Federal
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May 08, 2025
Hyatt's $300M From Reward Program Is Income, 7th Circ. Told
Hyatt Hotels should have to report nearly $300 million in revenue from a rewards program fund because it benefited from spending the money, including through advertising for its properties, the U.S. government told the Seventh Circuit on Thursday, defending a U.S. Tax Court ruling.
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May 08, 2025
NFTC Warns US Against Tariffs On Semiconductors, Pharma
The Trump administration should work to avoid using tariffs to address the perceived threat to national security caused by importing semiconductors and pharmaceuticals, the National Foreign Trade Council said, calling for extreme caution.
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May 08, 2025
Widow Says Husband's Estate Liable For $2M FBAR Fines
A nonagenarian widow told an Idaho federal court Thursday that her late husband's estate — not she — should be liable for more than $2 million in penalties for his unreported foreign accounts, calling the government's attempt to penalize her an unprecedented overreach.
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May 08, 2025
Milbank Hires King & Spalding Tax Planning Atty In DC
Milbank LLP has added a former King & Spalding LLP tax attorney as a partner in its global project, energy and infrastructure finance group in Washington, D.C.
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May 07, 2025
Bessent Defends Cuts To Community Fund Amid Scrutiny
U.S. Treasury Secretary Scott Bessent on Wednesday defended the Trump administration's proposal to significantly slash the fund that operates the new markets tax credit, which is meant to boost investment in poor communities, telling lawmakers that a new $100 million program would better support affordable financing in rural areas.
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May 07, 2025
Favorable Tax Cut Baseline Won't Fool Lenders, House Told
If Congress uses a current policy baseline to permanently extend the 2017 tax overhaul's provisions, it will be a red flag to institutional investors, such as hedge funds, mutual funds and endowments, panelists told the House Budget Committee on Wednesday.
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May 07, 2025
Tax Court Rejects Couple's Case For Lacking Evidence
A couple who challenged what the Internal Revenue Service said was their more than $650,000 in tax debt provided no evidence that the number was wrong, the U.S. Tax Court said in a bench opinion released Wednesday.
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May 07, 2025
11th Circ. Backs Frivolous Argument Ruling Against Teacher
A Georgia high school teacher who claimed that he didn't have to pay taxes on his salary and that income taxes are unconstitutional must pay $25,000 in court sanctions under an Eleventh Circuit ruling affirming a U.S. Tax Court decision.
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May 07, 2025
Don't Scrap US-China Tax Treaty, Biz Groups Tell Treasury
Business lobbying groups have urged the U.S. Treasury Department to reject the White House's plans to scrutinize the U.S.-China tax treaty, warning that scrapping the accord would lead to higher Chinese taxes on U.S. companies.
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May 07, 2025
Feds Seek 13 Years In Avenatti's California Resentencing
California federal prosecutors asked a judge Wednesday to sentence Michael Avenatti to 160 months in prison for tax fraud and stealing from clients, to be served atop the five-year term imposed in a pair of New York cases where Avenatti was convicted of trying to extort Nike Inc. and defrauding former client Stormy Daniels.
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May 07, 2025
Device Seller Asks For Probation In $2.4M Tax Evasion Case
The septuagenarian owner of a Florida medical device company who pled guilty to evading $2.4 million in taxes asked a federal district court Wednesday for his sentence to entail home probation and not prison, given his health challenges and payments he already made to the Internal Revenue Service.
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May 07, 2025
IRS To Open Applications For Low-Income Tax Clinic Grants
The Internal Revenue Service will begin accepting applications May 15 for its grant program for organizations providing tax services to low-income people or people who speak English as a second language, it announced Wednesday.
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May 06, 2025
Fed. Circ. Agrees Plane Taxability Patent Doesn't Fly
The Federal Circuit on Tuesday refused to revive an Ohio company's patent that covers using Federal Aviation Administration data to determine "the taxability status of aircraft," agreeing that it covered subject matter that isn't patentable.
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May 06, 2025
Military Moving-Cost Deduction Nixed For Civilian Contractor
A civilian contractor for the U.S. Air Force cannot deduct her moving expenses because she is not considered a member of the military for purposes of the deduction, the U.S. Tax Court said in a bench opinion released Tuesday.
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May 06, 2025
Actor Voight, Film Biz Adviser To Trump, Floats Tax Incentives
Actor Jon Voight, whom President Donald Trump tapped as an adviser on the Hollywood film industry, told Trump that tax incentives, international treaties and limited tariffs could revitalize production, while California Gov. Gavin Newsom separately floated a $7.5 billion federal film tax credit, according to statements shared Tuesday with Law360.
