Federal
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December 23, 2025
Top International Tax Cases Of 2025
Government tax administrations came up short in some of the biggest international cases decided this year, including Denmark's challenge to a British trader it accused of deceiving the tax authority into paying thousands of improper refunds. Here, Law360 examines seven of the year's top international tax cases.
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December 23, 2025
IRS Issues Updates To Healthcare Premium Tax Credit
The IRS released updates Tuesday to the refundable premium tax credit that allows individuals to purchase health insurance from the federal government's marketplace, including the removal of a repayment cap on excess credits that were established in the Republican 2025 budget law.
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December 23, 2025
IRS Issues FAQs For Interest Expense Deduction Limits
The Internal Revenue Service issued answers Tuesday to a set of frequently asked questions related to interest expense deduction calculations that were changed under the budget reconciliation law.
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December 23, 2025
11th Circ. Rejects Woman's Legal Fees In Tax Case Win
A Florida woman cannot recoup around $6,000 in attorney fees as part of her win in a U.S. Tax Court deficiency action despite paying her husband's legal practice to help with the case, the Eleventh Circuit found, affirming the Tax Court's ruling.
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December 22, 2025
10th Circ. Tosses Plumbing Co.'s Captive Deduction Bid
The Tenth Circuit is not the proper forum for a Utah plumbing company to challenge the Internal Revenue Service's 2016 notice denying a microcaptive insurance deduction, the appeals court found Monday, citing two statutes that bar the company's arguments.
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December 22, 2025
6th Circ. Vacates Pharma Salesman's $6.8M Restitution Order
The Sixth Circuit vacated a nearly $7 million restitution order against a pharmaceutical salesman convicted of healthcare fraud, finding an Ohio federal court erred in calculating that amount and apportioning liability.
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December 22, 2025
Draft House Bill Would Clarify Tax Rules For Digital Assets
A bipartisan draft bill in the U.S. House would modernize the federal tax code for digital assets, its backers said, by establishing a "commonsense tax treatment" for regulated payment stablecoins, clarifying source-of-income rules for trading and extending existing securities-lending rules to digital assets.
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December 22, 2025
IRS To Issue Guidance For Dyed Fuel Tax Refunds
The IRS announced plans Monday to issue guidance for a provision under the federal budget bill regarding a tax refund process for dyed fuel.
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December 22, 2025
Britney Spears Disputes $720K IRS Bill In Tax Court
Britney Spears is challenging the IRS over the more than $720,000 it assessed against her in 2021, telling the U.S. Tax Court that the agency improperly increased income she received through her pass-through entity.
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December 22, 2025
Tariff Refunds Would Be 'A Mess,' Economic Official Says
It would be an "administrative problem" to issue tariff refunds in the aftermath of a potential U.S. Supreme Court ruling against the White House's trade measures, a top economic policy official said.
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December 22, 2025
IRS Seeks Input On Updates To Voluntary Disclosure Process
The Internal Revenue Service asked Monday for comments on a proposed change to its voluntary disclosure program that would require payment of all taxes, penalties and interest within three months after being conditionally approved for the program.
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December 22, 2025
Farmers Can Pay Capital Gains Tax In Installments, IRS Says
Farmers who will pay capital gains tax on a farmland property sale to another farmer can opt to make the payments in four equal installments instead of a lump sum under guidance the IRS released Monday, implementing relief created by the 2025 budget law.
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December 19, 2025
Gunderson-Led Tax Firm Andersen Trades Up After Rare IPO
Tax valuation and advisory firm Andersen Group Inc. has closed a $202 million initial public offering, marking a rare IPO that required legal teams to navigate uncommon structural and governance challenges, according to attorneys who steered the offering.
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December 19, 2025
Conn. Investment Adviser Admits To Tax Evasion
A Connecticut man pled guilty to tax evasion after using $5.2 million of his private equity fund's money to pay personal expenses and causing a criminal tax loss of nearly $2.2 million, federal prosecutors said.
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December 19, 2025
IRS Extends Transition For States' Paid Family Leave Changes
States with paid family and medical leave programs have another year to transition to changes to the income and employment tax treatment of contributions paid in certain situations to support those benefits, the IRS said Friday, adopting stakeholders' recommendation for more time to comply.
