Tax

October 22, 2025
Australia Issues Guidance For Minimum Tax Safe Harbor

Australia released guidance Wednesday detailing when companies can forgo detailed top-up tax calculations for a jurisdiction under a safe harbor for the 15% global minimum tax that is based on country-by-country reporting.
October 22, 2025
US Among Few Places With Amount B Rules, OECD Reports

The U.S. is a significant exception to a swath of countries, including China, Japan and the U.K., that lack domestic rules allowing companies to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, the OECD reported Wednesday.
October 22, 2025
Tax Court Judge Warns Against Unchecked AI Use In Filings

A U.S. Tax Court judge cautioned attorneys Wednesday against relying on artificial intelligence to write filings without verifying the information it generates, saying recent "unfortunate incidents" have prompted the court to double down on accuracy in using such tools.
October 22, 2025
'The Right Facts' Can Reduce Cos.' Tariff Impacts, Atty Says

Multinational companies with U.S. distributors that typically bear fewer business risks and earn low profit margins may be able to mitigate the effect of U.S. tariffs on their business as a whole by having a foreign principal bear the tariff costs, an attorney said Wednesday.
October 22, 2025
COST Urges Ky. Justices To Reject Walgreens' Tax Valuations

Kentucky's Supreme Court should reverse an appeal court's ruling finding that a local assessor correctly took above-market contract rents into consideration when valuing several Walgreen store properties, the Council on State Taxation said, because it unfairly raised their assessed values.
October 22, 2025
Presidential Firing Limits Fight Builds At High Court

The ousted U.S. Merit Systems Protection Board chair has encouraged the U.S. Supreme Court to include a caveat for "legislative courts" if it overturns precedent that empowers Congress to limit the president's authority to fire certain agency officials, but opponents of independent agencies want a clean break from the status quo.
October 22, 2025
Trade Court OKs $235K Tax Bill On Korean Soju Imports

South Korean alcoholic beverages were improperly classified upon entering the U.S., and U.S. Customs and Border Protection correctly calculated a nearly $235,000 bill in unpaid federal excise taxes plus interest, according to the U.S. Court of International Trade.
October 22, 2025
Widow Not Liable For Husband's Tax Debt, 4th Circ. Told

An 80-year-old widow whose husband was imprisoned after hiding more than $20 million from the IRS told the Fourth Circuit that he was "abusive and controlling" and that she shouldn't have to pay the millions of dollars they jointly owe, despite contrary claims by the government.
October 22, 2025
NY Bill Seeks Clean Energy Payment Exemption For Tax Caps

New York would exempt payments in lieu of taxes for renewable energy projects from local governments' property tax cap calculations under a bill introduced in the state Assembly.
October 21, 2025
Partnership Deadline To Dispute IRS Is Fixed, Tax Court Says

A deadline to petition the U.S. Tax Court to challenge IRS adjustments to partnership returns is effectively fixed and cannot be extended, the court said Tuesday in a reviewed decision that denied an Alabama LLC's late bid to restore a $46 million deduction for donating to charity.
October 21, 2025
Discovery Against Gem Company Halted In Malawi's Tax Probe

Malawi's government can no longer proceed with discovery against a gemstone company that partnered with a mining outfit the country claims evaded billions of dollars in taxes and royalties on exported rubies and sapphires, a Washington federal judge ruled, vacating his own order.
October 21, 2025
CPA Admits $1.7M Tax Fraud, Pandemic Loan Charges

A Massachusetts certified public accountant has agreed to plead guilty to failing to disclose to the IRS nearly $1.7 million in off-the-books compensation to an employee and making false certifications to obtain pandemic relief loans.
October 21, 2025
Medtronic Says 8th Circ. Wrongly Tossed Tax Court's Method

The Eighth Circuit's rejection of the U.S. Tax Court's latest ruling on the pricing of Medtronic intangibles placed unnecessary restrictions on the court's unspecified method addressing such assets transferred to Puerto Rico, the company argued as it asked the circuit court to rethink its decision.
October 20, 2025
NY AG Reaches Deal With Accounting Firm Over Data Breaches

A certified public accounting firm has agreed to pay $60,000 and improve its data security to resolve the New York attorney general's claims that it failed to adequately protect unencrypted Social Security numbers and other personal information swept up in a pair of data breaches or swiftly notify affected clients.
October 20, 2025
Tax Pros Seek Clarity In Energy Supplier Certification Rules

