Federal

  • 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.

  • November 10, 2025

    IRS Sets Safe Harbor For Trusts Staking Digital Assets

    Investment and grantor trusts can stake their digital assets — which can generate passive income — without losing their tax benefits if they meet certain requirements, including obtaining approval from the U.S. Securities and Exchange Commission to authorize such activities, the Internal Revenue Service said in a revenue procedure Monday.

  • November 10, 2025

    Ex-Russian Gas Exec Seeks Release After Tax Sentence Axed

    A former Russian gas company executive convicted of hiding more than $100 million from the IRS asked a Florida federal court to release him from prison now that his sentence has been vacated on appeal, while the U.S. urged the court to deliver the same seven-year term.

  • November 10, 2025

    Supreme Court Declines Lawyer's Bid For New Tax Fraud Trial

    The U.S. Supreme Court won't hear a personal injury lawyer's appeal of his conviction over allegations he concealed more than $2.6 million in income from the Internal Revenue Service.

  • November 07, 2025

    Eaton Should Have Weighed Borrowing In Europe, Judge Says

    When it acquired Ireland-based Cooper Industries in 2012, Eaton Corp. should have considered the costs of borrowing in Europe to finance the transaction, Tax Court Judge Albert Lauber said Friday in questioning a former Eaton official.

  • November 07, 2025

    Justices Cast Constitutional Clouds Over Trump's Tariffs

    Several U.S. Supreme Court justices appeared skeptical of the government's arguments seeking to salvage President Donald Trump's emergency tariffs, signaling that the high court may come down with a ruling that reinforces Congress' constitutional authority to impose tariffs.

  • November 07, 2025

    State Tax Rules Flagged To DOJ In Interstate Commerce Probe

    Tax attorneys and business groups are using a federal effort that aims to reduce interstate commerce burdens to highlight litigation over state taxes and call for codifying U.S. Supreme Court precedent on the commerce clause.

  • November 07, 2025

    Calif. Cannabis Co. Fights $10M IRS Bill In Tax Court

    A California company that manages cannabis operators challenged $10 million in taxes and penalties in the U.S. Tax Court, arguing the Internal Revenue Service stripped it of business deductions by incorrectly determining it trafficked in a controlled substance.

  • November 07, 2025

    Donor Wants Tax Court To Reinstate Easement Deductions

    An Oklahoma donor asked the U.S. Tax Court to reinstate deductions of $12 million and $13 million he claimed through partnership entities on a pair of charitable conservation easement donations, asserting the Internal Revenue Service disallowed the tax breaks without adequate explanation.

  • November 07, 2025

    9th Circ. Sides With Calif. In Tribal Cigarette Tax Fight

    The Ninth Circuit on Friday backed California in a dispute it brought to enforce cigarette taxes against a tobacco company owned and operated by a federally recognized Native American tribe, holding that the tribal leader defendants can't claim sovereign or qualified immunity exempts them from the federal tax law.

  • November 07, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service on Friday released its weekly internal revenue bulletin, which included proposed regulations that would remove rules that allow revenue officials to look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.

  • November 07, 2025

    DOJ Backs Trump In NY False-Records Conviction Appeal

    The U.S. Department of Justice is throwing its support behind President Donald Trump's effort to overturn his New York criminal conviction for falsifying business records, filing a proposed amicus brief on Friday citing the U.S. Supreme Court's landmark 2024 decision "defining the contours of a president's federal constitutional immunity from criminal prosecution."

  • November 07, 2025

    Wyden, Warren Flag IRS CEO's Fiserv Tenure In Probe

    Two Senate Finance Committee members said they are investigating Internal Revenue Service CEO Frank Bisignano's conduct in his previous position as Fiserv Inc.'s CEO, saying the financial setbacks the company has faced this year raise questions about his ability to serve as a key IRS official.

  • November 07, 2025

    Taxation With Representation: Kirkland, Cravath, Paul Weiss

    In this week's Taxation With Representation, consumer products giant Kimberly-Clark acquires Tylenol maker Kenvue, shale producers SM Energy and Civitas Resources announce a merger, and power management company Eaton buys Boyd Corp.'s thermal business.

