Federal
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June 10, 2025
Flagging Fintech Could Help Stop Tax Crimes, Tax Chiefs Say
Governments could help mitigate money laundering and tax evasion by flagging fintech firms with services nested within traditional banks, with virtual assets used for anonymity or with fiat currency conversion services, top tax officials from five countries including the U.S. said Tuesday.
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June 10, 2025
Taxpayer Advocacy Panel Sets 6 July Committee Meetings
Six Taxpayer Advocacy Panel committees will meet in July to discuss the Internal Revenue Service's customer service, according to notices released Tuesday.
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June 09, 2025
States Warned Of Budget Bill's Push To Broaden PL 86-272
States and businesses should closely watch a provision in the budget reconciliation bill H.R. 1, or the One Big Beautiful Bill Act, that would expand the protections of a federal law that provides limited state income tax provisions for businesses, state tax professionals said Monday.
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June 09, 2025
Tax Court Backs Penalties In $24M Georgia Easement Feud
An Internal Revenue Service agent properly followed the procedure to secure timely supervisory approval to impose penalties against a partnership for incorrectly claiming a $24 million charitable tax deduction on its Georgia conservation easement donation, the U.S. Tax Court said Monday.
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June 09, 2025
CEOs Back Trump's Tax-Deferred Child Investment Accounts
The CEOs of several large corporations, including Dell Technologies, Uber and Goldman Sachs, pledged to contribute millions of dollars to tax-advantaged brokerage accounts for newborns that would be established under the House-passed budget bill, President Donald Trump announced at the White House on Monday.
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June 09, 2025
Russian Postdoc's Income Not Tax Exempt, Tax Court Says
A Russian permanent resident who was a postdoctoral laboratory worker at the University of South Carolina cannot escape federal taxes on her income by claiming it was a grant and thus exempt under the U.S.-Russia tax treaty, the U.S. Tax Court said Monday.
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June 09, 2025
Madigan Denied Acquittal, New Trial Ahead Of Sentencing
An Illinois federal judge on Monday denied former Illinois House Speaker Michael Madigan's bid for acquittal or a new trial, clearing the way for him to be sentenced for bribery, wire fraud and conspiracy later this week.
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June 09, 2025
Va. Woman's Overpayment Already Refunded, Tax Court Says
The Internal Revenue Service has already fully paid back the almost $90,000 it owes a Virginia woman to satisfy an overpayment determination, the U.S. Tax Court said Monday, dismissing a motion asking the court to enforce the determination.
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June 09, 2025
Businesses Warn Fed. Circ. Against Pausing Block On Tariffs
Thousands of businesses will suffer "irreparable harm" if the Federal Circuit halts the U.S. Court of International Trade's order that struck down President Donald Trump's global tariffs, a wine importer told the appellate court, urging against a long-term pause.
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June 09, 2025
US Opposes Ex-Tech CEO's Bid For Unrestricted Travel
Granting a former Florida tech CEO's request for unrestricted business travel during his probation would violate the conditions of his early prison release after he pled guilty to tax evasion, the U.S. told a federal court, urging it to reject his bid.
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June 09, 2025
Justices Urged To Keep Pause On 'Breakneck' Gov't Overhaul
The U.S. Supreme Court should leave in place a California federal judge's order barring implementation of layoffs and reorganizations at various federal departments and agencies, several unions and nonprofits argued Monday, claiming a decision allowing the changes would irreversibly harm the federal government and render Congress and the judiciary powerless.
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June 09, 2025
Taxpayer Advocacy Panel Joint Committee Sets July Meeting
The Taxpayer Advocacy Panel's Joint Committee will meet July 24 to discuss customer service, it announced Monday.
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June 09, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin included an updated list of automatic procedures for taxpayer-initiated changes to their accounting methods.
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June 06, 2025
The Tax Angle: IRS Funding, Budget Markup, Insurance Woes
From a look at upcoming Senate hearings on President Donald Trump's funding plans for the IRS to a potential markup of Republicans' $3.8 trillion budget reconciliation bill and the continuing crisis in homeowner insurance, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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June 06, 2025
8th Circ. Rejects Farm Leasing Co.'s Switch To Amortization
The Eighth Circuit denied an Arkansas farm leasing company's action to amortize federal subsidy-eligible land to reduce its tax liability, affirming Friday that the company was not authorized to make such accounting changes without approval from the Internal Revenue Service.
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June 06, 2025
11th Circ. Limits Easement Tax Break Tied To Failed Project
A Georgia partnership that formed after the failure of a resort development and donated a conservation easement in exchange for a tax break cannot take an $8.9 million deduction for the property's fair market value because the land was considered inventory, the Eleventh Circuit said Friday.
