Federal

  • August 26, 2025

    Facebook Urges Tax Court To Toss IRS' Royalty Calculations

    Facebook asked the U.S. Tax Court to reject the IRS' proposed royalty rate and other calculations for the social media giant's deal with an Irish affiliate to develop intangibles, arguing the agency is attempting to recharacterize the transaction.

  • August 26, 2025

    IRS Urged To Avoid Retroactive Solar, Wind Tax Changes

    Changes to the beginning-of-construction definition under rules to determine large solar and wind energy development projects' eligibility for certain tax credits should not be applied retroactively, several groups said in letters to the U.S. Department of the Treasury released Tuesday.

  • August 26, 2025

    EU Defends Digital Taxes Following Trump's Tariff Threat

    The European Commission said Tuesday that it stands by European Union member states keeping digital taxes in place despite President Donald Trump's renewed threats to impose tariffs on countries with measures hitting the U.S. tech giants.

  • August 25, 2025

    6th Circ. Says Tax Court Filing Deadline Can Be Tolled

    The 90-day deadline to petition the U.S. Tax Court is not a jurisdictional bar and may be extended for certain reasons, the Sixth Circuit found Monday, reviving a woman's late challenge to an IRS tax deficiency.

  • August 25, 2025

    Tax Court Tosses Suit From Accountant Who Copped To Fraud

    An accountant who admitted to tax and healthcare fraud in connection with an Alabama group home for disabled people can't challenge a tax debt because the underlying IRS notice stating the amount due was a reminder, not a determination, the U.S. Tax Court said Monday.

  • August 25, 2025

    NC Man Gets Nearly 20 Years For Tax Fraud, Ponzi Scheme

    A North Carolina man was sentenced to nearly 20 years in prison after willfully failing to report nearly $9 million in income to the Internal Revenue Service and evading more than $3 million in taxes in connection with a $20 million Ponzi scheme, federal prosecutors said.

  • August 25, 2025

    Tax Interest Rates To Stay Steady In 4th Quarter

    The Internal Revenue Service's interest rates for overpayments and underpayments of tax will remain the same in the quarter starting in October, the agency said Monday.

  • August 25, 2025

    Advocate Orgs. Ask DC Circ. To Stop IRS Sharing Info With ICE

    Immigrant advocacy groups urged the D.C. Circuit to stop the IRS from sharing taxpayer addresses with immigration authorities, saying the court should consider the substance of their challenge to an unprecedented information sharing deal rather than toss their case on procedural grounds put forward by the government.

  • August 25, 2025

    Ex-TSA Attorney Among 3 New Lawyers At Kaplan Kirsch

    A former Transportation Security Administration attorney is among three lawyers who recently joined Kaplan Kirsch LLP, a Denver-based law firm that specializes in representing state, local and tribal government agencies on projects such as airport expansions and new rail lines.

  • August 25, 2025

    Connecticut Court Backs Ouster Of Tax Atty Over Rogue Email

    Connecticut's former tax legal director was properly terminated after she used her work computer to send unauthorized draft legislation from her personal email account to a lobbyist who assumed that it was the state tax department's official position, a Connecticut appeals panel has ruled.

  • August 25, 2025

    Woman Who Beat $1.7M In Tax Liens Can't Recover Costs

    A woman blamed by the government for the employment tax failures of her husband's construction company cannot recover her legal costs after a jury cleared her, a New York federal judge ruled, saying the U.S. was justified in trying to uphold $1.7 million in liens against her.

  • August 22, 2025

    Liberty Global $240M Foreign Tax Credit Bid Fails At 10th Circ.

    Liberty Global cannot claim $240 million in foreign tax credits for the sale of a Japanese affiliate, the Tenth Circuit ruled Friday, rejecting the telecommunications giant's contention that a statutory provision allows it to recharacterize the proceeds as overseas income.

  • August 22, 2025

    Canada To Toss Tariffs On US Goods Under USMCA

    The Canadian government will remove retaliatory tariffs on U.S. goods that comply with the United States-Mexico-Canada Agreement, excluding steel, aluminum and automobiles, in a move aimed at jump-starting trade talks akin to an exemption made by the U.S. government, Canada's prime minister said Friday.

  • August 22, 2025

    Tribe Member Can't Discharge Tax Debt, 10th Circ. Affirms

    An Oklahoma federal court correctly affirmed a bankruptcy court's refusal to reopen a case brought by a member of the Muscogee Creek Nation who claimed his tax debt should have been discharged in bankruptcy, the Tenth Circuit said.