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December 19, 2025
Taxation With Representation: Baker Botts, Morgan Lewis
In this week's Taxation With Representation, Trump Media and Technology Group merges with fusion power company TAE Technologies, pharmaceutical company Cencora boosts its stake in cancer care company OneOncology, and Phoenix Financial partners with private equity giant Blackstone to plug billions into various credit strategies.
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December 19, 2025
Calif. Ex-Customs Broker Sentenced For Tax, Wire Fraud
A California man was sentenced to 51 months in federal prison after being indicted this year on federal fraud charges and one count of tax evasion, the U.S. Department of Justice said.
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December 19, 2025
Polsinelli Lands Glaser Weil Tax Pro In Los Angeles
Polsinelli PC is expanding its business team, bringing in a tax pro from Glaser Weil as a shareholder in its Los Angeles office.
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December 18, 2025
IRS Guidance Discriminates Against Wind, Solar, Groups Say
Several groups, including the Natural Resources Defense Council and the city of San Francisco, asked a D.C. federal court Thursday to block the Internal Revenue Service from instituting new tax credit rules that they say illegally discriminate against wind and solar projects.
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December 18, 2025
Tax Court Denies Ex-Calif. Software Officer's Loan Deductions
A former executive of a now-defunct California software company cannot get a tax break on loans he said he lent the failing business between 2012 and 2015, a U.S. Tax Court judge ruled Thursday, finding he failed to show the loans could be deductible.
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December 18, 2025
7th Circ. Upholds Ex-Illinois Lawmaker's Tax Sentence
A former Illinois lawmaker cannot change her sentence despite attempts to comply with her tax reporting obligations after she was charged with evading them, the Seventh Circuit ruled Thursday, rejecting her argument that a lower court unconstitutionally barred evidence of her amended return.
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December 18, 2025
IRS Sets Unused Housing Credit Carryovers For 25 States
The IRS published Thursday the amounts of unused housing credit carryovers allocated to qualified states for 2025.
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December 18, 2025
Trump Orders Loosening Of Federal Restrictions On Marijuana
President Donald Trump on Thursday announced that his administration would instruct federal agencies to loosen restrictions on cannabis via executive order, a historic acknowledgment from the executive branch that the drug has recognized medical uses.
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December 18, 2025
AICPA Urges IRS To Create Lower Private Ruling Fee Class
The Internal Revenue Service should create a separate, lower user fee category for S corporation private letter ruling requests, the American Institute of CPAs told agency officials.
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December 17, 2025
Court Remands Commerce Ruling On Vietnam Steel Duties
The U.S. Department of Commerce did not properly substantiate its 2023 findings that imports of Vietnamese steel products were flouting duties imposed on South Korea, India and China, the U.S. Court of International Trade said, remanding the agency's determinations.
Top Federal Tax Decisions Of 2025
Over the past year, federal courts have issued decisions that extended the deadline for challenging tax bills in the U.S. Tax Court, allowed the IRS to pursue a woman's decades-old tax debt caused by her return preparer and lifted a $1 million reporting penalty because a jury didn't sign off. Here, Law360 reviews some of the most significant federal tax decisions of 2025.
Top Federal Tax Policies Of 2025
The first year of President Donald Trump's second term brought the passage of this summer's budget reconciliation bill, which renewed major parts of the 2017 Tax Cuts and Jobs Act, and major staffing changes at the Internal Revenue Service. Here, Law360 looks at the most consequential developments in federal tax policy in 2025.
IRS Relaxes Carbon Capture Credit's Environmental Reporting
The Internal Revenue Service released guidance Friday easing the carbon capture tax credit's environmental reporting requirements, taking effect by the end of the year, for energy systems that permanently secure the emissions in geological locations, such as deep underground rock formations.
Featured Stories
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Top Federal Tax Decisions Of 2025
Over the past year, federal courts have issued decisions that extended the deadline for challenging tax bills in the U.S. Tax Court, allowed the IRS to pursue a woman's decades-old tax debt caused by her return preparer and lifted a $1 million reporting penalty because a jury didn't sign off. Here, Law360 reviews some of the most significant federal tax decisions of 2025.
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Top International Tax Cases Of 2025
Government tax administrations came up short in some of the biggest international cases decided this year, including Denmark's challenge to a British trader it accused of deceiving the tax authority into paying thousands of improper refunds. Here, Law360 examines seven of the year's top international tax cases.