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May 06, 2025
Stationery Co. Fights Bid To Move Tariff Case To Trade Court
The U.S. Court of International Trade does not have exclusive jurisdiction to hear disputes over President Donald Trump's global tariffs, a stationery company told a Florida federal court Monday in opposing the administration's bid to transfer to the suit.
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May 06, 2025
IRS Narrows Benefit Plan Sponsors Subject To New Rules
The Internal Revenue Service on Tuesday narrowed the group of defined benefit plan sponsors that will be subject to certain requirements related to agency approval to use mortality tables that start in January.
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May 06, 2025
Bessent Eyes IRS' Technology Budget For Major Cuts
The Internal Revenue Service must cut its bloated technology budget and decrease the agency's overall spending, U.S. Treasury Secretary Scott Bessent told a House Appropriations panel Tuesday.
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May 06, 2025
Eversheds Sutherland Brings On EY Tax Pro In Atlanta
Eversheds Sutherland has added a former EY senior manager of international tax and transaction services to its Atlanta office, further strengthening its tax practice after adding a dozen tax controversy attorneys from Chamberlain Hrdlicka White Williams & Aughtry PC in March, the firm announced Tuesday.
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May 06, 2025
4th Circ. Seems Split On BofA's Post-Merger Tax Offset Claims
The Fourth Circuit seemed split Tuesday on whether Bank of America should be able to use its tax overpayments to offset interest on tax underpayments by companies that merged into it, with one judge pressing the government to respond to what he described as the bank's "common sense" argument in the $163 million case.
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May 05, 2025
Credit Suisse To Pay Feds $510.6M For Helping Hide Assets
Credit Suisse Services AG has agreed to shell out more than $510 million under agreements with federal prosecutors in which the company admitted to helping customers hide more than $4 billion from the IRS in hundreds of offshore accounts, the U.S. Department of Justice announced Monday.
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May 05, 2025
Feds Say Calif. Tribe's Challenge To Cig Ruling Is 'Fruitless'
The federal government is urging a California federal court not to pause a ruling affirming the Bureau of Alcohol, Tobacco, Firearms and Explosives' decision to place a native tribe on a noncompliance list over cigarette sales, saying the tribe shouldn't be able to upend the status quo as it pursues a "fruitless" appeal to the Ninth Circuit.
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May 05, 2025
Trump Seeks 100% Tariff On Foreign-Made Movies
President Donald Trump asked his administration to place a 100% tariff on foreign-made movies, with a spokesperson telling Law360 on Monday that a final decision on the plan hadn't been made.
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May 05, 2025
Minn. Tribe Looks To Weigh In On 3,000-Acre Land Trust Row
The Mille Lacs Band of Ojibwe has asked a Minnesota federal judge to let it file a friend of the court brief in a county's case claiming the U.S. government wrongly accepted more than 3,000 acres of land into trust for the tribe.
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May 05, 2025
Trump Admin Defends Tariff Power In Toy-Makers' Challenge
President Donald Trump's administration urged a D.C. federal court to deny a request by toy companies to halt global tariffs, arguing the government is authorized to impose trade measures under the International Emergency Economic Powers Act.
11th Circ. Judge Frowns On New Arguments In Easement Case
An Eleventh Circuit judge disapproved of a Georgia partnership raising new arguments on appeal as it pursues a tax deduction for a conservation easement donation, saying Thursday that perhaps "we wouldn't be here" if the partnership had argued the points before the lower court.
6th Circ. Skeptical Of US In Tax Court Deadline Case
Sixth Circuit judges expressed skepticism of the U.S. government's claim that the 90-day deadline to petition the U.S. Tax Court is inflexible, with one judge saying during oral arguments Wednesday in a woman's case challenging the rule that the U.S. Supreme Court seemed to back her.
Tax Court Erred In Slashing $23M Easement, 11th Circ. Told
A partnership told the Eleventh Circuit that the U.S. Tax Court erred in substantially reducing its claim to a $23 million conservation easement tax deduction, arguing the decision was tainted by error-riddled criteria used by the IRS to value the property.
11th Circ. Judge Frowns On New Arguments In Easement Case
An Eleventh Circuit judge disapproved of a Georgia partnership raising new arguments on appeal as it pursues a tax deduction for a conservation easement donation, saying Thursday that perhaps "we wouldn't be here" if the partnership had argued the points before the lower court.
