Federal

  • November 14, 2025

    The Tax Angle: Letter Ruling Debate, Experts' Role In Policy

    From a discussion on whether seeking a private letter ruling risks sparking more IRS oversight to a former Congressional Budget Office director's thoughts on tax experts' role in policymaking, here's a peek into a reporter's notebook on stories from the National Tax Association's annual conference in Boston.

  • November 14, 2025

    Trump Pulls IRS Chief Counsel Nomination Before Floor Vote

    President Donald Trump on Friday withdrew his nomination of a Sullivan & Cromwell attorney to be the Internal Revenue Service's chief counsel just weeks after the Senate Finance Committee voted to advance the nomination to the Senate floor.

  • November 14, 2025

    MVP: Latham's Pardis Zomorodi

    Pardis Zomorodi, partner at Latham & Watkins LLP's transactional tax practice in Los Angeles, has guided companies through the tax aspects of major complex transactions, including 2024's largest IPO and the high-profile merger between Skydance Media and Paramount Global, earning her a spot as one of the 2025 Law360 Tax MVPs.

  • November 14, 2025

    DC Circ. Urged To Block Trump Org. From IRS Leaker's Appeal

    President Donald Trump's private business organization should not be allowed to intervene in a former IRS contractor's challenge to his prison sentence for leaking Trump's and other wealthy people's tax returns, the contractor told the D.C. Circuit, saying the organization's participation would unfairly bias the court.

  • November 14, 2025

    US To Slash Tariff On Swiss Imports To 15% In Trade Deal

    The U.S. will reduce a 39% tariff on Swiss imports to 15% as part of a framework trade agreement reached with Switzerland, according to Friday announcements by the White House and the Swiss government.

  • November 14, 2025

    Taxation With Representation: Wachtell, Paul Hastings, Sidley

    In this week's Taxation With Representation, Pfizer Inc. completes its acquisition of obesity drug developer Metsera Inc., motion and controls technologies company Parker-Hannifin Corp. acquires Filtration Group Corp., and fund administrator JTC PLC backs a cash offer in the billions from British private equity shop Permira.

  • November 14, 2025

    Biz Contests $1.7M Tax Bill After Insurance Deductions Axed

    The Internal Revenue Service incorrectly hit a Colorado corporation with $1.7 million in taxes and penalties after erroneously disallowing deductions the company claimed for insurance premiums, the company told the U.S. Tax Court in a petition published Friday.

  • November 14, 2025

    Liquidated Captive Insurer Fights IRS Bill In Tax Court

    A captive insurance company that was later dissolved challenged $800,000 in taxes and penalties in the U.S. Tax Court, saying the Internal Revenue Service wrongly claimed the company had $3 million in unreported long-term capital gains.

  • November 14, 2025

    US Expatriations Rise To 1,600 In 3rd Quarter, IRS Says

    The number of people who lost or renounced their U.S. citizenship totaled 1,600 in the third quarter as logged by the U.S. Treasury Department, a 50% increase from the previous quarter, the IRS said Friday.

  • November 14, 2025

    Ala. Partnerships Say IRS Erred Rejecting Easement Breaks

    The Internal Revenue Service unlawfully denied a pair of Alabama partnerships' $40 million charitable tax deduction on a conservation easement they donated in 2020, the partnerships told the U.S. Tax Court, arguing the agency offered no sufficient explanation for its determination.

  • November 14, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service released its weekly internal revenue bulletin Friday, which included guidance for group health plans and health insurers to calculate out-of-network healthcare coverage for 2026.

  • November 13, 2025

    Eaton Witnesses Probed About Data Used For Credit Analysis

    An accounting expert and a former Eaton Corp. official both advised the U.S. Tax Court on Thursday about the data used to establish the financial position of the U.S. company after its acquisition of Irish-based Cooper Industries in 2012.

  • November 13, 2025

    Clean Energy Cos. Tap Private Cash To Beat Tax Credit Clock

    Clean energy developers are increasingly looking to privately held investors to ensure they can do enough work to keep their projects fully eligible for tax credits that start phasing out next year, energy development attorneys told Law360.

  • November 13, 2025

    Latin American Trade Deals With US Include Zero Tariff Rates

    Latin American countries including El Salvador, Guatemala, Ecuador and Argentina committed to nontariff reductions for U.S. producers in exchange for a zero tariff rate on many imports not readily available in the U.S., under details of framework trade agreements the White House unveiled Thursday.

  • November 13, 2025

    Tax Court Lets Oil Co. Split Losses In $72M Carryback Dispute

    An oil and gas company was allowed to give up the normal carryback period for its net operating losses without waiving the 10-year period for $72 million in specified liability losses, a divided U.S. Tax Court ruled Thursday, with two judges saying the rules aren't so flexible.

  • November 13, 2025

    Tax Court Upholds Levy Action For $186K Deficiency In Ala.

    The U.S. Tax Court affirmed an Internal Revenue Service decision to collect an Alabama couple's $186,000 tax debt, ruling Thursday that despite sympathy for the wife's severe medical condition, the husband had failed to participate in proceedings to make his case.

  • November 13, 2025

    High Court's Tariff Ruling May Trigger Refunds, Reimposition

    Importers are being advised to prepare for potential refunds in the event the U.S. Supreme Court rules President Donald Trump's emergency tariffs are unlawful, leaving questions about how a refund process might play out and whether the duties would be reimposed.

  • November 13, 2025

    Tax Court Denies Couple's EITC Claim Over Lack Of Proof

    An Alabama couple who claimed a $3,600 earned income tax credit did not prove that they are entitled to it, the U.S. Tax Court said Thursday, ruling that the pair are not eligible to claim the credit for the wife's sister.

