruled Thursday.
-
June 05, 2025
KFC Parent Co. Fights $4B IRS Bill In Tax Court
The parent company of Pizza Hut, KFC and Taco Bell is challenging $2.5 billion in taxes and penalties that the IRS claims it owes for a corporate reorganization to restructure its international operations, according to a U.S. Tax Court petition served Thursday, a figure that has topped $4 billion with interest.
-
June 05, 2025
Justices Fault Wis. For Denying Tax Break To Charities
Wisconsin discriminated against a group of Catholic charities when it denied them an unemployment tax exemption, the U.S. Supreme Court said Thursday, rejecting the state's argument that the charities were not operated primarily for religious purposes.
-
June 04, 2025
Cheesesteak Icon Asks 3rd Circ. If Loper Bright Slices Sentence
Counsel for a Philadelphia cheesesteak shop owner seeking a lighter sentence for paying employees off the books told the court Wednesday that he has asked the Third Circuit to consider how the U.S. Supreme Court's landmark decision striking longstanding agency deference framework might affect his case.
-
June 04, 2025
NJ Man Cops To Dodging $2M Tax Bill On Real Estate
A New Jersey man linked to an intricate pension plan scheme involving refunds from the Dutch government pled guilty to evading more than $2.4 million in U.S. taxes by concealing ownership of more than $5.5 million in real estate, the U.S. Department of Justice said Wednesday.
-
June 04, 2025
Trump Ordered To Explain Why Layoffs Don't Flout Injunction
A California federal judge ordered the Trump administration Wednesday to explain why preparations for layoffs at the State Department and Department of Housing and Urban Development do not violate an injunction she issued last month, saying she needed more details about the agencies' plans to evaluate their compliance.
-
June 04, 2025
Biz Groups Urge US To Pressure Canada To Drop Digital Tax
A coalition of business lobbying groups have urged the U.S. government to take "decisive action" against Canada's digital services tax before the June 30 payment deadline, contending that the levy will cost U.S. companies about $2 billion this year.
-
June 04, 2025
Senate May Clash With House On SALT Cap, Energy Credits
Senate Republicans are working to finalize the chamber's version of the House's nearly $4 trillion tax bill, and the Senate's bill is likely to conflict with the House's over proposed changes to the state and local tax deduction and green energy credits.
-
June 04, 2025
Tax Court Rejects Frivolous Wage Classification Argument
A woman's wages from her job at Fidelity Investments should have been reported as income on her and her husband's joint tax return, the U.S. Tax Court affirmed Wednesday, upholding the IRS' deficiency finding and also hit the couple with a penalty.
-
June 04, 2025
Mother-Son Car Co. Owners Owe Penalties, Tax Court Says
A mother and son who owned a used car business owe tax penalties for failing to report corporate dividends, the U.S. Tax Court ruled Wednesday, saying the pair couldn't back up their claim that the state of California had seized the records they needed to defend themselves.
-
June 04, 2025
Satellite Co. Execs Released In $250M Fraud, Evasion Case
Two more satellite company executives facing charges of tricking investors out of $250 million are being released after their leader, who was additionally accused of tax crimes, was deemed a flight risk, according to D.C. federal court documents.
-
June 04, 2025
Loeb & Loeb Trusts And Estates Head Jumps To Proskauer
Proskauer Rose LLP has hired the former chair of Loeb & Loeb LLP's international trusts and estates practice group to represent ultra-high-net-worth individuals and families.
-
June 03, 2025
DC Circ. Rejects Tipster's Bid To Reverse IRS Award Denial
The D.C. Circuit refused to reinstate a tipster's petition for a whistleblower award before the U.S. Tax Court claiming his former employer intentionally misclassified him as an independent contractor, ruling Tuesday the Tax Court lacked jurisdiction since he failed to show the agency acted on his tip.
-
June 03, 2025
NY Family Partnership Fights $4.5M Income Shift In Tax Court
A New York family partnership challenged an Internal Revenue Service determination that it formed mainly to reduce the tax liability of one of its limited partners, telling the U.S. Tax Court that the agency wrongly shifted $4.5 million in income taxable to him.
-
June 03, 2025
WTO Useful For China Enforcement, US Trade Nominee Says
The U.S. should work with partners at the World Trade Organization to apply further trade pressure on China, making sure the country is complying with rules and trading fairly, a Skadden partner nominated by President Donald Trump to represent the U.S. at the WTO told lawmakers Tuesday.
