Federal

  • May 09, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included the reference price for enhanced oil recovery tax credits for calendar year 2024.

  • May 09, 2025

    Justice Souter Was An Unexpected Force Of Moderation

    Justice David Souter, who saw the high court as a moderating force apart from the messiness of politics, subverted the expectations of liberals and conservatives alike during his 19 years on the bench.

  • May 09, 2025

    Taxation With Representation: Paul Weiss, Weil, V&E, Torys

    In this week's Taxation With Representation, 3G Capital takes Skechers private, Sunoco LP buys Parkland Corp., and BCE Inc. and the Public Sector Pension Investment Board launch a wholesale network provider called Network FiberCo.

  • May 09, 2025

    Retired Supreme Court Justice David Souter Dies At 85

    Retired Justice David H. Souter, who served on the U.S. Supreme Court from 1990 to 2009, has died at 85, the court announced Friday. 

  • May 08, 2025

    Trump Admin Defends Gov't Restructuring As Lawful

    The Trump administration defended what it says is a lawful executive order looking to reorganize agencies and terminate workers, telling a California federal judge that unions, nonprofits and local governments "waited far too long" to seek a temporary restraining order.

  • May 08, 2025

    Hyatt's $300M From Reward Program Is Income, 7th Circ. Told

    Hyatt Hotels should have to report nearly $300 million in revenue from a rewards program fund because it benefited from spending the money, including through advertising for its properties, the U.S. government told the Seventh Circuit on Thursday, defending a U.S. Tax Court ruling.

  • May 08, 2025

    NFTC Warns US Against Tariffs On Semiconductors, Pharma

    The Trump administration should work to avoid using tariffs to address the perceived threat to national security caused by importing semiconductors and pharmaceuticals, the National Foreign Trade Council said, calling for extreme caution.

  • May 08, 2025

    Widow Says Husband's Estate Liable For $2M FBAR Fines

    A nonagenarian widow told an Idaho federal court Thursday that her husband's estate — not she — should be liable for more than $2 million in penalties for his unreported foreign accounts, calling the government's attempt to penalize her an unprecedented overreach.

  • May 08, 2025

    11th Circ. Judge Frowns On New Arguments In Easement Case

    An Eleventh Circuit judge disapproved of a Georgia partnership raising new arguments on appeal as it pursues a tax deduction for a conservation easement donation, saying Thursday that perhaps "we wouldn't be here" if the partnership had argued the points before the lower court.

  • May 08, 2025

    Milbank Hires King & Spalding Tax Planning Atty In DC

    Milbank LLP has added a former King & Spalding LLP tax attorney as a partner in its global project, energy and infrastructure finance group in Washington, D.C.

  • May 07, 2025

    Bessent Defends Cuts To Community Fund Amid Scrutiny

    U.S. Treasury Secretary Scott Bessent on Wednesday defended the Trump administration's proposal to significantly slash the fund that operates the new markets tax credit, which is meant to boost investment in poor communities, telling lawmakers that a new $100 million program would better support affordable financing in rural areas.

  • May 07, 2025

    Favorable Tax Cut Baseline Won't Fool Lenders, House Told

    If Congress uses a current policy baseline to permanently extend the 2017 tax overhaul's provisions, it will be a red flag to institutional investors, such as hedge funds, mutual funds and endowments, panelists told the House Budget Committee on Wednesday.

  • May 07, 2025

    Tax Court Rejects Couple's Case For Lacking Evidence

    A couple who challenged what the Internal Revenue Service said was their more than $650,000 in tax debt provided no evidence that the number was wrong, the U.S. Tax Court said in a bench opinion released Wednesday.

  • May 07, 2025

    11th Circ. Backs Frivolous Argument Ruling Against Teacher

    A Georgia high school teacher who claimed that he didn't have to pay taxes on his salary and that income taxes are unconstitutional must pay $25,000 in court sanctions under an Eleventh Circuit ruling affirming a U.S. Tax Court decision.

  • May 07, 2025

    Don't Scrap US-China Tax Treaty, Biz Groups Tell Treasury

    Business lobbying groups have urged the U.S. Treasury Department to reject the White House's plans to scrutinize the U.S.-China tax treaty, warning that scrapping the accord would lead to higher Chinese taxes on U.S. companies.

  • May 07, 2025

    Feds Seek 13 Years In Avenatti's California Resentencing

    California federal prosecutors asked a judge Wednesday to sentence Michael Avenatti to 160 months in prison for tax fraud and stealing from clients, to be served atop the five-year term imposed in a pair of New York cases where Avenatti was convicted of trying to extort Nike Inc. and defrauding former client Stormy Daniels.

  • May 07, 2025

    6th Circ. Skeptical Of US In Tax Court Deadline Case

    Sixth Circuit judges expressed skepticism of the U.S. government's claim that the 90-day deadline to petition the U.S. Tax Court is inflexible, with one judge saying during oral arguments Wednesday in a woman's case challenging the rule that the U.S. Supreme Court seemed to back her.

  • May 07, 2025

    Device Seller Asks For Probation In $2.4M Tax Evasion Case

    The septuagenarian owner of a Florida medical device company who pled guilty to evading $2.4 million in taxes asked a federal district court Wednesday for his sentence to entail home probation and not prison, given his health challenges and payments he already made to the Internal Revenue Service.

