Federal

  • November 03, 2025

    2 Doctrines Likely To Direct Justices' Review Of Trump Tariffs

    When the U.S. Supreme Court hears oral arguments Wednesday over whether President Donald Trump can impose tariffs under the International Emergency Economic Powers Act, it will likely test two doctrines the justices have recently considered: the major questions and nondelegation doctrines.

  • November 03, 2025

    Tribes Push Supreme Court To Overturn Okla. Tax Ruling

    The Oklahoma Supreme Court incorrectly ruled that a member of the Muscogee Creek Nation owes Oklahoma income tax, groups representing Native American tribes told the U.S. Supreme Court, asking the justices to hear the case and reverse the ruling.

  • November 03, 2025

    Veteran Tax Controversy Atty Moves Team To Kostelanetz

    A longtime New Jersey tax attorney and three of his associates have joined Kostelanetz LLP, the boutique tax firm announced Monday, saying it expected them to bolster its tax controversy practice and add to its commitment to volunteer work and legal education.

  • October 31, 2025

    Int'l Tax In October: Deal With China, Halt To Canada Talks

    A tentative deal to reduce American tariffs on Chinese goods, ruptured trade talks between the U.S. and Canada, court defeats for the Danish and U.S. tax administrations and an end to the European Union's plan for a financial transaction tax topped the list of international tax news in October. Here, Law360 looks at the biggest developments from the past month.

  • October 31, 2025

    Twin Peaks Lender Says Developer Defaulted On $12M Loan

    A Florida franchisee group is suing a developer in state court over a $12 million loan to build two Twin Peaks restaurants in an EB-5 visa program, alleging the developer defaulted on the note and then told the IRS that it converted the loan into equity interest.  

  • October 31, 2025

    Up Next At High Court: Tariffs, Fugitives & Contractor Liability

    The U.S. Supreme Court will begin its November oral argument session Monday, during which the justices will consider President Donald Trump's authority to impose tariffs on foreign countries under an emergency statute, whether military contractors can be held liable for alleged breaches of contracts in war zones, and if there are time limits for litigants who want to vacate a void judgment. Here, Law360 breaks down the week's oral arguments.

  • October 31, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included the continued monthslong slide in applicable federal rates for income tax purposes.

  • October 31, 2025

    Taxation With Representation: Skadden, Davis Polk

    In this week's Taxation With Representation, American Water Works Co. and Essential Utilities announce a merger, semiconductor companies Skyworks and Qorvo combine to create an industry giant, and Terex Corp. and REV Group team up to form a specialty equipment manufacturer.

  • October 31, 2025

    Ruling Dispute In Limbo As 6th Circ. Rebuffs Shutdown Pause

    The Sixth Circuit denied a federal government attorney's request to pause a closely watched case about a U.S. Tax Court filing deadline after he told the court he was barred from working during the shutdown, leaving his plan to request a rehearing in limbo.

  • October 30, 2025

    Trade Deals At Risk In Trump Tariff Case, Feds Tell Justices

    The federal government told the U.S. Supreme Court on Thursday that President Donald Trump's global tariffs have led to significant trade deals addressing the underlying national emergencies he declared, and a ruling determining them unlawful would prove catastrophic.

  • October 30, 2025

    China Delays Expanded Mineral Export Controls, Trump Says

    China has agreed to delay for a year an expansion to export controls for key minerals and is set to start purchasing more U.S. agricultural products including soybeans, while U.S. tariffs on Chinese goods will decrease 10%, President Donald Trump said early Thursday morning.

  • October 30, 2025

    Kansas Doctor Loses Collection Dispute In Tax Court

    The U.S. Tax Court upheld Thursday an Internal Revenue Service action to collect nearly $730,000 from a Kansas-based doctor with years of unpaid taxes, finding that her silence on the agency's judgment request prompted the decision.

  • October 30, 2025

    Senate Votes To Ax Global Tariffs, But House Path Blocked

    The Senate passed legislation Thursday to end the declared national emergency propping up President Donald Trump's global tariff regime shortly after passing similar bills regarding tariffs on Canada and Brazil, though the House previously moved its deadline for action on the matter to next year.

  • October 30, 2025

    IRS Discloses Record In ICE Data Sharing Case

    The IRS, following a judge's order, has released its administrative record in a lawsuit over its agreement to share taxpayer information with federal immigration authorities, including emails in which officials discuss U.S. Immigration and Customs Enforcement's request for information on nearly 1.3 million taxpayers.

  • October 30, 2025

    Pa. Couple Ordered To Pay $1.77M IRS Debt

    A Pennsylvania couple who purchased a Maserati and a Porsche and took trips to international destinations while owing the Internal Revenue Service $1.77 million must pay those tax debts, a Pennsylvania federal judge ruled Thursday, adopting a magistrate judge's report.

  • October 30, 2025

    Sidley's 'Incomplete' Story Hid Fraud Scheme, Family Says

    A family alleging it was roped into an illegal tax sheltering scheme on the advice of a former Sidley Austin LLP attorney has urged a Georgia federal judge to keep its suit against the firm alive, arguing a jury should decide when the family knew enough about the fraud to move forward with its claims.

