Federal

  • March 24, 2025

    IRS Abused Its Power In Levy Suit, Justices Told

    A New Jersey woman should be allowed to continue challenging her tax debt in a property seizure hearing after the IRS withheld her tax refunds and dropped its levy pursuit, business and tax groups told the U.S. Supreme Court on Monday, saying the agency had abused its power.

  • March 24, 2025

    IRS Underreported Direct File Costs By $8.8M, TIGTA Says

    The Internal Revenue Service's reported $24.6 million costs for the Direct File pilot program didn't include an estimated $8.8 million incurred by the Office of Management and Budget and the agency's credential service provider, according to the Treasury Inspector General for Tax Administration.

  • March 24, 2025

    McDermott Hires Skadden Partner To Lead London Tax Office

    McDermott Will & Emery LLP announced Monday that it has chosen a former Skadden Arps Slate Meagher & Flom LLP partner to serve as the new leader of the firm's U.K. tax office in London.

  • March 24, 2025

    Burden Of Proof Is IRS' For $2.3M Bill, Kyocera Tells Tax Court

    The Internal Revenue Service should bear the burden of proof in making adjustments to an amended return filed by electronics-maker Kyocera, the company argued as it urged the U.S. Tax Court to review an IRS notice saying the company owes $2.3 million for 2018.

  • March 24, 2025

    Trump Asks High Court To Halt Fed. Workers' Reinstatement

    The Trump administration asked the U.S. Supreme Court on Monday to pause a California federal court order reinstating tens of thousands of probationary federal workers who were fired from six agencies, arguing the band of nonprofit groups that obtained the order have no standing to challenge the firings.

  • March 24, 2025

    FinCEN Exempts US Businesses From Disclosure Rules

    The U.S. Department of the Treasury's financial crimes unit issued interim final rules that exempt domestic businesses from contested reporting regulations, which the department had previously signaled it would narrow to include only foreign companies registered stateside.

  • March 22, 2025

    Up Next At High Court: Non-Delegation & Clean Air Fights

    The U.S. Supreme Court will return to the bench Monday to hear arguments in a dispute that could revive a long-dormant separation of powers principle and trigger a regulatory power shift. 

  • March 21, 2025

    Fla. Tax Preparer Sentenced To Prison For $20M Fraud

    A Miami-area tax preparer was sentenced to nearly five years in prison Friday after admitting to filing thousands of individual tax returns wrongly claiming energy credits, resulting in a $20 million loss for the Internal Revenue Service, according to the U.S. Attorney's Office for the Southern District of Florida.

  • March 21, 2025

    'Not Mistake-Proof': College Can Try To Recoup Tax Penalties

    A community college can proceed with its suit seeking a refund of tax penalties for failing to file wage statements for nearly all its employees, a Michigan federal judge ruled Friday, saying the school didn't have to meet a "mistake-proof" standard to argue it should be excused from the fines.

  • March 21, 2025

    Groups Can Probe Treasury's Cooperation With DOGE

    A Washington, D.C., federal judge let two unions and a retirees group look into any steps the U.S. Secretary of the Treasury took to give the Department of Government Efficiency access to Treasury's computer systems, saying she needs the information to evaluate the action's lawfulness.

  • March 21, 2025

    Boutique Firm Accuses IRS Of Illegally Enforcing Payroll Tax

    A consumer-protection boutique law firm accused the IRS of illegally enforcing payroll taxes while delaying the processing of pandemic-era employee retention tax credits, which the firm claimed would have helped with compliance, according to a complaint in Connecticut federal court.

  • March 21, 2025

    Ex-UBS North America CEO Agrees To $4.9M FBAR Judgment

    The former North American CEO for Swiss bank UBS on Friday agreed to a $4.9 million judgment to end claims that he failed to file timely or accurate foreign bank account reports with the Internal Revenue Service between 2003 and 2013.

  • March 21, 2025

    Taxation With Representation: Cravath, Paul Weiss, Cooley

    In this week's Taxation With Representation, Google acquires Wiz, QXO Inc. acquires Beacon Roofing Supply, and the Boston Celtics are bought by a group led by private equity firm co-founder William Chisholm.

  • March 20, 2025

    IRS SALT Cap Workaround Rule Unlawful, 2nd Circ. Told

    The Internal Revenue Service unlawfully created a rule prohibiting workarounds to the federal cap on state and local tax deductions, a New Jersey deputy attorney general told a Second Circuit panel Thursday, asking the appellate judges to overturn a lower court ruling that upheld the rule.

