Federal

  • December 23, 2025

    SEC, FAT Brands Near Deal In Suit On CEO's $27M Loan Scam

    Restaurant franchiser FAT Brands, its former CEO and other executives told a California federal judge on Tuesday that they reached a deal to resolve the U.S. Securities and Exchange Commission's civil claims that they ran an illegal $27 million personal-loan scheme to fuel the former CEO's lavish lifestyle as the public company floundered.

  • December 23, 2025

    Tax Court Denies Couple's Child Tax Credit For Nephew

    A couple who jointly filed as a married couple in 2020 cannot claim the child tax credit for a minor whom they describe as their nephew from Mexico who came to live with them that year, a U.S. Tax Court judge ruled Tuesday.

  • December 23, 2025

    Top International Trade Developments Of 2025

    Importers faced novel levels of uncertainty in 2025 as President Donald Trump introduced several new tariff actions during his second term, including some that prompted importers to challenge a law used to authorize duties that had never been used before. Here, Law360 examines the year's top international trade developments.

  • December 23, 2025

    Top Federal Tax Decisions Of 2025

    Over the past year, federal courts have issued decisions that extended the deadline for challenging tax bills in the U.S. Tax Court, allowed the IRS to pursue a woman's decades-old tax debt caused by her return preparer and lifted a $1 million reporting penalty because a jury didn't sign off. Here, Law360 reviews some of the most significant federal tax decisions of 2025.

  • December 23, 2025

    Top International Tax Cases Of 2025

    Government tax administrations came up short in some of the biggest international cases decided this year, including Denmark's challenge to a British trader it accused of deceiving the tax authority into paying thousands of improper refunds. Here, Law360 examines seven of the year's top international tax cases.

  • December 23, 2025

    IRS Issues Updates To Healthcare Premium Tax Credit

    The IRS released updates Tuesday to the refundable premium tax credit that allows individuals to purchase health insurance from the federal government's marketplace, including the removal of a repayment cap on excess credits that were established in the Republican 2025 budget law.

  • December 23, 2025

    IRS Issues FAQs For Interest Expense Deduction Limits

    The Internal Revenue Service issued answers Tuesday to a set of frequently asked questions related to interest expense deduction calculations that were changed under the budget reconciliation law.

  • December 23, 2025

    11th Circ. Rejects Woman's Legal Fees In Tax Case Win

    A Florida woman cannot recoup around $6,000 in attorney fees as part of her win in a U.S. Tax Court deficiency action despite paying her husband's legal practice to help with the case, the Eleventh Circuit found, affirming the Tax Court's ruling.

  • December 22, 2025

    10th Circ. Tosses Plumbing Co.'s Captive Deduction Bid

    The Tenth Circuit is not the proper forum for a Utah plumbing company to challenge the Internal Revenue Service's 2016 notice denying a microcaptive insurance deduction, the appeals court found Monday, citing two statutes that bar the company's arguments.

  • December 22, 2025

    6th Circ. Vacates Pharma Salesman's $6.8M Restitution Order

    The Sixth Circuit vacated a nearly $7 million restitution order against a pharmaceutical salesman convicted of healthcare fraud, finding an Ohio federal court erred in calculating that amount and apportioning liability.

  • December 22, 2025

    Draft House Bill Would Clarify Tax Rules For Digital Assets

    A bipartisan draft bill in the U.S. House would modernize the federal tax code for digital assets, its backers said, by establishing a "commonsense tax treatment" for regulated payment stablecoins, clarifying source-of-income rules for trading and extending existing securities-lending rules to digital assets.

  • December 22, 2025

    IRS To Issue Guidance For Dyed Fuel Tax Refunds

    The IRS announced plans Monday to issue guidance for a provision under the federal budget bill regarding a tax refund process for dyed fuel.

  • December 22, 2025

    Top Federal Tax Policies Of 2025

    The first year of President Donald Trump's second term brought the passage of this summer's budget reconciliation bill, which renewed major parts of the 2017 Tax Cuts and Jobs Act, and major staffing changes at the Internal Revenue Service. Here, Law360 looks at the most consequential developments in federal tax policy in 2025.

