Federal

  • 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.

  • 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.

  • March 19, 2025

    Satellite Startup Execs Accused Of Fraud And Tax Evasion

    An aerospace company's founder, an attorney and other executives lied about a venture to launch billions of dollars in satellites so they could rake in millions from investors, according to an indictment in D.C. federal court that also charges the founder with tax crimes.

  • March 19, 2025

    Goldstein Says Feds 'Misled' Court With Obstruction Claim

    U.S. Supreme Court lawyer and SCOTUSblog publisher Tom Goldstein wants a Maryland federal judge to sanction prosecutors in his tax evasion case for a "pattern of false and misleading statements" to the court accusing him of hiding millions in cryptocurrency and bribing his former law firm manager.

  • March 19, 2025

    DC Judge Won't Preemptively Stop IRS Data Sharing With DHS

    A D.C. federal judge on Wednesday said two immigrant rights groups had not shown that the IRS is poised to unlawfully share noncitizen taxpayer records with immigration enforcement authorities, rejecting their bid for a court order that would preemptively block any information transfer.

  • March 19, 2025

    Law360 Announces The Members Of Its 2025 Editorial Boards

    Law360 is pleased to announce the formation of its 2025 Editorial Advisory Boards.

  • March 19, 2025

    Taxpayer Advocacy Joint Committee To Meet In April

    The Taxpayer Advocacy Panel's Joint Committee will meet April 21 following a string of meetings by individual subcommittees earlier in the month, the Internal Revenue Service said Wednesday.

  • March 18, 2025

    Tax Court Sides With IRS Deeming Debt 'Seriously Delinquent'

    A Florida man's tax debt was property certified by the Internal Revenue Service as "seriously delinquent" and reported to the U.S. secretary of state to bar him from obtaining or renewing a passport, the U.S. Tax Court said Tuesday.

  • March 18, 2025

    Express Scripts Denied Tax Break For Software In $43M Suit

    Express Scripts is not entitled to a tax deduction for domestic production activities related to its software because it did not grant licenses to pharmacy benefit plan sponsors who used it, a Missouri federal court said Tuesday, denying the company's request for a tax refund in its $43 million case.

  • March 18, 2025

    Tax Court Cleared To Resolve IRS Offset Feud, Justices Told

    The U.S. Tax Court can still adjudicate a case challenging an Internal Revenue Service collection action even after the agency tried to improperly zero out the disputed liability in an attempt to dismiss the suit, a New Jersey woman told the U.S. Supreme Court.

  • March 18, 2025

    Trump Hasn't Asked IRS For Immigrants' Tax Info, Gov't Says

    The IRS hasn't received any requests from President Donald Trump for immigrants' tax return information and hasn't released any such information to the U.S. Department of Homeland Security, the government told a D.C. federal court in opposing a restraining order sought by immigrant rights groups.

  • March 18, 2025

    5th Circ. Backs La. Doctor's Tax Evasion Conviction

    The Fifth Circuit declined to overturn a Louisiana doctor's felony tax evasion conviction, rejecting her contention that jurors received muddied instructions that led to her being wrongly found guilty of dodging $1.6 million taxes and sentenced to more than four years in federal prison.

Expert Analysis

  • Tariffs' Economic Downsides Outweigh Potential Revenue

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    Import tariffs proposed by the campaign of former president Donald Trump would generate revenue like other taxes, but policymakers must consider the net-negative impact of associated consumer and downstream-industry costs, harm to exporters, potential foreign retaliation and reduction in economic output, says Erica York at the Tax Foundation.

  • Navigating The Last Leg Of The Worker Retention Tax Credit

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    Whether a business has applied for the pandemic-era employee retention tax credit, received a denial letter or is still considering making a claim before the April 15 deadline, it should examine recent developments significantly affecting the program before planning next steps, say attorneys at Nixon Peabody.

  • How Cos. Can Build A Strong In-House Pro Bono Program

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    During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.

  • Home Canning Makes Me A Better Lawyer

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    Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.

  • Use The Right Kind Of Feedback To Help Gen Z Attorneys

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    Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.

  • Congress Can And Must Enact A Supreme Court Ethics Code

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    As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.

  • What To Make Of Dueling Corporate Transparency Act Rulings

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    Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.

  • The Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan

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    Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.

  • State Of The States' AI Legal Ethics Landscape

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    Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.

  • 8 Childhood Lessons That Can Help You Be A Better Attorney

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    A new school year is underway, marking a fitting time for attorneys to reflect on some fundamental life lessons from early childhood that offer a framework for problems that no legal textbook can solve, say Chris Gismondi and Chris Campbell at DLA Piper.

  • How The 2025 Tax Policy Debate Will Affect The Energy Sector

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    Regardless of the outcome of the upcoming U.S. election, 2025 will bring a major tax policy debate that could affect the energy sector more than any other part of the economy — so stakeholders who could be affected should be engaging now to make sure they understand the stakes, say attorneys at Mayer Brown.

  • This Election, We Need To Talk About Court Process

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    In recent decades, the U.S. Supreme Court has markedly transformed judicial processes — from summary judgment standards to notice pleadings — which has, in turn, affected individuals’ substantive rights, and we need to consider how the upcoming presidential election may continue this pattern, says Reuben Guttman at Guttman Buschner.

  • Mental Health First Aid: A Brief Primer For Attorneys

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    Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.

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