Federal

  • January 31, 2025

    The Tax Angle: TCJA Renewal Cost, ACA Credits, OMB Pick

    From a look at the budget impact of renewing the 2017 tax overhaul law to uncertainty surrounding the renewal of Affordable Care Act premium tax credits and the nomination of a new chief of the Office of Management and Budget, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • January 31, 2025

    Couple Can't Sue IRS Without First Paying Tax, 5th Circ. Says

    A couple who claimed they overpaid their taxes and should be allowed to sue the IRS for a refund must first pay the taxes the agency says are due, the Fifth Circuit ruled Friday, saying it was bound by U.S. Supreme Court precedent.

  • January 31, 2025

    Akin Hires Tax Pro From Cooley In London

    Akin Gump Strauss Hauer and Feld LLP announced Friday that a partner at Cooley LLP will join as a tax partner in Akin's London office later in 2025. 

  • February 14, 2025

    Law360 Seeks Members For Its 2025 Editorial Boards

    Law360 is looking for avid readers of our publications to serve as members of our 2025 editorial advisory boards.

  • January 31, 2025

    Goldstein Case Raises The Stakes For A DOJ Office In Tumult

    The bombshell tax-crimes case of U.S. Supreme Court lawyer Tom Goldstein landed at a U.S. Department of Justice outpost in Maryland that has been plagued in recent years by botched cases and internal strife — pitting a beleaguered U.S. attorney against a pair of former Donald Trump attorneys itching for a fight.

  • January 31, 2025

    Trump Funding Freeze Blocked As Court Doubts Reversal

    A Rhode Island federal judge on Friday issued a temporary restraining order barring the Trump administration from freezing spending on federal grant and aid programs, calling the move illegal and saying the issue was not mooted by a White House memo claiming the directive had been rescinded.

  • January 31, 2025

    Tax Group Of The Year: Sullivan & Cromwell

    Sullivan & Cromwell LLP's diverse tax practice went from strength to strength this year, from advising well-known companies like Boeing and Discover that inked multibillion-dollar deals to counseling industry leaders in shaking up their sectors, helping it earn a place among the 2024 Law360 Tax Groups of the Year.

  • January 31, 2025

    Taxation With Representation: Cravath, Gibson Dunn, Milbank

    In this week's Taxation with Representation, Eversource Energy sells Aquarion Water Co., Diversified Energy Partners acquires oil and gas company Maverick, Lantheus Holdings buys Evergreen Theragnostics, and NASCAR champion Jimmie Johnson becomes the majority owner in the Legacy Motor Club racing team.

  • January 31, 2025

    6th Circ. Affirms Pot Biz Owner's $2.8M Tax Restitution

    The owner of a medical marijuana dispensary who was sentenced to prison and ordered to pay $2.8 million in restitution to the IRS after being convicted of tax crimes failed to convince the Sixth Circuit that Congress lacked the power to tax his sales of the drug.

  • January 31, 2025

    Data Centers Blur Lines At BigLaw Firms

    The rise in complex, hybrid data center deals is increasingly calling for real estate, infrastructure and private equity attorneys to work together and, in some cases, to combine their practice groups.

  • January 31, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included final rules that target abusive tax avoidance by large partnerships using basis shifting, requiring partnerships to report certain transactions among related members.

  • January 30, 2025

    Retired Atty Says Schwab, Others Flubbed His Contributions

    A retired attorney said companies that managed his individual retirement plan, including Charles Schwab and Barnes & Thornburg LLP, hampered his tax savings by incorrectly classifying his pretax retirement contributions as posttax contributions, according to a lawsuit filed in an Indiana district court.

  • January 30, 2025

    IRS Allowed Summonses For Records In Foreign Assets Case

    A Georgia federal court gave the Internal Revenue Service the go-ahead to issue summonses for the records of a group of financial institutions that clients may have used to avoid taxes, the U.S. Department of Justice said Thursday.

  • January 30, 2025

    Tax Court OKs Penalty Sign-Off In $18M Easement Dispute

    An IRS agent complied with a requirement that her supervisor approve tax penalties she asserted against an Alabama partnership whose nearly $18 million deduction for a conservation easement donation was rejected by the agency, the U.S. Tax Court said Thursday.

  • January 30, 2025

    Tax Court OKs Levy Against Woman Who Didn't Back Up Args

    The Internal Revenue Service didn't act improperly when it upheld a levy against a California woman who owed tax debts for multiple years, the U.S. Tax Court determined Thursday, saying she routinely failed to back up her assertions.

  • January 30, 2025

    IRS Asked To Cut Forms For Tax-Exempt Groups' Int'l Deals

    Tax-exempt organizations shouldn't need to report transactions with foreign corporations or foreign partnerships if they don't hold a controlling interest in those entities, since the risk of unreported income is negligible, the American Institute of Certified Public Accountants told the IRS.

