Federal
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March 11, 2025
5th Circ. Hopes For 'Sanity' In Backing Legal Malpractice Arb.
Untangling a "ridiculous" arbitration proceeding that produced four contradictory awards in a legal malpractice dispute, the Fifth Circuit on Tuesday affirmed three awards and most of another, adding that the parties are "free to arbitrate another day" in the hope that their disagreements will be resolved "for the sake of sanity."
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March 11, 2025
Trump, Ontario Back Down After Two-Day Trade Flare-Up
President Donald Trump called off additional tariffs on Canadian steel and aluminum Tuesday after the Ontario government dropped a briefly imposed surcharge on electricity exports, the White House told Law360 on Tuesday evening.
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March 11, 2025
Retailer Fights US On Overriding Jury In $11.6M FBAR Case
A federal jury in Hawaii was justified in finding that an international businessman hadn't willfully failed to report his foreign bank accounts in an $11.6 million dispute, and the U.S. government is not entitled to an overruled verdict or new trial, he told the court.
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March 11, 2025
House Passes Repeal Of IRS DeFi Broker Reporting Rule
The House passed legislation Tuesday that would repeal a final U.S. Treasury Department rule implementing additional reporting requirements for decentralized finance brokers.
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March 11, 2025
House Passes Short-Term Funding Bill With IRS Money Freeze
The Internal Revenue Service would continue to be blocked from accessing more than $20 billion in Inflation Reduction Act funding under legislation passed Tuesday by the House of Representatives, paving the way for the government to keep running past this coming Friday.
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March 11, 2025
With Guardrails, AI Is A Valuable Tax Tool, Tax Pros Say
Relevance of artificial intelligence in the tax world is expanding rapidly, and individuals and businesses should consider using it as long as cautions and guidelines are in place, tax professionals who have adopted the technology said Tuesday.
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March 11, 2025
12 Govs. Assert States' Sovereignty Against CTA In 5th Circ.
A dozen Republican governors, led by Georgia Gov. Brian Kemp, urged the Fifth Circuit to maintain a nationwide block of enforcement of the Corporate Transparency Act, arguing the law undermines the traditional authority states have to regulate businesses.
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March 11, 2025
Tax Court Releases Ex-Wife From Shared Tax Debt
An ex-wife is not liable for taxes and penalties that sprang from her former husband's job, the U.S. Tax Court said Tuesday after considering the woman's explanation that the pair filed their return jointly while they were still married but living separately.
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March 11, 2025
Carlton Fields Tax Ace Jumps To Trenam Law In Fla.
Florida's Trenam Law has added a past chair of the tax section of the state bar after her 25-year stint at Carlton Fields PA.
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March 11, 2025
Goldstein Wants Look At Testimony On Alleged Obstruction
U.S. Supreme Court lawyer and SCOTUSblog publisher Tom Goldstein asked a Maryland federal judge to let him see grand jury material related to the government's claim that he offered to pay a potential witness cryptocurrency in his tax evasion case.
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March 11, 2025
Business Owner Denies Evading Taxes In Sports Betting Ring
The owner of an insurance salvage company denied accusations in a California federal court that he evaded taxes in connection with a multimillion-dollar illegal sports betting ring, according to the U.S. Department of Justice.
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March 11, 2025
IRS Issues Corp. Bond Monthly Yield Curve For March
The Internal Revenue Service published Tuesday the corporate bond monthly yield curve for March for use in calculations for defined benefit plans, as well as corresponding segment rates and other related provisions.
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March 10, 2025
Alsup Refuses To Vacate Hearing Into OPM Mass Firings
U.S. District Judge William Alsup on Monday denied the Trump administration's request to vacate an upcoming evidentiary hearing into the U.S. Office of Personnel Management's mass firings of probationary federal employees, and required OPM director Charles Ezell to appear in person or else be deposed.
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March 10, 2025
Cutting IRS Staff May Shift Audit Burden To States, Pros Say
A possible cut in half of the number of Internal Revenue Service employees, floated by President Donald Trump's administration, could profoundly affect state tax administration, particularly if states become more responsible for auditing federal taxable income, tax pros said Monday.
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March 10, 2025
Feds Sue FDIC For $1.9M For First Republic Tax Bill
The U.S. government sued the Federal Deposit Insurance Corp. in D.C. federal court as receiver for the failed First Republic Bank, alleging the bank understated its withholding tax for U.S.-sourced income of foreigners and now owes almost $2 million to the federal government.
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March 10, 2025
Tax Court Rejects Break For Donations Of Clothing, Supplies
A couple who said they donated thousands of personal clothing items and supplies to a New York church are not entitled to a $285,000 tax deduction for charity because the two did not have the items correctly appraised, the Tax Court said Monday.
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March 10, 2025
Court Affirms FBAR Penalties Against Estate, Not Widow
The estate of a man who failed to report his Swiss bank accounts is liable for tax penalties of at least $2 million, an Idaho federal court determined, finding the man's widow off the hook.
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March 10, 2025
Tax Pro Rejoins Norton Rose From Reed Smith In Houston
Norton Rose Fulbright announced Monday that it has bulked up in the face of increased demand in the corporate transactions space with the return of a tax partner in Houston who came aboard from Reed Smith LLP.