  • October 30, 2025

    3rd Circ. Affirms Tax On Interest In $191M Pharma Family Feud

    A pharmaceutical company's $191 million payment settling a family feud was for the sale of a family trust's ownership shares and included interest taxed as ordinary income, the Third Circuit said Thursday, rejecting the trust's claim that the money should be taxed at the lower, capital gains rate.

  • October 29, 2025

    Tax Atty Group Backs Fund Manager's $1.9M Refund Bid

    A tax attorneys professional association told the Eleventh Circuit that a Florida district court improperly blocked a fund manager and his wife's appeal to receive a $1.9 million tax refund under a rule that bars taxpayers from making new claims in federal court. 

  • October 29, 2025

    Senate Backs Axing Brazil Tariffs, But House Vote Blocked

    The Senate voted to end a declared national emergency underpinning U.S. tariffs placed on Brazil for the prosecution of its former president over an attempted coup, but the House has delayed a statutory requirement to expedite accompanying legislation.

  • October 29, 2025

    Partnership Challenges Nix of $4.5M Easement Deduction

    The Internal Revenue Service relied on an audit report that failed to meet the requirements of the Administrative Procedure Act when it rejected a partnership's $4.5 million tax deduction for donating a conservation easement across more than 50 acres in Tennessee, the partnership told the U.S. Tax Court as it challenged the rejection.

  • October 29, 2025

    Fla. Challenges 'Special' Calif. Tax Rule At Supreme Court

    Florida on Tuesday took steps to sue California in the U.S. Supreme Court, seeking to strike down a California taxation rule as unconstitutional for allegedly discouraging companies from relocating or operating outside the Golden State.

  • October 29, 2025

    7th Circ. Skeptical Of Bid To Toss Ex-Atty's Bribery Conviction

    Judges on a Seventh Circuit panel appeared doubtful Wednesday of a former attorney's contention that he never bribed ex-Chicago Alderman Ed Burke and was merely seeking to hire him for a legal matter.

  • October 29, 2025

    IRS Wrongly Nixed Insurance Transactions, Tax Court Told

    A Tennessee company that claims to provide in-house insurance to businesses supporting the U.S. Department of Defense and NATO has challenged more than $500,000 in tax liabilities and the IRS' denial of its status as an insurer, according to a U.S. Tax Court petition.

  • October 29, 2025

    Publix Heiress Asks To Quash IRS Summons For Bank Info

    An heiress to the Publix grocery store chain asked a Florida federal court to quash an IRS summons seeking her bank information on behalf of Italian tax officials, arguing that the agency's request flouts the Italy-U.S. tax treaty.

  • October 29, 2025

    Partnership Fights For $56M Tax Break For Conservation Gift

    A partnership is entitled to a $56 million tax deduction for donating a conservation easement over more than 200 acres in Louisiana that protects farmland and wildlife, including a threatened bird species, the partnership told the U.S. Tax Court in challenging the Internal Revenue Service.

Expert Analysis

  • US Reassessment Of OECD Tax Deal Is Right Move

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    The wholesale U.S. reevaluation of the Organization for Economic Cooperation and Development's global tax deal ordered by President Donald Trump is a positive step that could ultimately create a more durable international tax system, says Anne Gordon at the National Foreign Trade Council.

  • Measuring And Mitigating Harm From Discriminatory Taxes

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    In response to new tariffs and other recent "America First Trade Policy" pronouncements, corporations should assess and take steps to minimize their potential exposure to discriminatory and reciprocal tax measures that are likely to come, say economists at Charles River Associates.

  • Adapting To Private Practice: From DOJ Leadership To BigLaw

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    The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.

  • How The CRE Industry Is Adapting To Tariff Uncertainty

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    Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.

  • Law Firm Executive Orders Create A Legal Ethics Minefield

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    Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.

  • Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike

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    The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.

  • Firms Must Embrace Alternative Billing Models Or Fall Behind

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    As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.

  • How Attorneys Can Master The Art Of On-Camera Presence

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    As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.

  • Adapting To Private Practice: From Fed. Prosecutor To BigLaw

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    Making the jump from government to private practice is no small feat, but, based on my experience transitioning to a business-driven environment after 15 years as an assistant U.S. attorney, it can be incredibly rewarding and help you become a more versatile lawyer, says Michael Beckwith at Dickinson Wright.

  • Justices' False Statement Ruling Curbs Half-Truth Liability

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    The U.S. Supreme Court’s recent Thompson v. U.S. decision clarified that a federal statute used to prosecute false statements made to bank regulators only criminalizes outright falsehoods, narrowing prosecutors’ reach and providing defense counsel a stronger basis to challenge indictments of merely misleading statements, says Tamara de Silva at De Silva Law Offices.

  • Perfecting Security Interests In Renewable Energy Tax Credits

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    The ability to transfer renewable energy tax credits has created new opportunities for developers, investors and lenders, but it also raises important questions regarding when and how the security interests in these credits are perfected — questions that must be answered definitively to protect credit claims and transactions, says Harry Teichman at Stinson.

  • Firms Still Have Lateral Market Advantage, But Risks Persist

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    Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.

  • Making The Opportunity Zones Program Great At Last

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    As the opportunity zone program approaches its expiration, the Republican-led government could take specific steps to extend and improve the program, address its structural flaws, encourage broader participation and enable it to live up to its promised outcomes, say attorneys at Pillsbury.

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