2025 Tax Legislation | BakerHostetler

Federal tax legislation signed by President Donald Trump on July 4, 2025, affects nearly every sector of the economy and every type of taxpayer, including corporations, pass-through entities, tax-exempt organizations and individuals.

Serve as lead counsel in a more than $100 million Tax Court case filed in January 2024 challenging the validity of an illegal IRS retroactive regulation and IRS alternative Section 482 and economic substance arguments.
Perform a significant amount of large-case controversy work involving both domestic and international tax issues. Represented numerous clients under audit; at IRS appeals; and in Tax Court, refund and appellate litigation. Represented a multinational oil company in the U.S. Tax Court, where more than $1.3 billion in tax and interest was at stake with respect to a Section 482 transfer pricing issue alone.
Assist clients with structuring, negotiating and documenting corporate, partnership and limited liability company formation as well as merger, acquisition, joint venture, financial and disposition transactions – including spin-off transactions, asset sales, stock sales and Section 338(h)(10) transactions – and working closely with clients, investment bankers and the IRS national office, as necessary, and adhering to aggressive timetables in order to maximize client business opportunities.
Assist clients with multifaceted international matters, including structuring inbound and outbound business and real estate investments; cross-border mergers, dispositions and joint ventures; reorganizing and restructuring multinational corporate groups; creating centralized cash management centers; handling international controversies before the IRS and in the courts; and devising specialized planning involving transfer pricing, foreign entity classification, foreign tax credits, refreshing expiring NOLs, foreign currency transactions, profit repatriations and tax treaty issues.