Federal

  • October 10, 2025

    The Tax Angle: IRS Leadership Changes Amid Gov't Shutdown

    The federal government shutdown doesn't appear any closer to being resolved on Capitol Hill, but that hasn't stopped the U.S. Treasury Department from pushing ahead with a dizzying amount of changes in the Internal Revenue Service's top leadership. Here's a rundown of changes at the IRS in the past week.

  • October 10, 2025

    Tax Court Told IRS Miscalculated $21M Bill In Trust Dispute

    The Internal Revenue Service made erroneous calculations regarding an Arizona partnership's capital gains and assets related to partnership interests transferred to trusts, the partnership told the U.S. Tax Court as it challenged a $21 million tax bill.

  • October 10, 2025

    IRS Generally Provided Courteous Phone Service, TIGTA Says

    Limited testing of the Internal Revenue Service's telephone calls showed that agency representatives were generally courteous and professional when assisting taxpayers, but there are some areas where the IRS can improve, according to a Treasury Inspector General for Tax Administration report released Friday.

  • 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.

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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