  • November 06, 2025

    Goldstein Loses Bid To Trim Tax Charges Before Trial

    A Maryland federal judge Thursday handed SCOTUSblog co-founder Tom Goldstein a series of losses on pre-trial motions aimed at trimming the 22 federal tax charges he'll face at trial next year, ruling that many of the motions involved factual disputes fit for trial and keeping the government's case intact.

  • November 06, 2025

    Tax Court OKs Disallowance Of Unverified Litigation Fees

    The IRS correctly determined that a woman who'd been at odds with her various attorneys — having filed breach of contract suits against two separate legal teams — inadequately justified her claimed $28,000 deduction for legal expenses, the U.S. Tax Court said Thursday.

  • November 06, 2025

    Whistleblower Entitled To Award For $31M Tip, DC Circ. Told

    The U.S. Tax Court wrongly denied a whistleblower award to a woman who said she helped the Internal Revenue Service assess more than $31 million in corporate income, her supporter told the D.C. Circuit, saying the court allowed the agency to omit relevant information it was required to provide.

  • November 06, 2025

    IRS Microcaptive Reporting Rules Suit Can Move Forward

    A global tax services provider can move forward with its suit against the IRS to vacate tax reporting rules for microcaptive insurance companies, a Texas federal court said, finding the company had a stake in the challenge and a right to bring the case.

  • November 06, 2025

    No $22M Break For Real Estate Partnership, 6th Circ. Affirms

    An Ohio real estate partnership cannot claim a $22 million charitable tax deduction on a 2016 preservation easement, the Sixth Circuit found, affirming the U.S. Tax Court and Internal Revenue Service's conclusions that the partnership grossly misstated the value of the donated historic building.

  • November 06, 2025

    Tax Court Says IRS Took Too Long To Ax Easement Deduction

    The Internal Revenue Service failed to timely disallow a charitable deduction related to a company's conservation easement donation, the U.S. Tax Court said, throwing out a partnership adjustment by the agency.

Expert Analysis

  • UK's 1st ICSID Claim Shows Bilateral Investment Treaty Reach

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    For the first time, the U.K. is facing a claim under the International Centre for Settlement of Investment Disputes Convention, underscoring the broader reality that treaty protections are no longer confined to investors in emerging markets, says Philipp Kurek at Signature Litigation.

  • Trump Tax Law's Most Impactful Corp. And Individual Changes

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    The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.

  • From Clerkship To Law Firm: 5 Transition Tips For Associates

    Excerpt from Practical Guidance
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    Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.

  • Trump Tax Law's Most Consequential International Changes

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    The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.

  • Associates Can Earn Credibility By Investing In Relationships

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    As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.

  • Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling

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    The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.

  • What 2 Profs Noticed As Transactional Law Students Used AI

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    After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.

  • BigLaw Settlements Should Not Spur Ethics Deregulation

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    A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.

  • 5 Ways Lawyers Can Earn Back The Public's Trust

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    Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.

  • Legal Jeopardy Looms Over Trump's Trade Negotiation Plans

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    Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.

  • Opportunity Zone Overhaul Is Good News For Investors

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    Recently enacted reforms making the qualified opportunity zone program permanent, restoring the basis step-up for capital gains and adding flexibility to the zone designation process enhance the program’s appeal for long-term investment, says Steven Hadjilogiou at McDermott.

  • White House Report Strikes An Optimistic Note On Crypto

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    Taking seriously President Donald Trump's pledge to adopt a pro-innovation mindset toward digital assets and blockchain technologies, a recent benchmark White House report on crypto provides a comprehensive regulatory framework that takes into account the products' novel characteristics within the high-tech ecosystem, say attorneys at Davis Wright.

  • Bipartisan Bill Could Aid ESOP Formation, Valuation Clarity

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    The proposed Retire through Ownership Act represents a meaningful first step toward clarifying whether transactions qualify under the adequate consideration exemption in the Employee Retirement Income Security Act, potentially eliminating the litigation risk that has chilled employee stock ownership plan formation, say attorneys at Moore & Van Allen.

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