Federal

  • November 17, 2025

    Applicable Federal Rates To Continue Monthslong Slide

    Applicable federal rates for income tax purposes will decrease in December, the Internal Revenue Service said Monday, sliding for the fifth month in a row after a rebound in July.

  • November 17, 2025

    Fed. Circ. Finds Baby Formulas For Illnesses Duty-Free

    A baby formula maker's products designed as therapies for children with chronic medical conditions qualify for duty-free treatment, the Federal Circuit ruled Monday, overturning the U.S. Court of International Trade's decision in a decade-old dispute.

  • November 17, 2025

    Minn. Dentist's Wife Can't Feign Ignorance, Tax Court Says

    The U.S. Tax Court granted a Minnesota woman only partial relief Monday from shared tax liabilities with her former husband, holding that an Internal Revenue Service agent's visit marked "the dividing line" when she could no longer claim not to know about their unpaid taxes.  

  • November 17, 2025

    OMB Reviewing Treasury Regs On OECD Crypto Reporting

    The Office of Management and Budget is reviewing regulations proposed by the U.S. Department of the Treasury to implement automatic exchanges of information between tax authorities regarding taxpayers' cryptocurrency holdings under the OECD's crypto-asset reporting framework.

  • November 17, 2025

    MVP: Sullivan & Cromwell's Isaac Wheeler

    Isaac Wheeler of Sullivan & Cromwell LLP's tax practice advised RedBird Capital Partners on the Skydance and Paramount deal, helped xAI and X on a $113 billion transaction related to their merger and guided Tishman Speyer on its $3.5 billion refinancing of Rockefeller Center, earning him a spot as one of the 2025 Law360 Tax MVPs.

  • November 17, 2025

    Fed. Circ. Backs Commerce To Nix Turkish Steel Duties

    The U.S. Department of Commerce's removal of countervailing duties on Turkish steel imports was properly justified by the government, and the lower trade court correctly upheld its determination despite objections by the domestic steel industry, the Federal Circuit affirmed Monday.

  • November 17, 2025

    Madoff Victims Lose Bid To Claim $8.2M Theft Loss Deduction

    A New York couple lost their challenge to claim a $8.2 million theft loss tax deduction on life insurance policies invested in accounts tied to Bernie Madoff's Ponzi scheme after the Second Circuit found that the husband did not own the policies' underlying assets.

  • November 14, 2025

    IRS Expert Challenges Data Used In Eaton's Projections

    An expert witness for the Internal Revenue Service questioned the financial projections prepared by Eaton Corp.'s experts Friday in U.S. Tax Court, saying the data they relied on wasn't available in 2012, when the company took on debt to acquire Ireland-based Cooper Industries, a global electrical products manufacturer, for $13 billion.

  • November 14, 2025

    The Tax Angle: Letter Ruling Debate, Experts' Role In Policy

    From a discussion on whether seeking a private letter ruling risks sparking more IRS oversight to a former Congressional Budget Office director's thoughts on tax experts' role in policymaking, here's a peek into a reporter's notebook on stories from the National Tax Association's annual conference in Boston.

  • November 14, 2025

    Trump Pulls IRS Chief Counsel Nomination Before Floor Vote

    President Donald Trump on Friday withdrew his nomination of a Sullivan & Cromwell attorney to be the Internal Revenue Service's chief counsel just weeks after the Senate Finance Committee voted to advance the nomination to the Senate floor.

  • November 14, 2025

    MVP: Latham's Pardis Zomorodi

    Pardis Zomorodi, partner at Latham & Watkins LLP's transactional tax practice in Los Angeles, has guided companies through the tax aspects of major complex transactions, including 2024's largest IPO and the high-profile merger between Skydance Media and Paramount Global, earning her a spot as one of the 2025 Law360 Tax MVPs.

  • November 14, 2025

    DC Circ. Urged To Block Trump Org. From IRS Leaker's Appeal

    President Donald Trump's private business organization should not be allowed to intervene in a former IRS contractor's challenge to his prison sentence for leaking Trump's and other wealthy people's tax returns, the contractor told the D.C. Circuit, saying the organization's participation would unfairly bias the court.

  • November 14, 2025

    US To Slash Tariff On Swiss Imports To 15% In Trade Deal

    The U.S. will reduce a 39% tariff on Swiss imports to 15% as part of a framework trade agreement reached with Switzerland, according to Friday announcements by the White House and the Swiss government.

  • November 14, 2025

    Taxation With Representation: Wachtell, Paul Hastings, Sidley

    In this week's Taxation With Representation, Pfizer Inc. completes its acquisition of obesity drug developer Metsera Inc., motion and controls technologies company Parker-Hannifin Corp. acquires Filtration Group Corp., and fund administrator JTC PLC backs a cash offer in the billions from British private equity shop Permira.

  • November 14, 2025

    Biz Contests $1.7M Tax Bill After Insurance Deductions Axed

    The Internal Revenue Service incorrectly hit a Colorado corporation with $1.7 million in taxes and penalties after erroneously disallowing deductions the company claimed for insurance premiums, the company told the U.S. Tax Court in a petition published Friday.

  • November 14, 2025

    Liquidated Captive Insurer Fights IRS Bill In Tax Court

    A captive insurance company that was later dissolved challenged $800,000 in taxes and penalties in the U.S. Tax Court, saying the Internal Revenue Service wrongly claimed the company had $3 million in unreported long-term capital gains.