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June 06, 2025
Facebook Ruling Casts Uncertainty On Cost-Share Disputes
The U.S. Tax Court recently rejected Facebook's challenge to regulations that determine the buy-in payment for affiliated companies to share the costs of developing intangibles, raising questions about objections to similar rules by pharmaceutical multinationals.
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June 06, 2025
Taxation With Representation: Winston, Stibbe, Weil, Goodwin
In this week's Taxation With Representation, Chart Industries Inc. and Flowserve Corp. merge, Aedifica NV and Cofinimmo NV unite, Sanofi buys Blueprint Medicines Corp., and Kimberly-Clark Corp. sells a majority stake in its international tissue business to Suzano.
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June 06, 2025
Lobbyist Seeks No Prison After Admitting $1.3M Tax Evasion
A Miami lobbyist who admitted to evading $1.3 million in taxes asked a Florida federal court not to sentence him to prison, saying he reported his tax obligations in full, even for the years when he didn't pay, and was overwhelmed by family expenses.
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June 06, 2025
PE Firms Are Top Opportunity Zone Investors, Report Finds
A group tracking private equity activity said each of the 15 largest investors in the federal opportunity zone program are private equity firms, with Salt Lake City, Utah-based Bridge Investment Holdings topping the list with $3.7 billion in opportunity zone funds.
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June 05, 2025
'Sparse' OPM Record On Mass Firings Backs Win, Unions Say
A "sparse and self-serving" record provided by the U.S. Office of Personnel Management still shows the agency unlawfully directed federal agencies to fire probationary employees en masse, so a California federal court can reach a final decision now and "unwind" those terminations, a coalition including unions and advocacy groups said Thursday.
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June 05, 2025
Texas Plastics Co. Challenges IRS Over Microcaptive Rules
A Texas plastics company sued the IRS over regulations flagging microcaptive insurance plans as potentially abusive tax avoidance schemes, telling a Texas federal court that the agency exceeded its authority by imposing broad disclosure requirements that could penalize even legitimate arrangements.
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June 05, 2025
Ex-Atty Says IRS Suit Over Property Sale Tactic Is Retaliatory
A former attorney has asked an Idaho federal court to toss the government's suit accusing him and his company of promoting an abusive tax scheme, arguing that the underlying property sale transactions were above board but the government targeted him as punishment for suing the IRS and to gain backdoor access into confidential business records.
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June 05, 2025
Tax Court Upholds IRS' Proposed Tax Levy Against Neb. Man
The Internal Revenue Service did not abuse its discretion when sustaining a proposed levy against a Nebraska man aimed at collecting unpaid assessments for the 2006 and 2007 tax years, the U.S. Tax Court said Thursday, supporting the agency's determination.
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June 05, 2025
'Longtime Tax Protester' Must Pay On $226K In Income
A Texas man characterized by the U.S. Tax Court as a "longtime tax protester" was incorrect when he claimed his more than $226,000 in wages and retirement distributions aren't taxable, a judge ruled Thursday, also hitting him with a penalty.
Expert Analysis
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Perfecting Security Interests In Renewable Energy Tax Credits
The ability to transfer renewable energy tax credits has created new opportunities for developers, investors and lenders, but it also raises important questions regarding when and how the security interests in these credits are perfected — questions that must be answered definitively to protect credit claims and transactions, says Harry Teichman at Stinson.
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Firms Still Have Lateral Market Advantage, But Risks Persist
Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
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Making The Opportunity Zones Program Great At Last
As the opportunity zone program approaches its expiration, the Republican-led government could take specific steps to extend and improve the program, address its structural flaws, encourage broader participation and enable it to live up to its promised outcomes, say attorneys at Pillsbury.
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We Must Allow Judges To Use Their Independent Judgment
As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.
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Preparing For Tariffs On Canadian Power In The Northeast
The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.
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Making The Case For Rest In The Legal Profession
For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.
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Mitigating Tariff Risks For Healthcare In US And Canada
Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.
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4 Ways Women Attorneys Can Build A Legal Legacy
This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.
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A Judge's Pointers For Adding Spice To Dry Legal Writing
U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.
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Why NY May Want To Reconsider Its LLC Transparency Law
Against the backdrop of the myriad challenges to the federal Corporate Transparency Act, it may be prudent for New York to reconsider its adoption of the LLC Transparency Act, since it's unclear whether the Empire State's "baby-CTA" statute is still necessary or was passed prematurely, say attorneys at Pillsbury.
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IRS Scrutiny May Underlie Move Away From NIL Collectives
The University of Colorado's January announcement that it was severing its partnership with a name, image and likeness collective is part of universities' recent push to move NIL activities in-house, seemingly motivated by tax implications and increased scrutiny by the Internal Revenue Service, say attorneys at Buchanan Ingersoll.
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7 Tips For Associates To Thrive In Hybrid Work Environments
Excerpt from Practical Guidance
As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.
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IRS Should Revise Overbroad Microcaptive Regs
Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.