Freeman Law

Among the laws enacted by the 89th Texas Legislature was HB 3159, which provides an exemption from oil and gas severance taxes for certain restimulation wells… more

Fossil Fuel, Legislative Agendas, New Legislation, Oil & Gas, State Taxes

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Insider Trading Law | An Evolving Landscape

Throughout the history of the U.S. stock market, individuals have used insider access to information to gain an unfair advantage over other investors. The use of material non-public information (“MNPI”) in financial trading by… more

Enforcement Actions, Illegal Tipping, Insider Trading, Material Nonpublic Information, Personal Benefit

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Cory Halliburton

U.S. Attorney General’s “Guidance” to Federally-Funded Agencies and Third Parties – Another Blow to DEI Initiatives

On July 29, 2025, the Office of the U.S. Attorney General published its Memorandum for All Federal Agencies on the subject of “Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination.”… more

Affirmative Action, Department of Justice (DOJ), Diversity and Inclusion Standards (D&I), Educational Institutions, Employment Discrimination

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Jason Hendrix

Risks in Avoiding State Tax Obligations

When a business has been hit with substantial tax liability, it can often be tempting to pack things up and abandon the business. Often, taxpayers consider the possibility of opening a new business in its place, as a means to… more

Business Entities, Business Ownership, Fraudulent Transfers, Penalties, State Taxes

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Devin Hludzik

Tax Cout in Brief | Christiansen v. Commissioner

The Tax Court in Brief - Freeman Law’s “The Tax Court in Brief” covers substantive Tax Court opinion, providing a brief of its decisions in clear, concise prose… more

Burden of Proof, Internal Revenue Code (IRC), IRS, Penalties, Tax Court

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Fernando Juarez

The Cautionary Tale of the Malta Pension Plan: First, Civil Audits, Now Criminal Investigations

Few things scare a taxpayer more than the IRS knocking on their door. But when the taxpayer realizes that the person knocking on the door is a Special Agent of the Criminal Investigation Division (“CID”) of the IRS, well…… more

Criminal Investigations, Employee Benefits, IRS, Pensions

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Micah Miller

Is it Really Over? Contract Provisions that Survive Termination and Why.

Just like many relationships, not all parts of a contract become things of the past when they expire or terminate. One way to ensure that a contractual right or duty applies post-termination is to specify that will it “outlast”… more

Breach of Contract, Confidentiality Agreements, Contract Disputes, Contract Drafting, Contract Interpretation

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Andrew Mirisis

IRS: Basis Adjustments Apply to CFC Mid-Year Distributions to Prevent Section 961(b)(2) Gain

PLR 202304008: Taxpayer Does Not Have Section 961(b)(2) Gain for Mid-Year Distributions - Introduction to Section 961 and Mid-Year Distributions - For years, there has been a longstanding question under the subpart F rules… more

Controlled Foreign Corporations, Corporate Taxes, Income Taxes, Internal Revenue Code (IRC), IRS

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Gregory (Greg) Mitchell

When is an Issue Tried by Consent?

In a recent trial, I had occasion to encounter the issue of when an issue can be considered to have been tried by consent. The trial was an adversary proceeding in a bankruptcy court, and the issues related to the alleged… more

Bankruptcy Court, Creditors, Debtors, Evidence

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Matthew Roberts

IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated that he: (1) had Form 5471 filing obligations for… more

Failure-to-File, Income Taxes, Internal Revenue Code (IRC), IRS, Lack of Authority

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Stephanie Uribe

Propuesta de Reglamentación para Fideicomisos Extranjeros Análisis de la Sección 643(i) del IRC

El 8 de mayo de 2024, la Secretaría de Hacienda de los Estados Unidos (“Treasury Department”) dio a conocer propuestas de reglamentos que abordan la clasificación, tributación y requisitos de información para fideicomisos… more

Foreign Trusts, Internal Revenue Code (IRC), Ministry of Finance, Reporting Requirements, U.S. Treasury

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Cindy Wofford

Another IRS Adverse Private Letter Ruling | Revocation of Tax-Exempt Status and Organizational and Operational Issues

In this ruling, a corporation’s I.R.C. § 501(c)(3) tax exempt status was under scrutiny. The corporation (“Company”) represented in its articles of incorporation and during its Form 1023 application process that it was organized… more

501(c)(3), Charitable Organizations, Filing Requirements, Form 990, Internal Revenue Code (IRC)

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Freeman Law

TL Fahring

2025 Texas Legislative Update | Exemption from Oil and Gas Severance Tax for Certain Restimulation Wells

Jason Freeman

Insider Trading Law | An Evolving Landscape

Cory Halliburton

U.S. Attorney General’s “Guidance” to Federally-Funded Agencies and Third Parties – Another Blow to DEI Initiatives

Jason Hendrix

Risks in Avoiding State Tax Obligations

Devin Hludzik

Tax Cout in Brief | Christiansen v. Commissioner

Fernando Juarez

The Cautionary Tale of the Malta Pension Plan: First, Civil Audits, Now Criminal Investigations

Micah Miller

Is it Really Over? Contract Provisions that Survive Termination and Why.

Andrew Mirisis

IRS: Basis Adjustments Apply to CFC Mid-Year Distributions to Prevent Section 961(b)(2) Gain

Gregory (Greg) Mitchell

When is an Issue Tried by Consent?

Matthew Roberts

IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

Stephanie Uribe

Propuesta de Reglamentación para Fideicomisos Extranjeros Análisis de la Sección 643(i) del IRC

Cindy Wofford

Another IRS Adverse Private Letter Ruling | Revocation of Tax-Exempt Status and Organizational and Operational Issues

Freeman Law

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