  • November 14, 2025

    US Expatriations Rise To 1,600 In 3rd Quarter, IRS Says

    The number of people who lost or renounced their U.S. citizenship totaled 1,600 in the third quarter as logged by the U.S. Treasury Department, a 50% increase from the previous quarter, the IRS said Friday.

  • November 14, 2025

    Ala. Partnerships Say IRS Erred Rejecting Easement Breaks

    The Internal Revenue Service unlawfully denied a pair of Alabama partnerships' $40 million charitable tax deduction on a conservation easement they donated in 2020, the partnerships told the U.S. Tax Court, arguing the agency offered no sufficient explanation for its determination.

  • November 14, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly internal revenue bulletin Friday, which included guidance for group health plans and health insurers to calculate out-of-network healthcare coverage for 2026.

  • November 13, 2025

    Eaton Witnesses Probed About Data Used For Credit Analysis

    An accounting expert and a former Eaton Corp. official both advised the U.S. Tax Court on Thursday about the data used to establish the financial position of the U.S. company after its acquisition of Irish-based Cooper Industries in 2012.

  • November 13, 2025

    Clean Energy Cos. Tap Private Cash To Beat Tax Credit Clock

    Clean energy developers are increasingly looking to privately held investors to ensure they can do enough work to keep their projects fully eligible for tax credits that start phasing out next year, energy development attorneys told Law360.

  • November 13, 2025

    Latin American Trade Deals With US Include Zero Tariff Rates

    Latin American countries including El Salvador, Guatemala, Ecuador and Argentina committed to nontariff reductions for U.S. producers in exchange for a zero tariff rate on many imports not readily available in the U.S., under details of framework trade agreements the White House unveiled Thursday.

  • November 13, 2025

    Tax Court Lets Oil Co. Split Losses In $72M Carryback Dispute

    An oil and gas company was allowed to give up the normal carryback period for its net operating losses without waiving the 10-year period for $72 million in specified liability losses, a divided U.S. Tax Court ruled Thursday, with two judges saying the rules aren't so flexible.

  • November 13, 2025

    Tax Court Upholds Levy Action For $186K Deficiency In Ala.

    The U.S. Tax Court affirmed an Internal Revenue Service decision to collect an Alabama couple's $186,000 tax debt, ruling Thursday that despite sympathy for the wife's severe medical condition, the husband had failed to participate in proceedings to make his case.

  • November 13, 2025

    High Court's Tariff Ruling May Trigger Refunds, Reimposition

    Importers are being advised to prepare for potential refunds in the event the U.S. Supreme Court rules President Donald Trump's emergency tariffs are unlawful, leaving questions about how a refund process might play out and whether the duties would be reimposed.

Expert Analysis

  • Preserving Refunds As Tariffs Await Supreme Court Weigh-In

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    In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.

  • Revamped Opportunity Zones Can Aid Clean Energy Projects

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    The Qualified Opportunity Zone program, introduced in 2017 and reshaped in the One Big Beautiful Bill Act, offers investors federal tax incentives for development in low-income communities — incentives that are especially meaningful for clean energy projects, where capital-intensive infrastructure and long-term planning are essential, say attorneys at Dentons.

  • Writing Musicals Makes Me A Better Lawyer

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    My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.

  • How Fashion, Tech Can Maximize New Small Biz Tax Breaks

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    Fashion and technology companies, which invest heavily in innovation, should consider taking advantage of provisions in the One Big Beautiful Bill Act that favor small businesses, restructuing if necessary to become eligible for expanded research and experimental expenditure credits and qualified small business stock incentives, says Aime Salazar at Olshan Frome.

  • Adapting To Private Practice: From Va. AUSA To Mid-Law

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    Returning to the firm where I began my career after seven years as an assistant U.S. attorney in Virginia has been complex, nuanced and rewarding, and I’ve learned that the pursuit of justice remains the constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.

  • 7 Document Review Concepts New Attorneys Need To Know

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    For new associates joining firms this fall, stepping into the world of e-discovery can feel like learning a new language, but understanding a handful of fundamentals — from coding layouts to metadata — can help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.

  • Agentic AI Puts A New Twist On Attorney Ethics Obligations

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    As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.

  • Opportunity Zone's Future Corp. Tax Benefits Still Uncertain

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    Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.

  • How GILTI Reform Affects M&A Golden Parachute Planning

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    Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.

  • What To Expect As Trump's 401(k) Order Materializes

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    Following the Trump administration’s recent executive order on 401(k) plan investments in alternative assets like cryptocurrencies and real estate, the U.S. Department of Labor and the U.S. Securities and Exchange Commission will need to answer several outstanding questions before any regulatory changes are implemented, say attorneys at Cleary.

  • Demystifying The Civil Procedure Rules Amendment Process

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    Every year, an advisory committee receives dozens of proposals to amend the Federal Rules of Civil Procedure, most of which are never adopted — but a few pointers can help maximize the likelihood that an amendment will be adopted, says Josh Gardner at DLA Piper.

  • Parenting Skills That Can Help Lawyers Thrive Professionally

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    As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.

  • Unpacking The New Opportunity Zone Tax Incentive Program

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    The One Big Beautiful Bill Act brought several improvements to the opportunity zone tax incentive program that should boost investments in qualified funds, including making it permanent, increasing federal income tax benefits in rural areas, redesignating the qualified zones, and requiring more in-depth reporting, says Marc Schultz at Snell & Wilmer.

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