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A Blockbuster Year For Data Centers
Booming demand drove an explosive year for growth in the data center sector in 2025, with deals getting larger, more multifaceted and more complex for legal teams to pull off.
Expert Analysis
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How Fractional GCs Can Manage Risks Of Engagement
As more organizations eliminate their in-house legal departments in favor of outsourcing legal work, fractional general counsel roles offer practitioners an engaging and flexible way to practice at a high level, but they can also present legal, ethical and operational risks that must be proactively managed, say attorneys at Boies Schiller.
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How OECD Tax Update Tackles Mobile Workforce Complexity
The Organization for Economic Cooperation and Development’s recently updated model tax convention — a recalibration of international tax principles in response to an increasingly mobile workforce — should prompt companies to reevaluate cross-border operations, transfer pricing policies and tax controversy strategies, say attorneys at Eversheds.
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A Uniform Federal Rule Would Curb Gen AI Missteps In Court
To address the patchwork of courts’ standing orders on generative artificial intelligence, curbing abuses and relieving the burden on judges, the federal judiciary should consider amending its civil procedure rules to require litigants to certify they’ve reviewed legal filings for accuracy, say attorneys at Shook Hardy.
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Nonprofits Face Uncertainty Over Political Activity Rules
Two federal court decisions suggesting that the Internal Revenue Service's rules for 501(c)(4) organizations' political activity may be too vague to survive constitutional scrutiny leave nonprofit organizations caught between constitutional limits on government regulation of speech and tax limits on their exempt status, say attorneys at BakerHostetler.
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Supreme Court Term Limits Would Carry Hidden Risk
While proposals for limiting the terms of U.S. Supreme Court justices are popular, a steady stream of relatively young, highly marketable ex-justices with unique knowledge and influence entering the marketplace of law and politics could create new problems, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.
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Tariffs And Trade Volatility Drove 2025 Bankruptcy Wave
The Trump administration's tariff regime has reshaped the commercial restructuring landscape this year, with an increased number of bankruptcy filings showing how tariffs are influencing first‑day narratives, debtor-in-possession terms and case strategies, say attorneys at Thompson Hine.
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AI Evidence Rule Tweaks Encourage Judicial Guardrails
Recent additions to a committee note on proposed Rule of Evidence 707 — governing evidence generated by artificial intelligence — seek to mitigate potential dangers that may arise once machine outputs are introduced at trial, encouraging judges to perform critical gatekeeping functions, say attorneys at Lankler Siffert & Wohl.
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The Law Firm Merger Diaries: Getting The Message Across
Communications and brand strategy during a law firm merger represent a crucial thread that runs through every stage of a combination and should include clear messaging, leverage modern marketing tools and embrace the chance to evolve, says Ashley Horne at Womble Bond.
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Horizontal Stare Decisis Should Not Be Casually Discarded
Eliminating the so-called law of the circuit doctrine — as recently proposed by a Fifth Circuit judge, echoing Justice Neil Gorsuch’s concurrence in Loper Bright — would undermine public confidence in the judiciary’s independence and create costly uncertainty for litigants, says Lawrence Bluestone at Genova Burns.
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10 Commandments For Agentic AI Tools In The Legal Industry
Though agentic artificial intelligence has demonstrated significant promise for optimizing legal work, it presents numerous risks, so specific ethical obligations should be built into the knowledge base of every agentic AI tool used in the legal industry, says Steven Cordero at Akerman LLP.
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A Close Look At The Evolving Interval Fund Space
Interval funds — closed-end registered investment companies that make periodic repurchase offers — have recently moved to the center of the conversation about retail access to private markets, spurred along by President Donald Trump's August executive order incorporating alternative assets into 401(k) plans and target date strategies, say attorneys at Simpson Thacher.
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The Law Firm Merger Diaries: How To Build On Cultural Fit
Law firm mergers should start with people, then move to strategy: A two-level screening that puts finding a cultural fit at the pinnacle of the process can unearth shared values that are instrumental to deciding to move forward with a combination, says Matthew Madsen at Harrison.
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Rare Tariff Authority May Boost US Battery Manufacturing
Finalizing preliminary tariffs on active anode material from China — the result of a rare exercise of statutory authority finding that foreign dumping hampered the development of a nascent U.S. industry — should help domestic battery manufacturing, but potential price increases could discourage related clean-energy use, say attorneys at MoloLamken.