  • November 13, 2025

    MVP: Kirkland's Adam Kool

    Adam Kool, a tax partner at Kirkland & Ellis LLP, spent the past year advising on high-profile, industry-transforming transactions. Kool's work on AbbVie's $63 billion acquisition of the pharmaceutical giant Allergan, GTCR's pending $24.25 billion sale of global payment processing company Worldpay and other billion-dollar transactions has earned him a spot as one of the 2025 Law360 Tax MVPs.

  • November 13, 2025

    Trump Org. Pushes DC Circ. To Back IRS Leaker's Sentence

    President Donald Trump's private business organization said it opposes any reduction to the five-year prison sentence of the former IRS contractor who leaked Trump's tax returns and thousands of others, telling the D.C. Circuit the leaker has been shown enough leniency.

  • November 13, 2025

    Tax Interest Rates To Hold Steady In 1st Quarter

    The Internal Revenue Service's interest rates for overpayments and underpayments of tax will remain the same for the calendar quarter beginning Jan. 1, the agency said Thursday.

  • November 13, 2025

    IRS Increases Retirement Fund Contribution Limits

    The Internal Revenue Service on Thursday announced the increased limit for contributions to various retirement accounts, including upping the 401(k) limit to $24,500.

  • November 13, 2025

    In-House Tax Controversy Director Joins Miller & Chevalier

    The former director of tax controversy at Cleveland, Ohio-based real estate company GBX Group LLC has moved to Miller & Chevalier Chtd.'s Washington, D.C., office, where she'll continue working on a range of tax-related matters.

  • November 12, 2025

    Ports Warn USTR Against China Ship Fees, Crane Tariffs

    The U.S. Trade Representative should reconsider tariffs on Chinese cranes and fees on Chinese and other foreign ships while those measures are suspended for the next year as part of a trade truce between China and the U.S., according to comments recently submitted by a U.S. port industry association.

  • November 12, 2025

    Doctor Owes Penalties Over Microcaptives, Tax Court Affirms

    The U.S. Tax Court on Wednesday affirmed economic substance and accuracy-related penalties pinned on an eye doctor and his wife over their microcaptive insurance arrangement.

Expert Analysis

  • A Look At DOJ's Dropped Case Against Early Crypto Operator

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    The prosecution of an early crypto exchange operator over alleged unlicensed money transmission was recently dropped in Indiana federal court, showcasing that the U.S. Justice Department may be limiting the types of enforcement cases it will bring against digital asset firms, say attorneys at Greenberg Traurig.

  • 8 Ways Lawyers Can Protect The Rule Of Law In Their Work

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    Whether they are concerned with judicial independence, regulatory predictability or client confidence, lawyers can take specific meaningful actions on their own when traditional structures are too slow or too compromised to respond, says Angeli Patel at the Berkeley Center of Law and Business.

  • Despite Dark Clouds, Outlook For US Solar Has Bright Spots

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    While tariff, tax policy and bankruptcy news seemingly portends unending challenges for the U.S. solar energy industry, signs of continued growth in solar generating capacity and domestic solar manufacturing suggest that there is a path forward, say attorneys at Beveridge & Diamond.

  • Law School's Missed Lessons: Communicating With Clients

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    Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.

  • Bill Leaves Renewable Cos. In Dark On Farmland Reporting

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    A U.S. Senate bill to update disclosure requirements for foreign control of U.S. farmland does not provide much-needed guidance on how to report renewable energy development on agricultural property, leaving significant compliance risks for project developers, say attorneys at Hodgson Russ.

  • Adapting To Private Practice: From US Rep. To Boutique Firm

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    My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.

  • IRS Should Work With Industry On Microcaptive Regs

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    The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.

  • CARES Act Fraud Enforcement Is Unlikely To Slow Down

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    In the five years since the passage of the Coronavirus Aid, Relief and Economic Security Act, the federal government has devoted massive resources to investigating CARES Act fraud — and all signs suggest the U.S. Department of Justice will continue vigorous enforcement in this area, say attorneys at Kostelanetz.

  • Spinoff Transaction Considerations For Biotech M&A

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    Amid current market challenges, boards and management teams of biotech companies can consider several strategies for maximizing value should a spinoff opportunity arise, but not without significant advance planning and careful implementation, particularly in cases that might qualify as tax-free, say attorneys at Paul Hastings.

  • Senate's 41% Litigation Finance Tax Would Hurt Legal System

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    The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.

  • Drawbacks For Taxpayers From Justices' Levy Dispute Ruling

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    The Supreme Court's June decision in Commissioner v. Zuch, holding the Tax Court lacks jurisdiction to resolve disputes where the IRS has stopped pursuing a levy, may require taxpayers to explore new tactics for mitigating the increased difficulty of appealing their liability via collection due process hearings, says Matthew Roberts at Meadows Collier.

  • How Energy Cos. Can Prepare For Potential Tax Credit Cuts

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    The Senate Finance Committee's version of the One Big Beautiful Bill act would create a steep phaseout of renewable energy tax credits, which should prompt companies to take several actions, including conduct a project review to discern which could begin construction before the end of the year, say attorneys at Husch Blackwell.

  • DOJ Has Deep Toolbox For Corporate Immigration Violations

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    With the U.S. Department of Justice now offering rewards to whistleblowers who report businesses that employ unauthorized workers, companies should understand the immigration enforcement landscape and how they can reduce their risk, say attorneys at McDermott.

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