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March 10, 2025
Tax Court Warns Couple Who Call Taxes Voluntary Gifts
A Utah couple who claimed they would not make a "gift" to the U.S. Treasury Department by paying their taxes owe about $21,000 to the IRS, plus penalties, the U.S. Tax Court ruled Monday, warning them against making frivolous arguments.
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March 10, 2025
Hyatt's $300M Rewards Fund Not Corp. Income, 7th Circ. Told
Hyatt told the Seventh Circuit it shouldn't have to report nearly $300 million in revenue from a rewards program fund owned by individual hotel owners, saying the U.S. Tax Court wrongly sided with the IRS in deciding the company should treat the money as its own.
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March 09, 2025
Short-Term Funding Bill Extends IRS Money Freeze
The Internal Revenue Service would continue to be blocked from accessing more than $20 billion in Inflation Reduction Act funding under legislation that the House is expected to consider this week, a measure that overall would keep the government running past March 14.
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March 07, 2025
Bankruptcy Trust's Extension Won't Hurt Its Status, IRS Says
A trust created to convert assets to cash and distribute them under a bankruptcy plan will still qualify as a liquidating trust if it extends its term a fifth time, so long as a bankruptcy court approves, the IRS said in a private letter ruling released Friday.
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March 07, 2025
NFTC Supports Broader, Elective Adoption Of Amount B
The U.S.' proposed adoption of the OECD's approach to pricing certain cross-border transactions, known as Amount B, should go beyond just marketing and distribution activities, the National Foreign Trade Council said Friday, suggesting it be extended to services and other baseline activities.
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March 07, 2025
Calif. Man Must Pay $230K In FBAR Penalties After Default
A federal court ordered a Californian accused of withholding reports of his Swiss bank accounts from the Internal Revenue Service to pay more than $230,000 after awarding the U.S. government a default judgment.
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March 07, 2025
Taxation With Representation: Kirkland, Wachtell, Skadden
In this week's Taxation With Representation, Walgreens Boots Alliance goes private via a deal with Sycamore Partners, Honeywell buys Sundyne from Warburg Pincus, and Jazz Pharmaceuticals acquires Chimerix.
Energy Tax Credit Regs Foster Confidence Amid Uncertainty
Despite uncertainty over the future of the Inflation Reduction Act's clean energy tax credits, the abundance of rules that has been released on them has provided stability for development projects that practitioners say should hold for the next few years.
Ex-Credit Suisse Client Pleads Guilty To Hiding $90M
A Colombian-American businesswoman and former Credit Suisse client pled guilty Monday in Florida federal court to conspiring with family members to hide more than $90 million in assets from the IRS through a series of foreign bank accounts.
DC Judge Declines To Block DOGE From Treasury Systems
A D.C. federal judge on Friday declined to wall off access to the federal government's payment systems from employees of the so-called Department of Government Efficiency during a lawsuit brought by retirees and union groups, determining the alleged privacy risks were not enough to warrant the court's intervention.
Energy Tax Credit Regs Foster Confidence Amid Uncertainty
Despite uncertainty over the future of the Inflation Reduction Act's clean energy tax credits, the abundance of rules that has been released on them has provided stability for development projects that practitioners say should hold for the next few years.
Ex-Credit Suisse Client Pleads Guilty To Hiding $90M
A Colombian-American businesswoman and former Credit Suisse client pled guilty Monday in Florida federal court to conspiring with family members to hide more than $90 million in assets from the IRS through a series of foreign bank accounts.
DC Judge Declines To Block DOGE From Treasury Systems
A D.C. federal judge on Friday declined to wall off access to the federal government's payment systems from employees of the so-called Department of Government Efficiency during a lawsuit brought by retirees and union groups, determining the alleged privacy risks were not enough to warrant the court's intervention.
Featured Stories
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Energy Tax Credit Regs Foster Confidence Amid Uncertainty
Despite uncertainty over the future of the Inflation Reduction Act's clean energy tax credits, the abundance of rules that has been released on them has provided stability for development projects that practitioners say should hold for the next few years.
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How Eversheds Sutherland Drew 12-Atty Tax Team In Atlanta
New Eversheds Sutherland partner Hale E. Sheppard joined Law360 Pulse to discuss how he helped lead a team of 12 tax controversy attorneys to join the firm in Atlanta from Chamberlain Hrdlicka White Williams & Aughtry PC.
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Attorneys Shift Gaze To Contracts As Trade Tensions Escalate
Construction experts are racing to keep up with rapid changes from the White House on tariffs amid what's now becoming a full-fledged trade war, and are working out how best to allocate cost-increase risk in their contracts. Lawyers shared several contract excerpts with Law360 Real Estate Authority.
Expert Analysis
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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.
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IRS Should Revise Overbroad Microcaptive Regs
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.
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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.
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How Law Firms Can Counteract The Loneliness Epidemic
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.
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Texas Fraud Case Shows Dangers Of Faulty Crypto Reporting
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.
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Potential Impacts Of IRS' $1M Affiliate Pay Deduction Cap
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.
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5 Keys To Building Stronger Attorney-Client Relationships
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.
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Notable Q4 Updates In Insurance Class Actions
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.
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Attorneys Must Act Now To Protect Judicial Independence
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.
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Rethinking 'No Comment' For Clients Facing Public Crises
“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.
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How Design Thinking Can Help Lawyers Find Purpose In Work
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.
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Justices' Certiorari Denial Leaves Interstate Tax Questions
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.
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Corp. Transparency Act's Future Under Treasury's Bessent
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.