Federal

  • October 10, 2025

    Taxation With Representation: Sullivan, MoFo, Freshfields

    In this week's Taxation With Representation, Fifth Third Bancorp acquires Comerica in an all-stock deal, Qualtrics buys experience analytics firm Press Ganey Forsta, and SoftBank buys ABB's robotics division.

  • October 10, 2025

    Express Scripts Owed Trial In $43M Tax Row, 8th Circ. Told

    Express Scripts is entitled to a trial in its $43 million case seeking a tax refund for producing its own software in the U.S., the company told the Eighth Circuit, saying a lower court wrongly made an early decision that "glossed over" the facts of a complex case.

  • October 10, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included the withdrawal of a pair of proposed regulations for a narrow set of tax-free corporate separation deals known as spinoffs and a multiyear reporting regime for those transactions.

  • October 10, 2025

    Baker Botts Adds 2 Tax Pros From Venable In San Francisco

    Baker Botts LLP is expanding its West Coast transactional team, bringing in a pair of Venable LLP tax attorneys as partners in its San Francisco office.

  • October 09, 2025

    Hospice Co. Can't Get $450K In Deductions, Tax Court Affirms

    A California-based hospice company was correctly denied $450,000 in tax deductions, the U.S. Tax Court decided Thursday, saying most of the tax breaks were not substantiated as required.

  • October 09, 2025

    GOP Sen. Joins Dems On Bill To Nix Trump's Global Tariffs

    Several Senate Democrats and one Republican introduced legislation Thursday to eliminate the national emergency associated with President Donald Trump's so-called reciprocal tariff regime.

  • October 09, 2025

    IRS Sets Inflation-Adjusted Rates For Qualified Biz Income

    The IRS adjusted a bevy of tax provisions for 2026 in response to the passage of this summer's budget reconciliation bill, including the maximum capital gains rate and the qualified business income deduction.

  • October 09, 2025

    Bulgarian Says US Delay On Sanctions Decision Harming Him

    A Bulgarian businessman whose U.S. assets were frozen after the federal government accused him of bribery and tax evasion asked a D.C. federal court to force the U.S. to rule on his administrative challenge to the allegations, saying a delay has hurt his reputation and livelihood.

  • October 08, 2025

    Trump Tariffs Unconstitutional, Watchdog Tells Justices

    Either President Donald Trump doesn't have authority to impose tariffs under the International Emergency Economic Powers Act, or the law is unconstitutional, the nonprofit group Consumer Watchdog told the U.S. Supreme Court Wednesday, urging the justices to affirm lower court rulings deeming those measures unlawful.

  • October 08, 2025

    3rd Time's The Charm? The Tax Court's Odyssey In Medtronic

    A U.S. Tax Court judge has been sent back to the drawing board once again in the long-running transfer pricing litigation brought by Medtronic, raising questions about how much weight the court must give to IRS transfer pricing regulations and how much authority it has to go its own way.

  • October 08, 2025

    Senate Tax Panel Advances IRS Chief Counsel Nomination

    The Senate Finance Committee approved President Donald Trump's nomination of a Sullivan & Cromwell attorney to be general counsel of the Internal Revenue Service, the nearly party-line vote Wednesday setting up the nomination for a vote by the full Senate.

  • October 08, 2025

    Tax Court Upholds Lien Notice Against Health Co.

    The IRS didn't abuse its discretion when it sustained a federal tax lien notice against a health company for unpaid income and employment taxes, the U.S. Tax Court ruled Wednesday, saying the company didn't file documents, including tax returns, needed to challenge the notice.

  • October 08, 2025

    IRS Issued Tax Notices On Time, Tax Court Says

    The Internal Revenue Service issued notices of tax deficiency related to a man's partnership on time, the U.S. Tax Court ruled Wednesday, saying the agency made the notifications within a year of the conclusion of litigation over the affected items.

  • October 08, 2025

    IRS Stops Most Operations Due To Federal Budget Impasse

    The Internal Revenue Service has temporarily halted most of its operations, furloughed workers and ended paid leave for the affected employees as Congress remains deadlocked over federal appropriations legislation to fund the government, the agency's acting human resources officer said Wednesday.

  • October 08, 2025

    Gov't Resists Prison Delay For Lobbyist Who Evaded Tax

    A Miami lobbyist who was sentenced to prison for evading more than $1 million in taxes should not be allowed to delay the start of his term, the U.S. told a Florida federal court, saying the medical injection he argues he should take at home is available in prison.

  • October 08, 2025

    Denver Attorney Returns To Reed Smith State Tax Team

    Reed Smith is expanding its tax practice with the return of an experienced attorney, now based in Denver, with multistate experience in the full spectrum of tax issues.

  • October 07, 2025

    11th Circ. Wary Of IRS Procedure In FBAR Penalty Appeal

    An Eleventh Circuit panel Tuesday appeared concerned about IRS procedures that could keep a man from recouping $419,000 he paid to resolve his failure to disclose funds held in foreign bank accounts as he appeals a district court determination that he actually owes $2.2 million.

  • October 07, 2025

    Goldstein's $968K Border Cash Claim To Be Admitted At Trial

    A Maryland federal jury will hear claims from prosecutors that SCOTUSblog publisher Tom Goldstein told Dulles International Airport border guards that the $968,000 in cash he brought into the country in 2018 had been gambling winnings, after a judge shot down his efforts to suppress his alleged statements Tuesday.

