Federal

  • September 19, 2025

    Feds Urge Justices To Back Trump's Emergency Tariffs

    The federal government told the U.S. Supreme Court Friday that lower courts incorrectly determined President Donald Trump's emergency tariffs unlawful under a statute that gives the executive broad authority to regulate the economy in matters of national emergency,.

  • September 19, 2025

    Foreign Entity Rules Begin To Shape Clean Energy Deals

    The recently enacted federal budget that attaches stricter foreign supply chain and business ownership rules to clean energy tax credits has started to take practical effect, with project developers rewriting agreements to avoid getting snagged in the new regulatory regime.

  • September 19, 2025

    Pillar 2 At 4: High Compliance Costs, Low Tax Liabilities

    Four years after countries agreed to an international minimum corporate tax regime known as Pillar Two, finance executives and policy observers are voicing a common refrain: multinational companies likely will pay more compliance costs than actual taxes under the new rules.

  • September 19, 2025

    Bills Would End Emergencies For Tariffs On Brazil, Canada

    A national emergency underpinning U.S. tariffs imposed on Canada and another one justifying most American tariffs on Brazil would be ended under a pair of resolutions introduced with bipartisan support by Sen. Tim Kaine, D-Va.

  • September 19, 2025

    $1M FBAR Penalty Without Jury Unconstitutional, Judge Says

    A woman who faced more than $1 million in civil penalties for failing to report offshore bank accounts to the IRS is off the hook, as a Texas federal court ruled Friday that the federal government violated her constitutional right to a jury trial.

  • September 19, 2025

    Cayman Hedge Fund Takes $100M Tax Dispute To 3rd Circ.

    A Cayman Islands hedge fund urged the Third Circuit to revive its challenge to a $100 million tax bill for earning money in connection with a U.S. business, saying the business did not exist, contrary to claims by the IRS and the U.S. Tax Court.

  • September 19, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, consisted of just one item, the removal of a proposed rule that would have allowed the U.S. State Department to share taxpayer return information related to the revocation or denial of passports for those with serious tax debts.

  • September 19, 2025

    IRS Proposes Qualifying Occupations For Tips Deduction

    Nearly 70 occupations, including bartenders, food preparation workers, musicians, electricians and social media influencers, were included in the proposed list of occupations subject to President Donald Trump's policy of no tax on tips, the Internal Revenue Service said Friday. 

  • September 18, 2025

    IRS Discloses Details On ICE Agreement In Data Sharing Row

    The U.S. government disclosed additional details Thursday on the agreement between the IRS and immigration enforcement authorities to share confidential tax return information, including who had necessary permissions to access the disclosures, following a D.C. federal judge's order in a lawsuit seeking to end the interagency data sharing.

  • September 18, 2025

    Extending ACA Subsidies Would Cost $350M, CBO Says

    Extending pandemic-era enhancements to premium tax credits that subsidize marketplace health plans would increase the deficit by $350 million by 2035, though it would also increase the number of people with health insurance by 3.8 million, the Congressional Budget Office said Thursday.

  • September 18, 2025

    Halliburton Can Contest Rule On Settlement Tax Deductions

    Halliburton can continue challenging the legality of a U.S. Treasury Department regulation that denies tax deductions for settlement agreements, a Texas federal judge ruled, refusing to toss the company's claims connected to the deductibility of a $35 million payment to Nigeria's government.

  • September 18, 2025

    5th Circ. Won't Rehear Crypto Exec's IRS Summons Case

    The Fifth Circuit stood by its decision not to quash an IRS summons for a cryptocurrency executive's bank records, rejecting his request to reconsider its finding that he must wait until the federal government decides whether to bring legal proceedings against him before challenging a lower court's ruling.

  • September 18, 2025

    IRS Leaked Private Info To News Outlets, Agency Official Says

    An IRS official serving as head of the agency's Large Business and International Division who was placed on leave accused the agency of unlawfully leaking information on her employment status to news outlets including Fox News and Bloomberg, according to a complaint filed Thursday in D.C. federal court.

  • September 17, 2025

    Tribal Members Tell 9th Circ. Tariff Suit Belongs In Fed. Court

    Counsel for members of the Blackfeet Nation tribe told the Ninth Circuit on Wednesday their suit challenging President Donald Trump's emergency tariffs should stay in federal district courts, where constitutional and congressional claims over tribal commerce must be heard.

  • September 17, 2025

    Democrats Push Wealth Tax Targeting Billionaires' Assets

    Billionaires would pay higher taxes on their unrealized gains from property, stocks and other valuable assets under legislation reintroduced Wednesday by Senate Finance Committee ranking member Ron Wyden and other congressional Democrats.

  • September 17, 2025

    House Panel OKs Bill To Expand Tax Court's Subpoena Power

    The House Ways and Means Committee unanimously approved legislation Wednesday that would grant the U.S. Tax Court the power to issue subpoenas without connection to a scheduled hearing and apply mandatory recusal rules to its judges.

  • September 17, 2025

    IRS-ICE Pact Allows For Mass Tax Data Swaps, DC Circ. Told

    An information sharing agreement between the IRS and immigration enforcement agencies allows for disclosure of confidential tax information on a mass scale, as evidenced by an IRS official's declaration in a taxpayer group's suit, immigration advocacy groups challenging the agreement told the D.C. Circuit on Wednesday.

  • September 17, 2025

    Partners Barred From Fighting Deal In $54M Easement Suit

    Dozens of investment partners were barred from challenging a settlement with the IRS over their disputed $54 million conservation easement deduction under a U.S. Tax Court ruling Wednesday that found they waited until the last minute and didn't show why they should be allowed to participate in proceedings.