  • May 07, 2025

    IRS To Open Applications For Low-Income Tax Clinic Grants

    The Internal Revenue Service will begin accepting applications May 15 for its grant program for organizations providing tax services to low-income people or people who speak English as a second language, it announced Wednesday.

  • May 06, 2025

    Fed. Circ. Agrees Plane Taxability Patent Doesn't Fly

    The Federal Circuit on Tuesday refused to revive an Ohio company's patent that covers using Federal Aviation Administration data to determine "the taxability status of aircraft," agreeing that it covered subject matter that isn't patentable.

  • May 06, 2025

    Tax Court Erred In Slashing $23M Easement, 11th Circ. Told

    A partnership told the Eleventh Circuit that the U.S. Tax Court erred in substantially reducing its claim to a $23 million conservation easement tax deduction, arguing the decision was tainted by error-riddled criteria used by the IRS to value the property.

  • May 06, 2025

    Military Moving-Cost Deduction Nixed For Civilian Contractor

    A civilian contractor for the U.S. Air Force cannot deduct her moving expenses because she is not considered a member of the military for purposes of the deduction, the U.S. Tax Court said in a bench opinion released Tuesday.

  • May 06, 2025

    Actor Voight, Film Biz Adviser To Trump, Floats Tax Incentives

    Actor Jon Voight, whom President Donald Trump tapped as an adviser on the Hollywood film industry, told Trump that tax incentives, international treaties and limited tariffs could revitalize production, while California Gov. Gavin Newsom separately floated a $7.5 billion federal film tax credit, according to statements shared Tuesday with Law360.

  • May 06, 2025

    Stationery Co. Fights Bid To Move Tariff Case To Trade Court

    The U.S. Court of International Trade does not have exclusive jurisdiction to hear disputes over President Donald Trump's global tariffs, a stationery company told a Florida federal court Monday in opposing the administration's bid to transfer to the suit.

  • May 06, 2025

    IRS Narrows Benefit Plan Sponsors Subject To New Rules

    The Internal Revenue Service on Tuesday narrowed the group of defined benefit plan sponsors that will be subject to certain requirements related to agency approval to use mortality tables that start in January.

Expert Analysis

  • Planning Law Firm Content Calendars: What, When, Where

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    During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.

  • Brownfield Questions Surround IRS Tax Credit Bonus

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    Though the IRS has published guidance regarding the Inflation Reduction Act's 10% adder for tax credits generated by renewable energy projects constructed on brownfield sites, considerable guesswork remains as potential implications seem contrary to IRS intentions, say Megan Caldwell and Jon Micah Goeller at Husch Blackwell.

  • Law Firms Should Move From Reactive To Proactive Marketing

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    Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.

  • The Big Issues A BigLaw Associates' Union Could Address

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    A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.

  • It's Time For A BigLaw Associates' Union

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    As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.

  • Why DOJ's Whistleblower Program May Have Limited Impact

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    The U.S. Department of Justice’s new whistleblower pilot program aims to incentivize individuals to report corporate misconduct, but the program's effectiveness may be undercut by its differences from other federal agencies’ whistleblower programs and its interplay with other DOJ policies, say attorneys at Milbank.

  • How Justices Upended The Administrative Procedure Act

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    In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.

  • Trump's Best Hush Money Appeal Options Still Likely To Fail

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    The two strongest potential arguments former President Donald Trump could raise in appealing his New York hush money conviction seem promising at first, but precedent strongly suggests they will still ultimately fail — though, of course, Trump's unique position could lead to surprising results, says former New York Supreme Court Justice Ethan Greenberg, now at Anderson Kill.

  • Tips For Tax Equity-Tax Credit Transfers That Pass IRS Muster

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    Although the Internal Revenue Service has increased its scrutiny of complex partnership structures, which must demonstrate their economic substance and business purpose, recent cases and IRS guidance together provide a reliable road map for creating legitimate tax equity structures, say Ian Boccaccio and Michael Messina at Ryan Tax.

  • Mirror, Mirror On The Wall, Is My Counterclaim Bound To Fall?

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    A Pennsylvania federal court’s recent dismissal of the defendants’ counterclaims in Morgan v. Noss should remind attorneys to avoid the temptation to repackage a claim’s facts and law into a mirror-image counterclaim, as this approach will often result in a waste of time and resources, says Matthew Selmasska at Kaufman Dolowich.

  • 3 Leadership Practices For A More Supportive Firm Culture

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    Traditional leadership styles frequently amplify the inherent pressures of legal work, but a few simple, time-neutral strategies can strengthen the skills and confidence of employees and foster a more collaborative culture, while supporting individual growth and contribution to organizational goals, says Benjamin Grimes at BKG Leadership.

  • E-Discovery Quarterly: Rulings On Hyperlinked Documents

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    Recent rulings show that counsel should engage in early discussions with clients regarding the potential of hyperlinked documents in electronically stored information, which will allow for more deliberate negotiation of any agreements regarding the scope of discovery, say attorneys at Sidley.

  • Loper Bright Limits Federal Agencies' Ability To Alter Course

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    The U.S. Supreme Court's recent decision to dismantle Chevron deference also effectively overrules its 2005 decision in National Cable & Telecommunications Association v. Brand X, greatly diminishing agencies' ability to change regulatory course from one administration to the next, says Steven Gordon at Holland & Knight.

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