  • March 20, 2025

    Frost Brown Adds Former Houston City Atty To Finance Team

    Frost Brown Todd LLP announced that it has hired an attorney from the ranks of Houston's city government to strengthen its public finance group, adding his expertise in state and local government operations, taxation and economic development.

  • March 20, 2025

    Texas Law Firm Fights Denial Of Captive Insurance Deduction

    A Texas law firm asked the U.S. Tax Court to find that the IRS improperly denied it a $621,000 deduction for payments it made to a captive insurance company, saying the agency wrongly accused the firm of participating in an abusive insurance arrangement.

  • March 20, 2025

    PwC, Deloitte, KPMG Back Coke In $2.7B Dispute In 11th Circ.

    Three major accounting firms have asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming the IRS' change to Coca-Cola's intercompany pricing, which led to a $2.7 billion tax bill, arguing the agency's conduct was unsupported and unjustified.  

  • March 20, 2025

    90% Of Crypto Sellers Conceal Income, Danish Data Shows

    Danish Tax Agency data shows more than 90% of cryptocurrency sellers don't report that income and that many have shifted to foreign platforms to avoid domestic reporting rules, the EU Tax Observatory said in a working paper, suggesting international coordination is essential to tax crypto effectively.

  • March 20, 2025

    Sisters Say Bad Advice Led To Skipped $14M Estate Tax Filing

    Two sisters overseeing their brother's $13.7 million estate told a Rhode Island district court that they shouldn't have to pay hundreds of thousands of dollars in tax penalties for missing the deadline to file an estate tax return because they were reasonably relying on advice from their attorney.

  • March 19, 2025

    IRS Hunter Biden Whistleblower Named Deputy Criminal Chief

    An Internal Revenue Service special agent who accused the U.S. Department of Justice of mishandling an investigation into former President Joe Biden's son has been named deputy chief in the IRS Criminal Investigation division, the agency said Wednesday.

  • March 19, 2025

    Coke's $2.7B Tax Bill Arbitrary, Business Groups Tell 11th Circ.

    Three industry groups asked the Eleventh Circuit to reverse a U.S. Tax Court decision affirming that the Internal Revenue Service could raise Coca-Cola's taxes by $2.7 billion, saying in friend-of-the-court briefs that the IRS acted arbitrarily in hiking the Atlanta-based beverage giant's tax liability.

  • March 19, 2025

    Tax Court Upholds Penalty On Early Retirement Withdrawal

    A Florida man should have included his early withdrawal of roughly $57,000 from his retirement account in that year's tax return, the U.S. Tax Court said Wednesday, also agreeing that the agency was correct to assess an accuracy-related penalty against him.

  • March 19, 2025

    Technical, Policy Questions Still Swirl Around Amount B

    U.S. multinational corporations have welcomed the option of a simplified transfer pricing approach under an international tax framework known as Amount B, but uncertainties linger about how the rules will ultimately shake out on a technical level both domestically and globally.

  • March 19, 2025

    7th Circ. Orders Tax Court To Clarify ESOP Suit Dismissal

    The Seventh Circuit axed the U.S. Tax Court's dismissal of a transit company's suit over an employee stock ownership plan, saying the lower court must specify that it lacked the authority to review the case because it was filed before the IRS completed an exam.

  • March 19, 2025

    6th Circ. Says Pharmacist Doesn't Owe Tax On Forfeited IRA

    A pharmacist doing time for running a Kentucky pill mill doesn't owe taxes on his forfeited retirement account, the Sixth Circuit ruled Wednesday, reversing a U.S. Tax Court decision that upheld what the appeals court described as an unexpected punishment.

Featured Stories

  • These 3 GOP Budget Questions Will Shape TCJA Talks

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    As Congress barrels toward negotiations over renewing expiring provisions of the Tax Cuts and Jobs Act, Republican lawmakers are faced with several major budgetary decisions that will govern which proposals can be included in the bill they send to President Donald Trump's desk.

  • Technical, Policy Questions Still Swirl Around Amount B

    Natalie Olivo

    U.S. multinational corporations have welcomed the option of a simplified transfer pricing approach under an international tax framework known as Amount B, but uncertainties linger about how the rules will ultimately shake out on a technical level both domestically and globally.

  • The Tax Angle: Lawmakers Huddle To Mull TCJA

    Stephen K. Cooper

    From a look at the three-day legislative retreat held by House Democrats to Ways and Means Republicans meeting behind closed doors to discuss the 2017 GOP tax overhaul, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

Expert Analysis

  • 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.

  • IRS Should Revise Overbroad Microcaptive Regs

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    Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.