The Journey of Litigation
Quick Guide to Administrative Hearings
Wire Fraud Litigants Beware: Fourth Circuit Ruling Protects the Banks — The Consumer Finance Podcast
Solicitors General Insights: The Tale of Two Washingtons — Regulatory Oversight Podcast
How confidential is a request to access or challenge information in INTERPOL’s files?
Understanding the Impact of IPR Estoppel and PTAB Discretionary Denials — Patents: Post-Grant Podcast
The Presumption of Innocence Podcast: Episode 64 - Cages We Built: The Making of Mass Incarceration in America
Solicitors General Insights: The Legal Frontlines in Iowa and Indiana — Regulatory Oversight Podcast
The Briefing: The Ninth Circuit Puts the Brakes on Eleanor’s Copyright Claim
The Briefing: No CTRL-ALT-DEL For the Server Test
Navigating PTAB’s New Approach to IPR and PGR Discretionary Denial - Patents: Post-Grant Podcast
Solicitors General Insights: A Deep Dive With Mississippi and Tennessee Solicitors General — Regulatory Oversight Podcast
Update on the State of Non-compete Restrictions (LaborSpeak)
UPIC Audits
Consumer Finance Monitor Podcast Episode: Prominent Journalist, David Dayen, Describes his Reporting on the Efforts of Trump 2.0 to Curb CFPB
#WorkforceWednesday®: Federal Contractors Alert - DEI Restrictions Reinstated by Appeals Court - Employment Law This Week®
5 Key Takeaways | Building a Winning Evidentiary Record at the PTAB (and Surviving Appeal)
Exploring Procedural Justice | Judge Steve Leben | Texas Appellate Law Podcast
Handling Post-Conviction Death Penalty Cases Pro Bono | McKenzie Edwards | Texas Appellate Law Podcast
Inside the Fourth Court of Appeals’ Clerk’s Office | Michael Cruz | Texas Appellate Law Podcast
A recent decision from the Ontario Court of Appeal is a good reminder that courts won’t bail you out just because a tax plan didn’t go as expected. In Pyxis Real Estate Equities Inc. v. Canada, 2025 ONCA 65, the Court made it...more
The Employee Retention Credit (ERC) was introduced as part of the March 2020 Coronavirus Aid, Relief, and Economic Security (CARES) Act to encourage businesses to maintain their workforce during the economic disruptions of...more
In June, the Appellate Court of Illinois upheld an assessment of over $314 million against Sam’s Club for unpaid county cigarette excise taxes, including a 10% late fee, a 25% penalty, and accrued interest. The assessment...more
On June 12, 2025, the U.S. Supreme Court issued a significant decision in Commissioner of Internal Revenue v. Zuch, clarifying the jurisdictional boundaries of the U.S. Tax Court in Collection Due Process (CDP) appeals....more
The recent federal district court decision in Faulk Company, Inc. v. Xavier Becerra, et al., No. 24-cv-00609-P (N.D. Tex. 2025) significantly alters the primary mechanism used by the U.S. Department of Health and Human...more
La Cour administrative d’appel de Nancy précise la définition d’activité permettant de bénéficier du régime de faveur des BSPCE (CAA Nancy, 15 mai 2025, n° 22NC03173)....more
On May 28, 2025, in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) (“Soroban II”), the Tax Court held the active role of limited partners in a fund manager caused them to fail to qualify as “limited partners”...more
Taxpayers who made payments to the Internal Revenue Service (IRS) that included underpayment interest and/or failure-to-file/pay penalties that accrued during all or part of the period between January 20, 2020, through July...more
A recent 1st U.S. Circuit Court of Appeals ruling upheld a lower court decision that the Controlled Substances Act (CSA) does not violate federal law. The decision stems from Canna Provisions’ lawsuit against the government...more
On May 28, 2025, the United States Tax Court held that the limited partners of a limited partnership providing investment management services to various investment funds were not limited partners within the meaning of...more
On May 28, 2025, the US Tax Court ruled that investment manager limited partners in Soroban Capital Partners were active limited partners and, as such, were ineligible for the limited partner exception to self-employment...more
In this Court Rips edition of the buzz: IRC §280E limits the ERC for cannabis company - Canna Provisions case is dismissed (again) by Appeals Court....more
Recently, the Internal Revenue Service ("IRS") has successfully asserted that limited partners in private equity and hedge funds that are organized as limited partnerships were subject to tax under the Self-Employment...more
On May 28th, the U.S. Tax Court issued a decision in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) holding that all of the income allocable to the partnership’s limited partners (not just the amount...more
Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more
Denham Capital Management LP (“Denham”), a private equity firm, has appealed the recent U.S. Tax Court decision that declined to revisit its interpretation of the “limited partner exception” under the Self-Employment...more
On April 28, YA Global Investments, LP (“YA Global”) filed an appeal in the 3rd Circuit, contesting the Tax Court’s decision in YA Global Investments, LP v. Commissioner. In YA Global Investments, the court found that YA...more
The Alabama Legislature adjourned sine die near midnight on May 14, 2025, with the final legislative meeting day bogged down with filibusters by certain senators. Fortunately, a spate of tax bills had already passed both the...more
La Cour administrative d’appel de Paris confirme que la déductibilité fiscale de charges facturées au titre d’un contrat d’asset management entre sociétés liées suppose la démonstration concrète de prestations réellement...more
La Cour administrative d’appel de Versailles rappelle que la seule réduction de capital d’une filiale ne permet pas de caractériser une perte certaine et définitive sur titres, condition pourtant indispensable à la déduction...more
As a result of President Trump’s recent social media posts regarding Harvard University’s tax-exempt status, some institutions of higher education (IHE) have expressed concerns over whether the Internal Revenue Service (IRS)...more
In two rulings, the Federal Fiscal Court (BFH) ruled in favor of the taxpayer on the requirements for a consolidated tax group for income tax purposes. Managing holding partnership as controlling company (judgment of November...more
This client alert discusses recent developments relevant to members of UK LLPs in respect of the UK’s salaried member employment tax rules. In particular, it focuses on recent developments in relation to Condition B (the...more
The Court of Appeal (CA) in WTGIL Ltd v HMRC [2025] EWCA Civ 399 considered the scope of the VAT exemption for services supplied by insurance intermediaries. The case concerned motor insurance for young drivers which required...more
Last month, Bloomberg carried an article about a “small but growing trend” of states that are either cutting their individual income taxes or phasing them out entirely. According to the article, the states adopting these...more