Tax

  • November 03, 2025

    Eaton Debt Analysis Must Trace Distinct Steps, Tax Court Told

    An attorney for Eaton Corp. told the U.S. Tax Court on Monday that the interest rates and guarantee fees the company paid to its newly formed Irish parent in 2012 must be analyzed as a set of distinct steps, beginning with determining a standalone credit rating for the U.S. company — an analysis a government attorney said was "needlessly elaborate."

  • November 03, 2025

    Insurance Law Firm's Bid For $600K Biz Tax Refund Flops

    Washington appellate judges spurned a Pacific Northwest law firm's request for a roughly $600,000 tax refund on Monday, agreeing with state regulators that the firm owes business taxes on legal services for insurance clients when the litigation unfolded within the Evergreen State.

  • November 03, 2025

    'No Basis In Reality' In $10M Easement Claim, Tax Court Says

    A U.S. Tax Court judge rejected a partnership's claim that its donation of a conservation easement over 200 acres in Georgia was worth a $10 million tax deduction, saying in an opinion Monday that it "has no basis in reality."

  • 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

    US, China Agree To Cut Tariffs, Restrictions In Trade Truce

    The United States and China have agreed to a one-year suspension of certain tariffs, export controls and retaliatory trade restrictions, according to statements by the White House and China's Ministry of Commerce.

  • 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

    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

    5 Indicted In Germany In €188M VAT Fraud Scheme

    Five German residents have been indicted on charges related to their participation in a €188 million ($217 million) value-added tax fraud scheme, European Union authorities said Friday.

  • October 30, 2025

    Michigan Tax Foreclosure Deal At Risk As Deadline Looms

    Property owners on Wednesday asked a Michigan federal judge to undo the initial approval of a settlement reached with counties accused of illegally keeping the proceeds of tax-foreclosed home sales, saying the counties' delay in providing information will force claimants to miss a deadline to choose how they want to recover their share.

  • 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

    Defamation Litigation Roundup: Drake, IRS, Greenpeace

    In this month's review of defamation fights, Law360 highlights notable developments in California's anti-SLAPP law following a major Ninth Circuit opinion, as well as a decision — and appeal — in Drake's fight with his record label over Kendrick Lamar's diss track.

  • 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

    Lawmakers Slam Value-Based Patent Fee Proposal

    Six members of the U.S. House of Representatives wrote to U.S. Secretary of Commerce Howard Lutnick on Thursday expressing concern over the proposal to charge patent holders fees based on their patent's value, saying that will harm innovation and economic growth.

  • 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

    Mich. Cannabis Group Asks Judge To Block Wholesale Tax

    The Michigan Legislature willfully evaded the state's constitution by passing a 24% wholesale tax on cannabis without required three-fourths majorities, an industry group said, asking a state court to block the tax.

  • October 30, 2025

    Suspended NC Atty Fights Disbarment Bid Over Tax Issues

    A North Carolina attorney currently serving a five-year suspension for misconduct, including tax crimes and commingling funds in a client trust account, is fighting the state bar's appeal seeking to disbar him, telling the state's intermediate appeals court that his failure to withhold income taxes from his own wages is not a crime.

  • 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 30, 2025

    EU's Top Court Axes Dutch Co.'s Challenge Against Pillar 2

    The European Union's top court declined Thursday to revive a Dutch company's case against an EU directive that implements an international minimum tax agreement known as Pillar Two, holding that the business lacked standing to challenge the law.

  • October 30, 2025

    Tribal Business Owner Says Tariffs Violate 1855 Yakama Treaty

    A Yakama Indian tribe member is asking an Oregon federal court to block a series of tariffs issued by President Donald Trump, arguing that the orders violate a 19th century treaty that gives her the right to free trade.

Expert Analysis

  • From Clerkship To Law Firm: 5 Transition Tips For Associates

    Excerpt from Practical Guidance
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    Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.

  • Trump Tax Law's Most Consequential International Changes

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    The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.

  • Associates Can Earn Credibility By Investing In Relationships

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    As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.

  • Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling

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    The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.

  • NY Tax Talk: ALJ Vacancy, Online Sales, Budget

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    Among the most notable developments in New York tax law last quarter, an administrative law judge vacancy continued affecting taxpayers, a state court decision tested the scope of the Interstate Income Act, and Gov. Kathy Hochul signed the 2025-2026 fiscal budget containing key tax-related provisions, say attorneys at Eversheds Sutherland.

  • Series

    Quilting Makes Me A Better Lawyer

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    Turning intricate patterns of fabric and thread into quilts has taught me that craftsmanship, creative problem-solving and dedication to incremental progress are essential to creating something lasting that will help another person — just like in law, says Veronica McMillan at Kramon & Graham.

  • What 2 Profs Noticed As Transactional Law Students Used AI

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    After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.

  • Rebuttal

    BigLaw Settlements Should Not Spur Ethics Deregulation

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    A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.

  • 5 Ways Lawyers Can Earn Back The Public's Trust

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    Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.

  • Legal Jeopardy Looms Over Trump's Trade Negotiation Plans

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    Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.

  • Series

    Hiking Makes Me A Better Lawyer

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    On the trail, I have thought often about the parallels between hiking and high-stakes patent litigation, and why strategizing, preparation, perseverance and joy are important skills for success in both endeavors, says Barbara Fiacco at Foley Hoag.

  • Opportunity Zone Overhaul Is Good News For Investors

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    Recently enacted reforms making the qualified opportunity zone program permanent, restoring the basis step-up for capital gains and adding flexibility to the zone designation process enhance the program’s appeal for long-term investment, says Steven Hadjilogiou at McDermott.

  • What US-India Trade Deal Will Mean For Indian Pharma

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    Complicated by newly imposed tariffs from the U.S., the outcome of the U.S.-India trade talks is poised to reshape not just trade policy, but also the strategic alignment of the two countries' pharmaceutical ecosystems, says Jashaswi Ghosh at Holon Law Partners.

  • White House Report Strikes An Optimistic Note On Crypto

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    Taking seriously President Donald Trump's pledge to adopt a pro-innovation mindset toward digital assets and blockchain technologies, a recent benchmark White House report on crypto provides a comprehensive regulatory framework that takes into account the products' novel characteristics within the high-tech ecosystem, say attorneys at Davis Wright.

  • Series

    Law School's Missed Lessons: Negotiation Skills

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    I took one negotiation course in law school, but most of the techniques I rely on today I learned in practice, where I've discovered that the process is less about tricks or tactics, and more about clarity, preparation and communication, says Grant Schrantz at Haug Barron.

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