Federal
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October 10, 2025
The Tax Angle: IRS Leadership Changes Amid Gov't Shutdown
The federal government shutdown doesn't appear any closer to being resolved on Capitol Hill, but that hasn't stopped the U.S. Treasury Department from pushing ahead with a dizzying amount of changes in the Internal Revenue Service's top leadership. Here's a rundown of changes at the IRS in the past week.
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October 10, 2025
Tax Court Told IRS Miscalculated $21M Bill In Trust Dispute
The Internal Revenue Service made erroneous calculations regarding an Arizona partnership's capital gains and assets related to partnership interests transferred to trusts, the partnership told the U.S. Tax Court as it challenged a $21 million tax bill.
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October 10, 2025
IRS Generally Provided Courteous Phone Service, TIGTA Says
Limited testing of the Internal Revenue Service's telephone calls showed that agency representatives were generally courteous and professional when assisting taxpayers, but there are some areas where the IRS can improve, according to a Treasury Inspector General for Tax Administration report released Friday.
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October 10, 2025
Taxation With Representation: Sullivan, MoFo, Freshfields
In this week's Taxation With Representation, Fifth Third Bancorp acquires Comerica in an all-stock deal, Qualtrics buys experience analytics firm Press Ganey Forsta, and SoftBank buys ABB's robotics division.
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October 10, 2025
Express Scripts Owed Trial In $43M Tax Row, 8th Circ. Told
Express Scripts is entitled to a trial in its $43 million case seeking a tax refund for producing its own software in the U.S., the company told the Eighth Circuit, saying a lower court wrongly made an early decision that "glossed over" the facts of a complex case.
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October 10, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the withdrawal of a pair of proposed regulations for a narrow set of tax-free corporate separation deals known as spinoffs and a multiyear reporting regime for those transactions.
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October 10, 2025
Baker Botts Adds 2 Tax Pros From Venable In San Francisco
Baker Botts LLP is expanding its West Coast transactional team, bringing in a pair of Venable LLP tax attorneys as partners in its San Francisco office.
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October 09, 2025
Hospice Co. Can't Get $450K In Deductions, Tax Court Affirms
A California-based hospice company was correctly denied $450,000 in tax deductions, the U.S. Tax Court decided Thursday, saying most of the tax breaks were not substantiated as required.
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October 09, 2025
GOP Sen. Joins Dems On Bill To Nix Trump's Global Tariffs
Several Senate Democrats and one Republican introduced legislation Thursday to eliminate the national emergency associated with President Donald Trump's so-called reciprocal tariff regime.
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October 09, 2025
IRS Sets Inflation-Adjusted Rates For Qualified Biz Income
The IRS adjusted a bevy of tax provisions for 2026 in response to the passage of this summer's budget reconciliation bill, including the maximum capital gains rate and the qualified business income deduction.
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October 09, 2025
Bulgarian Says US Delay On Sanctions Decision Harming Him
A Bulgarian businessman whose U.S. assets were frozen after the federal government accused him of bribery and tax evasion asked a D.C. federal court to force the U.S. to rule on his administrative challenge to the allegations, saying a delay has hurt his reputation and livelihood.
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October 08, 2025
Trump Tariffs Unconstitutional, Watchdog Tells Justices
Either President Donald Trump doesn't have authority to impose tariffs under the International Emergency Economic Powers Act, or the law is unconstitutional, the nonprofit group Consumer Watchdog told the U.S. Supreme Court Wednesday, urging the justices to affirm lower court rulings deeming those measures unlawful.
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October 08, 2025
3rd Time's The Charm? The Tax Court's Odyssey In Medtronic
A U.S. Tax Court judge has been sent back to the drawing board once again in the long-running transfer pricing litigation brought by Medtronic, raising questions about how much weight the court must give to IRS transfer pricing regulations and how much authority it has to go its own way.
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October 08, 2025
Senate Tax Panel Advances IRS Chief Counsel Nomination
The Senate Finance Committee approved President Donald Trump's nomination of a Sullivan & Cromwell attorney to be general counsel of the Internal Revenue Service, the nearly party-line vote Wednesday setting up the nomination for a vote by the full Senate.
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October 08, 2025
Tax Court Upholds Lien Notice Against Health Co.
The IRS didn't abuse its discretion when it sustained a federal tax lien notice against a health company for unpaid income and employment taxes, the U.S. Tax Court ruled Wednesday, saying the company didn't file documents, including tax returns, needed to challenge the notice.
