Federal

  • March 25, 2025

    EU Wants Timeline For Blacklisted US Territories' Data Swaps

    The European Union asked the U.S. to provide a concrete timeline for when it will set up a framework to begin automatic exchanges of information with three territories on the bloc's blacklist for uncooperative tax jurisdictions — the U.S. Virgin Islands, Guam and American Samoa — according to a letter released Tuesday.

  • March 25, 2025

    Carlton Fields Adds Former Tax Law Professor In Atlanta

    Carlton Fields has brought on a former tenured professor at Georgia State University College of Law to its team in Atlanta, strengthening its tax and business transactions practices with an attorney experienced in nonprofit law, tax and business matters, the firm announced Tuesday.

  • 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

    These 3 GOP Budget Questions Will Shape TCJA Talks

    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.

  • 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 24, 2025

    Justices Won't Hear Peanut Truck Co.'s Excise Tax Case

    The U.S. Supreme Court said Monday it will not hear a Georgia company's case arguing the IRS wrongly denied it an excise tax exemption for the special trucks it makes for peanut farming, letting stand an Eleventh Circuit ruling.

  • 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 21, 2025

    Fed. Circ. Backs Actavis' $12M Patent Suit Cost Deduction

    Drugmaker Actavis can take a $12 million tax deduction for money it spent fending off lawsuits while securing approval to sell generic birth control and other drugs, the Federal Circuit ruled Friday, affirming the U.S. Court of Federal Claims' decision that the costs were deductible as ordinary business expenses.

  • 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.

Expert Analysis

  • 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.

  • Terraform Case May Be Bellwether For Crypto Enforcement

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    The prosecution of crypto company Terraform Labs and its CEO, Do Kwon, offers a unique test of the line between lawful and unlawful conduct in digital transactions, and the Trump administration’s posture toward the case will provide clues about its cryptocurrency enforcement agenda in the years to come, say attorneys at Brooks Pierce.

  • How Law Firms Can Counteract The Loneliness Epidemic

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    The legal industry is facing an urgent epidemic of loneliness, affecting lawyer well-being, productivity, retention and profitability, and law firm leaders should take concrete steps to encourage the development of genuine workplace connections, says Michelle Gomez at Littler and Gwen Mellor Romans at Herald Talent.

  • Texas Fraud Case Shows Dangers Of Faulty Crypto Reporting

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    The recent sentencing of a man who failed to properly report capital gains from bitcoin sales is a reminder that special attention must be given to the IRS' reporting requirements in order to stay out of the government's crosshairs, says Saverio Romeo at Fox Rothschild.

  • Potential Impacts Of IRS' $1M Affiliate Pay Deduction Cap

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    If finalized, a recent Internal Revenue Service proposal expanding Section 162(m) of the Internal Revenue Code to include the highly compensated employees of affiliates would make tracking which executives may be subject to the limit from year to year far more complex, say attorneys at Debevoise.

  • 5 Keys To Building Stronger Attorney-Client Relationships

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    Attorneys are often focused on being seen as the expert, but bonding with clients and prospects by sharing a few key personal details provides the basis for a caring, trusted and profoundly deeper business relationship, says Deb Feder at Feder Development.

  • Notable Q4 Updates In Insurance Class Actions

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    In a continuation of trends in property and casualty insurance class actions, last quarter insurers struggled with defending the merits and class certification of sales tax and fee suits, and labor depreciation cases, but succeeded in dismissing privacy class actions at the pleading stages, says Mathew Drocton at BakerHostetler.

  • Attorneys Must Act Now To Protect Judicial Independence

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    Given the Trump administration's recent moves threatening the independence of the judiciary, including efforts to impeach judges who ruled against executive actions, lawyers must protect the rule of law and resist attempts to dilute the judicial branch’s authority, says attorney Bhavleen Sabharwal.

  • Rethinking 'No Comment' For Clients Facing Public Crises

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    “No comment” is no longer a cost-free or even a viable public communications strategy for companies in crisis, and counsel must tailor their guidance based on a variety of competing factors to help clients emerge successfully, says Robert Bowers at Moore & Van Allen.

  • How Design Thinking Can Help Lawyers Find Purpose In Work

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    Lawyers everywhere are feeling overwhelmed amid mass government layoffs, increasing political instability and a justice system stretched to its limits — but a design-thinking framework can help attorneys navigate this uncertainty and find meaning in their work, say law professors at the University of Michigan.

  • Justices' Certiorari Denial Leaves Interstate Tax Questions

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    Since the U.S. Supreme Court recently declined to review a Philadelphia resident’s claim that her Delaware state income taxes should be credited against her city wage tax liabilities, constitutional questions about state and local tax distinctions linger, and some states may continue to apply Supreme Court precedent differently, say attorneys at Dentons.

  • Corp. Transparency Act's Future Under Treasury's Bessent

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    The Corporate Transparency Act’s ultimate fate faced uncertain terms at the end of 2024, but new U.S. Department of the Treasury Secretary Scott Bessent's statements and actions so far demonstrate that he does not intend to ignore the law, though he may attempt to make modifications, say attorneys at Taylor English.

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