  • January 30, 2025

    Florida Salesman Evaded $2M In Tax Over 13 Years, Court Told

    A Florida salesman evaded nearly $2 million in taxes over more than a dozen years while earning more than $10 million by transferring his home and cash to his domestic partner and creating a nominee business, according to an indictment in Florida federal court.

  • January 30, 2025

    Crapo, Wyden Pitch Harsher Tax Pro Fines In IRS Revamp Bill

    The Internal Revenue Service would be required to simplify foreign bank account report compliance and increase civil and criminal penalties on tax professionals who deliberately harm their clients under draft legislation released Thursday by the Senate Finance Committee's top Democrat and Republican.

  • January 30, 2025

    New Penalty Rules Flawed, 5th Circ. Told In Microcaptive Row

    Treasury's new rules on supervisory approval of penalties are flawed and don't apply to a couple's suit challenging tax penalties and denied deductions related to microcaptive insurance companies they operated for a network of urgent care clinics, an attorney for the couple told the Fifth Circuit.

  • January 30, 2025

    Pillar 2 Should Live On Despite US Threats, Economists Say

    Nations worldwide should continue implementing the international minimum tax agreement known as Pillar Two despite recent threats from the U.S. government to retaliate against what it sees as discriminatory measures imposed on U.S. companies, a group of economists said.

  • January 30, 2025

    Tax Group Of The Year: Skadden

    Skadden Arps Slate Meagher & Flom LLP's tax practice advised on key deals and cases in 2024, including Mars Inc.'s $35.9 million acquisition of Kellanova and BlackRock Inc.'s $12.5 billion acquisition of Global Infrastructure Partners, landing it among the 2024 Law360 Tax Groups of the Year.

  • January 30, 2025

    SCOTUSblog Publisher Can't Shield Home From Forfeiture

    SCOTUSblog publisher Tom Goldstein won't be able to shield his Washington, D.C., residence from forfeiture by substituting various properties in South Carolina as he battles charges that he dodged taxes and used his law firm's money to pay off gambling debts.

  • January 30, 2025

    IRS Updates NDA Language To Include Anti-Gag Provisions

    The Internal Revenue Service has updated its nondisclosure agreement templates to include anti-gag provisions, following a review by the Treasury Inspector General for Tax Administration that found many NDAs lacked required references to whistleblower protections.

  • January 30, 2025

    Dechert's NY Office Adds Tax Pro From Milbank

    Dechert LLP said it has bolstered its global tax group by adding a former special counsel from Milbank LLP to the firm's New York office.

  • January 30, 2025

    IRS Missing Mark On Processing Paper Returns, GAO Says

    The Internal Revenue Service failed to hit its goal of processing paper returns for the 2024 tax filing season in an average of 13 days, instead taking 20, continuing a pattern of delays, the Government Accountability Office said Thursday.

Expert Analysis

  • How Associates Can Build A Professional Image

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    As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.

  • Navigating New Safe Harbor For Domestic Content Tax Credits

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    The U.S. Department of the Treasury’s recent notice simplifying domestic content calculations for certain solar, onshore wind and battery storage projects, which directly acknowledges the difficulty for taxpayers in gathering data to support a domestic content analysis, should make it easier to qualify additional domestic content bonus tax credits, say attorneys at A&O Shearman.

  • Firms Must Rethink How They Train New Lawyers In AI Age

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    As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.

  • 'Energy Communities' Update May Clarify Tax Credit Eligibility

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    A recent IRS notice that includes updated lists of locations where clean energy projects can qualify for additional tax credits — based 2023 unemployment data and placed-in-service dates — should help provide clarity regarding project eligibility that sponsors and developers need, say attorneys at Troutman Pepper.

  • Think Like A Lawyer: Always Be Closing

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    When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Attys Can Be Heroic Like Olympians

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    Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.

  • Lean Into The 'Great Restoration' To Retain Legal Talent

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    As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.

  • How Cannabis Rescheduling May Alter Paraphernalia Imports

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    The Biden administration's recent proposal to loosen federal restrictions on marijuana use raises questions about how U.S. Customs and Border Protection enforcement policies may shift when it comes to enforcing a separate federal ban on marijuana accessory imports, says R. Kevin Williams at Clark Hill.

  • NCAA Settlement May End The NIL Model As We Know It

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    The recent House v. NCAA settlement in California federal court, in which the NCAA agreed to allow schools to directly pay March Madness television revenue to their athletes, may send outside name, image and likeness collectives in-house, says Mike Ingersoll at Womble Bond.

  • Fishing Makes Me A Better Lawyer

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    Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.

  • A Healthier Legal Industry Starts With Emotional Intelligence

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    The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.

  • To Make Your Legal Writing Clear, Emulate A Master Chef

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    To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.

  • Circuit Judge Writes An Opinion, AI Helps: What Now?

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    Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.

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