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October 08, 2025
IRS Issued Tax Notices On Time, Tax Court Says
The Internal Revenue Service issued notices of tax deficiency related to a man's partnership on time, the U.S. Tax Court ruled Wednesday, saying the agency made the notifications within a year of the conclusion of litigation over the affected items.
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October 08, 2025
IRS Stops Most Operations Due To Federal Budget Impasse
The Internal Revenue Service has temporarily halted most of its operations, furloughed workers and ended paid leave for the affected employees as Congress remains deadlocked over federal appropriations legislation to fund the government, the agency's acting human resources officer said Wednesday.
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October 08, 2025
Gov't Resists Prison Delay For Lobbyist Who Evaded Tax
A Miami lobbyist who was sentenced to prison for evading more than $1 million in taxes should not be allowed to delay the start of his term, the U.S. told a Florida federal court, saying the medical injection he argues he should take at home is available in prison.
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October 08, 2025
Denver Attorney Returns To Reed Smith State Tax Team
Reed Smith is expanding its tax practice with the return of an experienced attorney, now based in Denver, with multistate experience in the full spectrum of tax issues.
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October 07, 2025
11th Circ. Wary Of IRS Procedure In FBAR Penalty Appeal
An Eleventh Circuit panel Tuesday appeared concerned about IRS procedures that could keep a man from recouping $419,000 he paid to resolve his failure to disclose funds held in foreign bank accounts as he appeals a district court determination that he actually owes $2.2 million.
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October 07, 2025
Goldstein's $968K Border Cash Claim To Be Admitted At Trial
A Maryland federal jury will hear claims from prosecutors that SCOTUSblog publisher Tom Goldstein told Dulles International Airport border guards that the $968,000 in cash he brought into the country in 2018 had been gambling winnings, after a judge shot down his efforts to suppress his alleged statements Tuesday.
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October 07, 2025
Simpson Thacher Atty On Making New REIT Blueprints
The real estate investment landscape has changed dramatically in recent years, as alternative asset managers — and their counsel — have pioneered ways to tap into new sources of capital. Simpson Thacher partner Benjamin Wells spoke to Law360 about the changes he's seen, how to navigate regulatory shifts, and how real estate investment trusts may continue to reinvent themselves.
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October 07, 2025
Ex-Executives' Payroll Tax Convictions Biased, 4th Circ. Told
Two former software executives asked the Fourth Circuit to reverse their criminal convictions stemming from their failure to pay employment taxes, claiming the jury's instructions were biased.
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October 07, 2025
Senate OKs Top Treasury Atty Pick In Slate Of Confirmations
The Senate approved President Donald Trump's choice of a Sidley Austin LLP partner to be general counsel of the U.S. Department of the Treasury on Tuesday as part of a combined confirmation of 108 nominees to various roles.
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October 07, 2025
Approach The Bench: Judge Kaplan On Suit Against The Gov't
U.S. Court of Federal Claims Judge Elaine Kaplan's docket doesn't always garner attention in the same way trial court cases do, but that may change as the executive branch makes sweeping budget and policy changes that could lend more political significance to monetary claims against the government.
Expert Analysis
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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.
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Terraform Case May Be Bellwether For Crypto Enforcement
The prosecution of crypto company Terraform Labs and its CEO, Do Kwon, offers a unique test of the line between lawful and unlawful conduct in digital transactions, and the Trump administration’s posture toward the case will provide clues about its cryptocurrency enforcement agenda in the years to come, say attorneys at Brooks Pierce.
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How Law Firms Can Counteract The Loneliness Epidemic
The legal industry is facing an urgent epidemic of loneliness, affecting lawyer well-being, productivity, retention and profitability, and law firm leaders should take concrete steps to encourage the development of genuine workplace connections, says Michelle Gomez at Littler and Gwen Mellor Romans at Herald Talent.
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Texas Fraud Case Shows Dangers Of Faulty Crypto Reporting
The recent sentencing of a man who failed to properly report capital gains from bitcoin sales is a reminder that special attention must be given to the IRS' reporting requirements in order to stay out of the government's crosshairs, says Saverio Romeo at Fox Rothschild.
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Potential Impacts Of IRS' $1M Affiliate Pay Deduction Cap
If finalized, a recent Internal Revenue Service proposal expanding Section 162(m) of the Internal Revenue Code to include the highly compensated employees of affiliates would make tracking which executives may be subject to the limit from year to year far more complex, say attorneys at Debevoise.