  • December 22, 2025

    Britney Spears Disputes $720K IRS Bill In Tax Court

    Britney Spears is challenging the IRS over the more than $720,000 it assessed against her in 2021, telling the U.S. Tax Court that the agency improperly increased income she received through her pass-through entity.

  • December 22, 2025

    Tariff Refunds Would Be 'A Mess,' Economic Official Says

    It would be an "administrative problem" to issue tariff refunds in the aftermath of a potential U.S. Supreme Court ruling against the White House's trade measures, a top economic policy official said.

  • December 22, 2025

    IRS Seeks Input On Updates To Voluntary Disclosure Process

    The Internal Revenue Service asked Monday for comments on a proposed change to its voluntary disclosure program that would require payment of all taxes, penalties and interest within three months after being conditionally approved for the program.

  • December 22, 2025

    Farmers Can Pay Capital Gains Tax In Installments, IRS Says

    Farmers who will pay capital gains tax on a farmland property sale to another farmer can opt to make the payments in four equal installments instead of a lump sum under guidance the IRS released Monday, implementing relief created by the 2025 budget law.

  • December 19, 2025

    Gunderson-Led Tax Firm Andersen Trades Up After Rare IPO

    Tax valuation and advisory firm Andersen Group Inc. has closed a $202 million initial public offering, marking a rare IPO that required legal teams to navigate uncommon structural and governance challenges, according to attorneys who steered the offering.

  • December 19, 2025

    Conn. Investment Adviser Admits To Tax Evasion

    A Connecticut man pled guilty to tax evasion after using $5.2 million of his private equity fund's money to pay personal expenses and causing a criminal tax loss of nearly $2.2 million, federal prosecutors said.

  • December 19, 2025

    IRS Extends Transition For States' Paid Family Leave Changes

    States with paid family and medical leave programs have another year to transition to changes to the income and employment tax treatment of contributions paid in certain situations to support those benefits, the IRS said Friday, adopting stakeholders' recommendation for more time to comply.

  • December 19, 2025

    IRS Relaxes Carbon Capture Credit's Environmental Reporting

    The Internal Revenue Service released guidance Friday easing the carbon capture tax credit's environmental reporting requirements, taking effect by the end of the year, for energy systems that permanently secure the emissions in geological locations, such as deep underground rock formations.

  • December 19, 2025

    Taxation With Representation: Baker Botts, Morgan Lewis

    In this week's Taxation With Representation, Trump Media and Technology Group merges with fusion power company TAE Technologies, pharmaceutical company Cencora boosts its stake in cancer care company OneOncology, and Phoenix Financial partners with private equity giant Blackstone to plug billions into various credit strategies.

  • December 19, 2025

    Calif. Ex-Customs Broker Sentenced For Tax, Wire Fraud

    A California man was sentenced to 51 months in federal prison after being indicted this year on federal fraud charges and one count of tax evasion, the U.S. Department of Justice said.

  • December 19, 2025

    Polsinelli Lands Glaser Weil Tax Pro In Los Angeles

    Polsinelli PC is expanding its business team, bringing in a tax pro from Glaser Weil as a shareholder in its Los Angeles office.

  • December 18, 2025

    IRS Guidance Discriminates Against Wind, Solar, Groups Say

    Several groups, including the Natural Resources Defense Council and the city of San Francisco, asked a D.C. federal court Thursday to block the Internal Revenue Service from instituting new tax credit rules that they say illegally discriminate against wind and solar projects.

Expert Analysis

  • Despite Dark Clouds, Outlook For US Solar Has Bright Spots

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    While tariff, tax policy and bankruptcy news seemingly portends unending challenges for the U.S. solar energy industry, signs of continued growth in solar generating capacity and domestic solar manufacturing suggest that there is a path forward, say attorneys at Beveridge & Diamond.

  • Law School's Missed Lessons: Communicating With Clients

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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.

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