  • October 07, 2025

    Simpson Thacher Atty On Making New REIT Blueprints

    The real estate investment landscape has changed dramatically in recent years, as alternative asset managers — and their counsel — have pioneered ways to tap into new sources of capital. Simpson Thacher partner Benjamin Wells spoke to Law360 about the changes he's seen, how to navigate regulatory shifts, and how real estate investment trusts may continue to reinvent themselves.

  • October 07, 2025

    Ex-Executives' Payroll Tax Convictions Biased, 4th Circ. Told

    Two former software executives asked the Fourth Circuit to reverse their criminal convictions stemming from their failure to pay employment taxes, claiming the jury's instructions were biased.

  • October 07, 2025

    Senate OKs Top Treasury Atty Pick In Slate Of Confirmations

    The Senate approved President Donald Trump's choice of a Sidley Austin LLP partner to be general counsel of the U.S. Department of the Treasury on Tuesday as part of a combined confirmation of 108 nominees to various roles.

  • October 07, 2025

    Approach The Bench: Judge Kaplan On Suit Against The Gov't

    U.S. Court of Federal Claims Judge Elaine Kaplan's docket doesn't always garner attention in the same way trial court cases do, but that may change as the executive branch makes sweeping budget and policy changes that could lend more political significance to monetary claims against the government.

  • October 07, 2025

    Estate's $17M Transfer Not Tax-Related, 5th Circ. Told

    The estate of a woman who inherited her husband's oil business and was the victim of elder abuse told the Fifth Circuit that it had multiple reasons unrelated to avoiding estate tax for setting up a partnership and transferring $17 million into it just before she died.

  • October 07, 2025

    IRS Provides Grace Period For Int'l Money Transfer Tax Errors

    U.S. financial institutions that handle overseas money transfers won't immediately face penalties if they fail to accurately deposit new excise taxes that are required under the budget reconciliation bill enacted in July, the Internal Revenue Service announced Tuesday.

  • October 07, 2025

    TCJA Designer Tapped For Deputy Treasury Role

    An architect of the 2017 federal tax overhaul has been appointed to serve as second-in-command at the U.S. Department of the Treasury, Secretary Scott Bessent announced Tuesday.

Expert Analysis

  • DOJ Crypto Enforcement Is Shifting To Target Willfulness

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    Three pending criminal prosecutions could be an indication of how the U.S. Department of Justice's recent digital assets memo is shaping enforcement of the area, and show a growing focus on executives who knowingly allow their platforms to be used for criminal conduct involving sanctions offenses, say attorneys at Gibson Dunn.

  • 4 Former Justices Would Likely Frown On Litigation Funding

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    As courts increasingly confront cases involving hidden litigation finance contracts, the jurisprudence of four former U.S. Supreme Court justices establishes a constitutional framework that risks erosion by undisclosed financial interests, says Roland Eisenhuth at the American Property Casualty Insurance Association.

  • Practical Implications Of SEC's New Crypto Staking Guidance

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    The U.S. Securities and Exchange Commission's recent staff guidance that protocol staking does not constitute securities offerings provides a workable compliance blueprint for crypto developers, validators and custodial platforms willing to keep staking strictly limited to protocol-driven rewards, say attorneys at Cahill.

  • How Attys Can Use AI To Surface Narratives In E-Discovery

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    E-discovery has reached a turning point where document review is no longer just about procedural tasks like identifying relevance and redacting privilege — rather, generative artificial intelligence tools now allow attorneys to draw connections, extract meaning and tell a coherent story, says Rose Jones at Hilgers Graben.

  • AbbVie Frees Taxpayers From M&A Capital Loss Limitations

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    The U.S. Tax Court’s June 17 opinion in AbbVie v. Commissioner, finding that a $1.6 billion break fee was an ordinary and necessary business expense, marks a pivotal rejection of the Internal Revenue Service’s position on the tax treatment of termination fees related to failed mergers or acquisitions, say attorneys at Holland & Knight.

  • ABA Opinion Makes It A Bit Easier To Drop A 'Hot Potato'

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    The American Bar Association's recent ethics opinion clarifies when attorneys may terminate clients without good cause, though courts may still disqualify a lawyer who drops a client like a hot potato, so sending a closeout letter is always a best practice, say attorneys at Thompson Hine.

  • Federal Construction Considerations Amid Policy Overhaul

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    The rapid overhaul of federal procurement, heightened domestic sourcing rules and aggressive immigration enforcement are reshaping U.S. construction, but several pragmatic considerations can help federal contractors engaged in infrastructure and public construction avoid the legal, financial and operational fallout, say attorneys at Cozen O'Connor.

  • Can Companies Add Tariffs Back To Earnings Calculations?

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    With the recent and continually evolving tariffs announced by the Trump administration, John Ryan at King & Spalding takes a detailed look at whether those new tariffs can be added back in calculating earnings before interest, taxes, depreciation and amortization — an important question that may greatly affect a company's compliance with its financial covenants.

  • A Look At DOJ's Dropped Case Against Early Crypto Operator

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    The prosecution of an early crypto exchange operator over alleged unlicensed money transmission was recently dropped in Indiana federal court, showcasing that the U.S. Justice Department may be limiting the types of enforcement cases it will bring against digital asset firms, say attorneys at Greenberg Traurig.

  • 8 Ways Lawyers Can Protect The Rule Of Law In Their Work

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    Whether they are concerned with judicial independence, regulatory predictability or client confidence, lawyers can take specific meaningful actions on their own when traditional structures are too slow or too compromised to respond, says Angeli Patel at the Berkeley Center of Law and Business.

  • 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.

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