The U.S. Treasury Department should clarify how developers can demonstrate new supplier certification compliance for some clean energy tax credits retooled by the Republican budget law, practitioners said Monday, noting uncertainty over what information could suffice under new restrictions on certain foreign suppliers.
October 20, 2025
Tax Startup CEO Swindled $13M From Investors, SEC Says

The CEO of a defunct tax-compliance startup lied to investors as she raised $13 million for her company, overstating its revenues by almost 900 times and falsely claiming she was a certified public accountant, the U.S. Securities and Exchange Commission said Monday in California federal court.
October 20, 2025
Emergency Tariffs Unlawfully Unprecedented, Justices Told

The International Emergency Economic Powers Act has never been used until President Donald Trump to impose tariffs, and nowhere does the law provide that explicit authority, a dozen states, several small businesses and a pair of Illinois toymakers told the U.S. Supreme Court Monday.
October 20, 2025
Justices Won't Review Repeat Indictment For Medicare Fraud

The U.S. Supreme Court let stand Monday the repeat indictment of a health clinic manager for what the Second Circuit called a massive, yearslong scheme to submit false claims to Medicare and Medicaid, effectively rejecting the manager's claims that his original trial was irreparably delayed.
October 17, 2025
Arson, Stalking Claims Not Defamatory, NC Biz Court Rules

A Virginia couple has lost their bid for a pretrial win on claims their former friends defamed them online, with a North Carolina Business Court judge finding the posts weren't defamatory and their identities couldn't otherwise be easily deduced.
October 17, 2025
NM Medical Cannabis Co. Tells Tax Court 280E Does Not Apply

A New Mexico medical marijuana company said Friday that a federal policy barring cannabis enterprises from taking ordinary business deductions should not apply, and the company is entitled to a refund for overpayment.
October 17, 2025
3rd Circ. Won't Rethink IRS Collections For Preparer Fraud

The Third Circuit declined Friday to reconsider a panel decision allowing the IRS to pursue a woman's unpaid taxes more than 20 years later — well after the normal three-year deadline — because her return preparer committed fraud on her filings without her knowledge.
October 17, 2025
Georgia Justices Affirm Stormwater Charge Is Fee, Not Tax

A stormwater utility charge levied by a local government in Georgia is a fee, not a tax, the state Supreme Court said, upholding a trial court's finding that the charge did not violate the state constitution's uniformity provision on property taxation.
October 17, 2025
Federal Courts To Scale Back Operations Amid Shutdown

The federal court system has run out of money and will scale back operations beginning Monday as a result of the ongoing government shutdown, possibly leading to case delays.
October 17, 2025
UN Shipping Agency Delays Carbon Price Opposed By US

The United Nations' shipping agency agreed Friday to postpone for one year its plan to introduce a global carbon price, which the U.S. government opposes, having called it a "global carbon tax."
October 17, 2025
Covington Adds Former IRS Special Counsel In DC

Covington & Burling LLP has grown its tax practice in Washington, D.C., with the addition of a former special counsel in the Office of Chief Counsel at the Internal Revenue Service.

Editor's Picks

Blockchain Tech May Present New Transfer Pricing Challenges

Companies that develop blockchain systems to digitally record transactions may face difficulties when valuing intangibles tied to the decentralized and highly varied technology, creating novel transfer pricing issues for multinational corporations that create their own blockchain networks.
Trump-Era Tariff Angst Hasn't Gone Away Under Biden

The early days of the Biden administration have been relatively quiet on the trade front, but importers have nevertheless found themselves in the throes of a familiar battle: pleading with the government to hold off on tariffs in a heated trade dispute.
3 Major Implications For States In Biden's Tax Plans

President Joe Biden's sweeping tax changes proposed to pay for trillions in infrastructure spending would significantly alter the way the federal government taxes corporations, leaving states, for the second time in four years, to decide if and how to conform. Here Law360 presents three considerations for states in the president's tax proposals.