Expert Analysis
-
Corp. Transparency Act's Future Under Treasury's Bessent
The Corporate Transparency Act’s ultimate fate faced uncertain terms at the end of 2024, but new U.S. Department of the Treasury Secretary Scott Bessent's statements and actions so far demonstrate that he does not intend to ignore the law, though he may attempt to make modifications, say attorneys at Taylor English.
-
A Look At A Possible Corporate Transparency Act Exemption
Attorneys at Kirkland offer a deep dive into the application of the Corporate Transparency Act's reporting requirements specifically to U.S.-domiciled co-issuers in typical collateralized loan obligation transactions, and consider whether such issuers may be able to assert an exemption from the CTA's reporting requirements.
-
Inconsistent Injury-In-Fact Rules Hinder Federal Practice
A recent Third Circuit decision, contradicting a previous ruling about whether consumers of contaminated products have suffered an injury in fact, illustrates the deep confusion this U.S. Supreme Court standard creates among federal judges and practitioners, who deserve a simpler method of determining which cases have federal standing, says Eric Dwoskin at Dwoskin Wasdin.
-
In-House Counsel Pointers For Preserving Atty-Client Privilege
Several recent rulings illustrate the challenges in-house counsel can face when attempting to preserve attorney-client privilege, but a few best practices can help safeguard communications and effectively assert the privilege in an increasingly scrutinized corporate environment, says Daniel Garrie at Law & Forensics.
-
Emerging Energy Trends Reflect Shifting Political Landscape
As the Trump administration settles in, some emerging energy industry trends, like expanded support for fossil fuel production, are right off of its wish list — while others, like the popularity of Inflation Reduction Act energy tax credits, and bipartisan support for carbon capture, reflect more complex political realities, say attorneys at Greenberg Traurig.
-
Tax-Free Ways To Help Employees After The LA Wildfires
Following the recent wildfires in Los Angeles, there are various tax-free ways to give employees the resources and flexibility they need, including simpler methods like disaster relief payments under Internal Revenue Code Section 139 and leave-sharing programs, and others that require more planning, says Ligeia Donis at Baker McKenzie.
-
Judge Should Not Have Been Reprimanded For Alito Essay
Senior U.S. District Judge Michael Ponsor's New York Times essay critiquing Supreme Court Justice Samuel Alito for potential ethical violations absolutely cannot be construed as conduct prejudicial to the administration of the business of the courts, says Ashley London at the Thomas R. Kline School of Law of Duquesne University.
-
Lights, Camera, Ethics? TV Lawyers Tend To Set Bad Example
Though fictional movies and television shows portraying lawyers are fun to watch, Hollywood’s inaccurate depictions of legal ethics can desensitize attorneys to ethics violations and lead real-life clients to believe that good lawyers take a scorched-earth approach, says Nancy Rapoport at the University of Nevada, Las Vegas.
-
Accountant-Owned Law Firms Could Blur Ethical Lines
KPMG’s recent application to open a legal practice in Arizona represents the first overture by an accounting firm to take advantage of the state’s relaxed law firm ownership rules, but enforcing and supervising the practice of law by nonattorneys could prove particularly challenging, says Seth Laver at Goldberg Segalla.
-
AI Will Soon Transform The E-Discovery Industrial Complex
Todd Itami at Covington discusses how generative artificial intelligence will reshape the current e-discovery paradigm, replacing the blunt instrument of data handling with a laser scalpel of fully integrated enterprise solutions — after first making e-discovery processes technically and legally harder.
-
When Innovation Overwhelms The Rule Of Law
In an era where technology is rapidly evolving and artificial intelligence is seemingly everywhere, it’s worth asking if the law — both substantive precedent and procedural rules — can keep up with the light speed of innovation, says Reuben Guttman at Guttman Buschner.
-
What Compensation Committees Must Keep In Mind In 2025
New disclosure obligations, an evolving discussion on the analysis of executive perks and updated proxy adviser policies — on top of a new presidential administration — are all important things compensation committees must pay close attention to in 2025, say attorneys at Simpson Thacher.
-
Anticipating Direction Of Cosmetics Regulation Under Trump
It is unclear how cosmetics regulation reform from the last few years will fare under President Donald Trump, but the new administration's emphasis on deregulation and Robert F. Kennedy Jr.'s views on product safety provide some insight, say attorneys at Crowell & Moring.