6th Circ. Skeptical Of US In Tax Court Deadline Case
Sixth Circuit judges expressed skepticism of the U.S. government's claim that the 90-day deadline to petition the U.S. Tax Court is inflexible, with one judge saying during oral arguments Wednesday in a woman's case challenging the rule that the U.S. Supreme Court seemed to back her.
Tax Court Erred In Slashing $23M Easement, 11th Circ. Told
A partnership told the Eleventh Circuit that the U.S. Tax Court erred in substantially reducing its claim to a $23 million conservation easement tax deduction, arguing the decision was tainted by error-riddled criteria used by the IRS to value the property.
Featured Stories
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Tax Breaks For Offshore Production Could Thwart Tariffs' Goal
President Donald Trump has said that his wide-ranging tariffs will jump-start domestic industry and production, but an international tax policy created under the 2017 federal overhaul may undermine the goal of bringing manufacturing back to the U.S.
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Takeaways From Justices' Questioning In Tax Collection Suit
The U.S. Supreme Court heard oral arguments this past week in a nearly 11-year-old case that could redefine taxpayers' challenges of Internal Revenue Service determinations to collect tax debts. Here, Law360 examines tax practitioners' key takeaways from the justices' remarks.
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Bill To Ax Church Politics Ban Reignites Free-Speech Debate
More than a dozen congressional Republicans support what they characterize as free-speech legislation to overturn a 1954 tax law barring churches from endorsing candidates, despite warnings from some lawmakers and others that it could weaken church-state separation and flood politics with a new source of dark money.
Expert Analysis
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Crisis Management Lessons From The Parenting Playbook
The parenting skills we use to help our kids through challenges — like rehearsing for stressful situations, modeling confidence and taking time to reset our emotions — can also teach us the fundamentals of leading clients through a corporate crisis, say Deborah Solmor at the Wisconsin Alumni Research Foundation and Cara Peterman at Alston & Bird.
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Immunity Waiver Ruling A Setback For Ch. 7 Trustees
While governmental units should welcome the U.S. Supreme Court's recent decision in U.S. v. Miller restricting the reach of the Bankruptcy Code's sovereign immunity waiver, Chapter 7 trustees now have a limited ability to maximize bankruptcy estates, says Dan Prieto at Jones Day.
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Adapting To Private Practice: From NY Fed To BigLaw
While the move to private practice brings a learning curve, it also brings chances to learn new skills and grow your network, requiring a clear understanding of how your skills can complement and contribute to a firm's existing practice, and where you can add new value, says Meghann Donahue at Covington.
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Top 3 Litigation Finance Deal-Killers, And How To Avoid Them
Like all transactions, litigation finance deals can sometimes collapse, but understanding the most common reasons for failure, including a lack of trust or a misunderstanding of deal terms, can help both parties avoid problems, say Rebecca Berrebi at Avenue 33 and Boris Ziser at Schulte Roth.
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A 2-Step System For Choosing A Digital Asset Reporting Path
Under the Internal Revenue Service's new digital asset reporting regulation, each type of asset may have three potential reporting destinations, so a detailed testing framework can help to determine the appropriate path, says Keval Sonecha at Sonecha & Amlani.
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How Attys Can Use A Therapy Model To Help Triggered Clients
Attorneys can lean on key principles from a psychotherapeutic paradigm known as the "Internal Family Systems" model to help manage triggered clients and get settlement negotiations back on track, says Jennifer Gibbs at Zelle.
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3 Steps For In-House Counsel To Assess Litigation Claims
Before a potential economic downturn, in-house attorneys should investigate whether their company is sitting on hidden litigation claims that could unlock large recoveries to help the business withstand tough times, says Will Burgess at Hilgers Graben.
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IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement
Tax crimes are historically difficult to prosecute, but the Internal Revenue Services’ recent agreement with U.S. Immigration and Customs Enforcement to share taxpayer records of non-U.S. citizens could be used to enhance payroll tax-related enforcement against their employers, say attorneys at Holland & Knight.
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Adapting To Private Practice: From DOJ Enviro To Mid-Law
Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares their principles, values their experience and will invest in their transition, says John Cruden at Beveridge & Diamond.
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Legal Ethics Considerations For Law Firm Pro Bono Deals
If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.
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10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks
The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.
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Notable Q1 Updates In Insurance Class Actions
The first quarter of 2025 was filled with the refinement of old theories in the property and casualty space, including in vehicle valuation, time to seek appraisal and materials depreciation, says Mathew Drocton at BakerHostetler.
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The Benefits Of Aligning States On Legal Paraprofessionals
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.