  • September 17, 2025

    Spencer Fane Adds Corporate, RE Attys In The Midwest

    Spencer Fane LLP announced the addition of two new attorneys in the Midwest this week — a partner joining its corporate and business transactions group and a counsel joining its real estate group.

  • September 17, 2025

    11th Circ. Finds Couple On Hook For Penalty On Back Taxes

    A couple who owed $1.7 million in back taxes is on the hook for a penalty after the Eleventh Circuit rejected their dual claims that an Internal Revenue Service supervisor failed to correctly approve the penalty and that U.S. Tax Court judges have unconstitutional job protections.

  • September 17, 2025

    IRS Spent $40M On Outdated Computer Systems, TIGTA Says

    A decade-old plan at the Internal Revenue Service to consolidate dozens of computer systems has made little progress, the Treasury Inspector General for Tax Administration said Wednesday, reporting that the agency spent nearly $40 million last year on maintaining outdated systems.

  • September 16, 2025

    $300M Hyatt Rewards Tax Ruling Criticized By 7th Circ. Judge

    A Seventh Circuit judge took issue Tuesday with a U.S. Tax Court's finding that Hyatt should report $300 million in rewards program fund revenue, saying the decision seemed to focus on a factor that was shot down by decades-old legal precedent.

  • September 16, 2025

    Avalara Investors' Claims Pass Muster After 9th Circ. Revival

    A Washington federal judge has allowed a proposed class action to proceed accusing tax software company Avalara Inc. of misleading investors ahead of an $8.4 billion deal to take the company private, but said the suit failed to adequately allege negligence by individual board members, giving investors one week to amend those claims.

  • September 16, 2025

    Tax-Exempt Hospitals Face Financial Duress, Panel Hears

    The nation's nonprofit hospitals are under growing financial stress due to cutbacks in federal funding, an aging population and unnecessary spending on programs unrelated to providing healthcare to their communities, industry experts told lawmakers Tuesday at a congressional hearing.

  • September 16, 2025

    Tax Court's Petition Deadline Is Flexible, 1st Circ. Told

    A taxpayer advocacy group urged the First Circuit on Tuesday to become the fourth appellate court to find that the deadline for filing a petition in the U.S. Tax Court can be extended to create fairness, arguing that the deadline is not a jurisdictional bar.

Expert Analysis

  • How Energy Cos. Can Prepare For Potential Tax Credit Cuts

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    The Senate Finance Committee's version of the One Big Beautiful Bill act would create a steep phaseout of renewable energy tax credits, which should prompt companies to take several actions, including conduct a project review to discern which could begin construction before the end of the year, say attorneys at Husch Blackwell.

  • DOJ Has Deep Toolbox For Corporate Immigration Violations

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    With the U.S. Department of Justice now offering rewards to whistleblowers who report businesses that employ unauthorized workers, companies should understand the immigration enforcement landscape and how they can reduce their risk, say attorneys at McDermott.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.

  • Del. Dispatch: General Partner Discretion In Valuing Incentives

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    In Walker v. FRP Investors, the Delaware Court of Chancery recently held that the general partner of a limited partnership breached its obligations when determining the threshold value of newly issued incentive units, highlighting the court's willingness to reconstruct what a reasonable determination of value by a general partner should have been, say attorneys at Fried Frank.

  • Move Beyond Surface-Level Edits To Master Legal Writing

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    Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.

  • 9th Circ. Has Muddied Waters Of Article III Pleading Standard

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    District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.

  • Steps For Universities To Pass Tax-Exempt Test Amid Scrutiny

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    After decades of a quiet governmental acceptance of tax-exempt status, universities are facing unprecedented and public pressure to defend themselves, and must consider how to protect this valuable status, say attorneys at Eversheds Sutherland.

  • Tax Court Ruling Sets High Bar For Limited Partner Exception

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    The U.S. Tax Court’s recent decision in Soroban Capital Partners v. Commissioner endorsed the IRS’ use of functional analysis to determine whether the limited partner exception applied for taxation under the Self-Employed Contributions Act, highlighting the intense factual analysis that will occur during audits, says Erin Hines at Akerman.

  • How AI May Reshape The Future Of Adjudication

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    As discussed at a recent panel at Texas A&M, artificial intelligence will not erase the human element of adjudication in the next 10 to 20 years, but it will drive efficiencies that spur private arbiters to experiment, lead public courts to evolve and force attorneys to adapt, says Christopher Seck at Squire Patton.

  • When Legal Advocacy Crosses The Line Into Incivility

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    As judges issue sanctions for courtroom incivility, and state bars advance formal discipline rules, trial lawyers must understand that the difference between zealous advocacy and unprofessionalism is not just a matter of tone; it's a marker of skill, credibility and potentially disciplinary exposure, says Nate Sabri at Perkins Coie.

  • Attacks On Judicial Independence Tend To Manifest In 3 Ways

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    Attacks on judicial independence now run the gamut from gross (bald-faced interference) to systemic (structural changes) to insidious (efforts to undermine public trust), so lawyers, judges and the public must recognize the fateful moment in which we live and defend the rule of law every day, says Jim Moliterno at Washington and Lee University.

  • Increased Tariffs Create Opportunity To Protect IP Rights

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    Heightened tariffs on certain foreign imports have created operational and fiscal challenges for companies, but the corresponding increase in customs inspections could offer a silver lining of more consistent enforcement against counterfeit and infringing goods, says Andraya Pulaski Brunau at Day Pitney.

  • Dissecting House And Senate's Differing No-Tax-On-Tips Bills

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    Employers should understand how the House and Senate versions of no-tax-on-tips bills differ — including in the scope of related deductions and reporting requirements — to meet any new compliance obligations and communicate with their employees, say attorneys at Greenberg Traurig.

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