  • August 22, 2025

    Taxation With Representation: Kirkland, Weil, Fried Frank

    In this week's Taxation With Representation, private equity firm Thoma Bravo buys human resources software provider Dayforce Inc. in a take-private deal, Lowe's buys Foundation Building Materials, Nexstar Media Group Inc. acquires fellow media company Tegna Inc., and Soho House & Co. Inc. inks a take-private deal with hotel operator MCR.

  • August 22, 2025

    Michigan Judge Gives Initial OK To Tax Foreclosure Deal

    A Michigan federal judge has granted preliminary approval to a settlement that would allow former property owners to receive the surplus profits they allege county treasurers made selling their tax-delinquent properties.

  • August 22, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included proposed rules that would change its system of business classification for employees hoping to exclude fringe benefits and employee discounts from their gross income.

  • August 22, 2025

    Treasury Doubles Statutory Value Of Clean Energy Credit

    The U.S. Department of the Treasury is nearly doubling the statutory value of an income tax credit for producing electricity in line with a regularly scheduled increase tied to inflation, according to a Friday notice.

  • August 22, 2025

    IRS Guidance Sparks Mixed Reaction For Solar, Wind Projects

    The IRS recently narrowed the way large solar and wind energy development projects can set their construction start dates to qualify for certain tax credits, a change offering relief for some developers but new hurdles for others depending on the stage, type and size of the project.

  • August 21, 2025

    Tax Court Says Civil Fraud Penalty Cases Don't Require Juries

    The U.S. Tax Court rejected Thursday a Mississippi partnership's bid, based on the Supreme Court's landmark 2024 decision requiring a jury to adjudicate common law fraud penalties, to dismiss civil fraud penalties the IRS imposed on a conservation easement transaction.

  • August 21, 2025

    Man Who Hid Account From Wife Owes FBAR Fines, US Says

    A claim by the owner of a check-cashing business that he only meant to hide a foreign bank account from his wife during divorce proceedings doesn't excuse his failure to report the money to the Internal Revenue Service, the U.S. told a California federal court.

  • August 21, 2025

    EU, US Agree To Eliminate Industrial Tariffs

    The European Union and the U.S. have agreed on new terms to the trade agreement to eliminate EU tariffs on U.S. industrial products and implement a 15% U.S. tariff cap for most other sectors, according to a joint statement issued Thursday.

  • August 21, 2025

    Treasury Gets New Acting International Tax Counsel

    A deputy international tax counsel for the U.S. Department of the Treasury has been elevated to serve as acting counsel, he said in a post on LinkedIn.

  • August 21, 2025

    IRS Asks For Input On Free Filing Programs

    The Internal Revenue Service is surveying the public on tax preparation and filing as part of efforts to prepare a report for Congress on key issues surrounding free tax filing options, the agency said Thursday.

  • August 21, 2025

    Gov't Shrugs Off Sentencing Errors, IRS Leaker Tells DC Circ.

    The IRS contractor appealing his five-year prison sentence for leaking thousands of wealthy people's tax returns to the media accused the U.S. of glossing over sentencing errors that unfairly burdened him with "the harshest sentence possible," he told the D.C. Circuit.

Expert Analysis

  • 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.

  • We Must Allow Judges To Use Their Independent Judgment

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    As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.

  • Preparing For Tariffs On Canadian Power In The Northeast

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    The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.

  • Making The Case For Rest In The Legal Profession

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    For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.

  • Mitigating Tariff Risks For Healthcare In US And Canada

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    Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.

  • 4 Ways Women Attorneys Can Build A Legal Legacy

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    This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.

  • A Judge's Pointers For Adding Spice To Dry Legal Writing

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    U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.

  • Why NY May Want To Reconsider Its LLC Transparency Law

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    Against the backdrop of the myriad challenges to the federal Corporate Transparency Act, it may be prudent for New York to reconsider its adoption of the LLC Transparency Act, since it's unclear whether the Empire State's "baby-CTA" statute is still necessary or was passed prematurely, say attorneys at Pillsbury.

  • IRS Scrutiny May Underlie Move Away From NIL Collectives

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    The University of Colorado's January announcement that it was severing its partnership with a name, image and likeness collective is part of universities' recent push to move NIL activities in-house, seemingly motivated by tax implications and increased scrutiny by the Internal Revenue Service, say attorneys at Buchanan Ingersoll.

  • 7 Tips For Associates To Thrive In Hybrid Work Environments

    Excerpt from Practical Guidance
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    As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.

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