Federal

  • 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.

  • 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.

  • March 10, 2025

    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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • March 07, 2025

    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.

  • March 07, 2025

    Immigrant Rights Groups Fight IRS Data Sharing With DHS

    Two Illinois-based immigrant and Latino rights groups filed a suit Friday seeking to block the Internal Revenue Service from disclosing the names and addresses of taxpayers with taxpayer identification numbers to the U.S. Department of Homeland Security and other agencies with the purpose of enforcing immigration laws.

  • March 07, 2025

    10th Circ. Urged To Reject Bid To Nix Microcaptive Notice

    The federal government urged the Tenth Circuit to affirm a ruling that rejected a plumbing supply company's request to invalidate an IRS notice that added reporting requirements for certain microcaptive insurance arrangements, saying the lower court correctly found the suit would illegally hinder tax collection.

  • March 07, 2025

    Goldstein Must Be Tracked Amid 'Ongoing' Crimes, Feds Say

    The federal government has doubled down on allegations that U.S. Supreme Court advocate and SCOTUSblog publisher Tom Goldstein has been secretly moving cryptocurrency, urging a federal judge to keep monitoring his electronic devices to prevent him from fleeing tax evasion charges.

  • March 07, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included guidance related to alternative methods for employers to provide health insurance coverage statements to employees as part of a larger move to reduce paperwork.

  • March 06, 2025

    Feds Say 11th Circ. Should Affirm Value Of Ex-Braves' Farm

    Despite dropping a bid for civil fraud penalties this week against two former Atlanta Braves players accused of overvaluing a conservation easement donation, the federal government has told the Eleventh Circuit it still stands by a U.S. Tax Court ruling that the players' valuation of the property was "firmly planted in the realm of fantasy."

  • March 06, 2025

    Tipster Urges DC Circ. To Reverse IRS Award Denial

    A man whose claim for a whistleblower award was rejected by the U.S. Tax Court asked the D.C. Circuit to reverse and reject arguments by the IRS that the court lacked authority to make a decision on grounds the agency did not act on the tipster's information.

  • March 06, 2025

    Feds Want Foreclosure On NJ Property In $16.2M Tax Fight

    A New Jersey property owned by a man who owes $16.2 million in taxes should be foreclosed on and sold to pay his debt, the U.S. government said Thursday, arguing that a property easement no longer restricts it from a sale.

  • March 06, 2025

    Trump Gives Mexico A Break Until April From New Tariffs

    President Donald Trump announced Thursday an almost monthlong exemption for most Mexican imports to tariffs he had placed on the country over drug trafficking concerns, as Mexico President Claudia Sheinbaum pointed to data showing border seizures of fentanyl dropped 70% since she took office.

  • March 06, 2025

    Treasury Pick Pledges To Protect Privacy Of Taxpayer Data

    A former assistant secretary of the U.S. Department of the Treasury said Thursday that he would safeguard the privacy of taxpayers' data if the Senate approves his return to Treasury as its deputy secretary.

  • March 06, 2025

    IRS Can't Defend Slashing Of Easement Value, 11th Circ. Told

    Conservation easement donors whose charitable tax deduction was reduced by millions of dollars by the U.S. Tax Court criticized the Internal Revenue Service's defense of the decision, telling the Eleventh Circuit the ruling ignored copious evidence of the property's value underlying the donation's worth.

Expert Analysis

  • AI Will Soon Transform The E-Discovery Industrial Complex

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    Todd Itami at Covington discusses how generative artificial intelligence will reshape the current e-discovery paradigm, replacing the blunt instrument of data handling with a laser scalpel of fully integrated enterprise solutions — after first making e-discovery processes technically and legally harder.

  • When Innovation Overwhelms The Rule Of Law

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    In an era where technology is rapidly evolving and artificial intelligence is seemingly everywhere, it’s worth asking if the law — both substantive precedent and procedural rules — can keep up with the light speed of innovation, says Reuben Guttman at Guttman Buschner.

  • What Compensation Committees Must Keep In Mind In 2025

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    New disclosure obligations, an evolving discussion on the analysis of executive perks and updated proxy adviser policies — on top of a new presidential administration — are all important things compensation committees must pay close attention to in 2025, say attorneys at Simpson Thacher.

  • Anticipating Direction Of Cosmetics Regulation Under Trump

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    It is unclear how cosmetics regulation reform from the last few years will fare under President Donald Trump, but the new administration's emphasis on deregulation and Robert F. Kennedy Jr.'s views on product safety provide some insight, say attorneys at Crowell & Moring.

  • IRS Basis-Shifting Rule Poses Notable Reporting Obligations

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    While the IRS’ recently finalized rule requiring partnerships to report certain related-party basis adjustment transactions is narrower than originally proposed, taxpayers and their advisers will still need to comb through myriad transactions to comply, say attorneys at Debevoise.

  • Imagine The Possibilities Of Openly Autistic Lawyering

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    Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.

  • Litigation Funding Disclosure Debate: Strategy Considerations

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    In the ongoing debate over whether courts should require disclosure of litigation funding, funders and plaintiffs tend to argue against such mandates, but voluntarily disclosing limited details about a funding arrangement can actually confer certain benefits to plaintiffs in some scenarios, say Andrew Stulce and Marc Cavan at Longford Capital.

  • Top Considerations For Insurance Companies In 2025

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    As insurance industry participants look to plan for the year, regulatory changes, climate-related challenges, the ongoing effects of social inflation and the potential for significant mergers and acquisitions will be among the key items for insurer boards and management to have on their radar, say attorneys at Debevoise.

  • Scope And Nature Of Judicial Relief Will Affect Loper's Impact

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    The practical result of post-Loper Bright rulings against regulatory actions will depend on the relief courts grant — and there has been controversy in these types of cases over whether the ruling is applied just to the parties or nationwide, and whether the action can be left in place while it's corrected, says Steven Gordon at Holland & Knight.

  • 5 Ways To Create Effective Mock Assignments For Associates

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    In order to effectively develop associates’ critical thinking skills, firms should design mock assignments that contain a few key ingredients, from messy fact patterns to actionable feedback, says Abdi Shayesteh at AltaClaro.

  • Congress Should Pass Sex Abuse Settlement Tax Exemptions

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    The proposed Survivor Justice Tax Prevention Act would expand tax exemptions more clearly for sexual abuse cases, and finally remove the stigma around compensation for emotional and psychological damage, says Rocco Strangio at Milestone & Co.

  • What's Next For Accounting Enforcement After SEC's Big 2024

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    The U.S. Securities and Exchange Commission under the Trump administration will likely continue to focus enforcement efforts on many of the same accounting and auditing issues that it pursued over the past year — but other areas, such as ESG, internal controls and cryptocurrency cases, may fall out of focus, say attorneys at Debevoise.

  • Mentorship Resolutions For The New Year

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    Attorneys tend to focus on personal achievements or career milestones when they set yearly goals, but one important area often gets overlooked in this process — mentoring relationships, which are some of the most effective tools for professional growth, say Kelly Galligan at Rutan & Tucker and Andra Greene at Phillips ADR.

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