Expert Analysis

Opinion

IRS Shutdown Backlog May Trigger Collection, Refund Chaos

As the IRS continues to send automated collection notices amid the ongoing federal government shutdown, a mounting backlog of unprocessed refunds, collections filings and mail is causing problems for taxpayers that will continue even after the shutdown ends, says Meeren Amin at Fox Rothschild.
SDNY OpenAI Order Clarifies Preservation Standards For AI

The Southern District of New York’s recent order in the OpenAI copyright infringement litigation, denying discovery of The New York Times' artificial intelligence technology use, clarifies that traditional preservation benchmarks apply to AI content, relieving organizations from using a “keep everything” approach, says Philip Favro at Favro Law.
Opinion

High Court, Not A Single Justice, Should Decide On Recusal

As public trust in the U.S. Supreme Court continues to decline, the court should adopt a collegial framework in which all justices decide questions of recusal together — a reform that respects both judicial independence and due process for litigants, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.
Series

Traveling Solo Makes Me A Better Lawyer

Traveling by myself has taught me to assess risk, understand tone and stay calm in high-pressure situations, which are not only useful life skills, but the foundation of how I support my clients, says Lacey Gutierrez at Group Five Legal.
Series

Law School's Missed Lessons: Client Service

Law school teaches you how to interpret the law, but it doesn't teach you some of the key ways to keeping clients satisfied, lessons that I've learned in the most unexpected of places: a book on how to be a butler, says Gregory Ramos at Armstrong Teasdale.
Series

Adapting To Private Practice: 3 Tips On Finding The Right Job

After 23 years as a state and federal prosecutor, when I contemplated moving to a law firm, practicing solo or going in-house, I found there's a critical first step — deep self-reflection on what you truly want to do and where your strengths lie, says Rachael Jones at McKool Smith.
Series

Painting Makes Me A Better Lawyer

Painting trains me to see both the fine detail and the whole composition at once, enabling me to identify friction points while keeping sight of a client's bigger vision, but the most significant lesson I've brought to my legal work has been the value of originality, says Jana Gouchev at Gouchev Law.
Compliance Pointers Amid Domestic Terrorism Clampdown

A recent presidential memorandum marks a shift in federal domestic-terrorism enforcement that should prompt nonprofits to enhance diligence related to grantees, vendors and events, and financial institutions to shore up their internal resources for increased suspicious-activity monitoring and reporting obligations, say attorneys at Morgan Lewis.
Trump Tax Law Has Mixed Impacts On Commercial Real Estate

The One Big Beautiful Bill Act brings sweeping changes to the real estate industry — and while the permanency of opportunity zones and bonus depreciation creates predictability for some taxpayers, sunsetting incentives for renewable energy projects will leave others with hard choices, says Jordan Metzger at Cole Schotz.
Protecting Sensitive Court Filings After Recent Cyber Breach

In the wake of a recent cyberattack on federal courts' Case Management/Electronic Case Files system, civil litigants should consider seeking enhanced protections for sensitive materials filed under seal to mitigate the risk of unauthorized exposure, say attorneys at Redgrave.
Series

Judging Figure Skating Makes Me A Better Lawyer

Judging figure skating competitions helps me hone the focus, decisiveness and ability to process complex real-time information I need in court, but more importantly, it makes me reengage with a community and my identity outside of law, which, paradoxically, always brings me back to work feeling restored, says Megan Raymond at Groombridge Wu.
What Ethics Rules Say On Atty Discipline For Online Speech

Though law firms are free to discipline employees for their online commentary about Charlie Kirk or other social media activity, saying crude or insensitive things on the internet generally doesn’t subject attorneys to professional discipline under the Model Rules of Professional Conduct, says Stacie H. Rosenzweig at Halling & Cayo.
2 Rulings Highlight IRS' Uncertain Civil Fraud Penalty Powers

Conflicting decisions from the U.S. Tax Court and the Northern District of Texas that hinge on whether the IRS can administratively assert civil fraud penalties since the U.S. Supreme Court’s 2024 decision in SEC v. Jarkesy provide both opportunities and potential pitfalls for taxpayers, says Michael Landman at Bird Marella.
Junior Attys Must Beware Of 5 Common Legal Brief Mistakes

Excerpt from Practical Guidance

Junior law firm associates must be careful to avoid five common pitfalls when drafting legal briefs — from including every possible argument to not developing a theme — to build the reputation of a sought-after litigator, says James Argionis at Cozen O'Connor.
Digital Asset Report Opens Doors For Banks, But Risks Linger

A recent report from a White House working group discussing digital asset market structure signals how banks may elect to expand into digital asset custody, trading and related services in the years ahead, but the road remains layered with challenges, say attorneys at Foley & Lardner.