Federal
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September 15, 2025
McKesson Too Late To Fight IRS Cost-Share Rules, Gov't Says
Pharmaceutical giant McKesson waited too long to challenge transfer pricing regulations that cover cost-sharing arrangements as part of its $10 million tax refund bid, the U.S. government told a Texas federal court, arguing the statutory window to seek invalidation has closed.
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September 15, 2025
Applicable Federal Rates Set To Drop For A Third Month
Applicable federal rates for income tax purposes are slated to drop in October, falling for a third month after a rebound in July, the Internal Revenue Service said Monday.
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September 15, 2025
Court Urged To Block Offshore Asset Freeze In $28M Tax Row
The federal government's claim that a beneficiary of offshore trusts is likely to spend down assets to avoid a $28 million tax bill lacks evidence, the beneficiary argued in urging a Florida federal court not to freeze his accounts.
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September 15, 2025
OIRA Concludes Review Of Tipped Occupations
The Office of Information and Regulatory Affairs has concluded its review of a proposed regulation concerning guidance on occupations that will be subject to President Donald Trump's policy of no tax on tips, the office said.
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September 15, 2025
Kingsley Napley Bags Private Client Pro To Head Tax Desk
Kingsley Napley LLP said Monday that it has hired Paul Davidoff to head its international tax desk as the firm deals with a surge in work connected with tax and trusts amid an exodus of high-net-worth individuals from Britain.
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September 12, 2025
Justices' Tariff-Suit Review Halts Case In Texas Federal Court
A Texas federal court has postponed further proceedings in a suit challenging President Donald Trump's emergency tariffs until the U.S. Supreme Court considers matters involving similar claims that were taken under review earlier this week.
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September 12, 2025
Family Of Businessman Must Face $80M Tax Scheme Claims
A theater businessman's descendants and extended family cannot avoid claims by the U.S. accusing them of knowingly engaging in an $80 million tax shelter scheme to sell their shares of the family holding company, a New York federal judge ruled, declining to toss the suit.
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September 12, 2025
BEPS At 10: The Global Tax Revamp That's Still Unfolding
The OECD's project against base erosion and profit shifting didn't upend the international tax landscape overnight, but a decade later, the project's fingerprints have emerged on major policies that materially changed corporate behavior, including the 2017 U.S. tax overhaul.
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September 12, 2025
Taxation With Representation: Felesky Flynn, Gibson, Kirkland
In this week's Taxation With Representation, copper mining companies Anglo American and Teck Resources plan to merge, EchoStar agrees to sell spectrum licenses to SpaceX, and Diversified Energy acquires fellow energy operator Canvas.
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September 12, 2025
Customs Duties 2nd Largest US Revenue Source In August
Customs duties, including tariffs, were the second-largest contributor to federal revenues in August, raising $30 billion, the U.S. Treasury Department said in a monthly statement.
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September 12, 2025
Another Investor Settles In $2.1B Danish Tax Fraud Case
A U.S. investor and two of his alleged pension plans have settled claims by Denmark's tax agency accusing them of participating in a $2.1 billion scheme that fraudulently claimed refunds on tax withheld from stock dividends, with a New York federal court dismissing the allegations.
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September 12, 2025
Title Group Says FinCEN Erred In Rule On All-Cash Resi Deals
The American Land Title Association told a Florida federal judge that the U.S. Department of the Treasury's Financial Crimes Enforcement Network underestimated the costs and overestimated the benefits of a rule imposing new reporting requirements on all-cash residential real estate transactions.
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September 12, 2025
Troutman Adds Robinson Bradshaw Benefits Pro
Troutman Pepper Locke LLP has grown its tax and benefits practice group in North Carolina with the addition of a Robinson Bradshaw & Hinson PA attorney.
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September 12, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the near doubling of the statutory value of an income tax credit for producing electricity in line with a regularly scheduled increase tied to inflation.
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September 12, 2025
IRS Mostly Compliant In Levy Actions, TIGTA Says
The IRS properly issued more than 99% of the levies between July 2023 and June 2024, the Treasury Inspector General for Tax Administration said in a report, publicly released Friday, that examined more than 46,000 taxpayers with systemic tax delinquent cases.
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September 11, 2025
Full Tax Court Limits Deduction For Cannabis Biz Owners
Co-owners of two cannabis businesses owe $1 million in taxes because the wages they paid are rendered ineligible for a business income deduction for pass-throughs by a ban on deductions for companies that traffic in controlled substances, the full U.S. Tax Court ruled Thursday.
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September 11, 2025
ABA Tax Chair Seeks To Maintain Section's Ties With IRS
The new chair of the American Bar Association's Section of Taxation steps in during a rocky period for the profession amid departures of federal tax employees and clashes between the Trump administration and the ABA. Here, she outlines her priorities for the section, from boosting engagement with members to reinforcing ties with the U.S. Department of the Treasury and Internal Revenue Service.
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September 11, 2025
Montana Tribe Members Ask To Join Justices' Tariff Suit Review
Members of the Blackfeet Nation have asked the U.S. Supreme Court to join its review of cases challenging President Donald Trump's emergency tariffs, telling the justices that their arguments' inclusion in the matter is essential to support tribal rights under federal law.
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September 11, 2025
IRS Forfeits Opposition In $37M Easement Dispute, Court Told
Two partnerships seeking to reinstate their combined $37 million tax deductions for donating adjoining Georgia conservation easements told the Eleventh Circuit that the IRS has effectively forfeited its opposition to their claim that the U.S. Tax Court made valuation errors in reducing their tax breaks.
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September 11, 2025
5th Circ. Won't Revisit Doctor's Captive Insurance Case
The Fifth Circuit rejected a Texas doctor's request for the full court to review a panel's July decision that he was not entitled to $1 million in tax deductions linked to his urgent care network's captive insurance company.
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September 10, 2025
Unions' Challenge To Fed. Layoffs, Reorganizations Proceeds
The Trump administration must continue facing a union-backed challenge to its federal worker layoffs and agency reorganizations, a California federal judge ruled, tossing the administration's argument that the U.S. Supreme Court cast enough doubt on the suit's legitimacy by pausing an injunction to justify dismissing the case.
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September 10, 2025
Trump's Pick For Top IRS Atty Touts Experience At Agency
The Sullivan & Cromwell attorney tapped by President Donald Trump to return to the IRS for a second stint as chief counsel told a Senate panel Wednesday that he would arm the agency with a breadth of specialized experience and prioritize issuing guidance quickly.
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September 10, 2025
Chemical Co. Challenges $7.7M Tax Bill Over Foreign Credits
Multinational chemical manufacturer Huntsman is challenging a $7.7 million tax liability in the U.S. Tax Court, alleging that the IRS erred by not applying its Dutch holding company's deficit to its deemed paid foreign tax credits.
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September 10, 2025
The Tax Angle: New Extenders, Housing Credits
From a look at the new tax extenders included in the Republican Party's budget reconciliation law and the law's expanded housing tax credit, here's a peek into a reporter's notebook on a few developing tax stories.
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September 10, 2025
Too Many Credits Taken For Electric Car, Tax Court Says
A California couple who claimed a one-time tax credit for their electric car for several years owe $7,500 in taxes for one of the years when they were not entitled to it, the U.S. Tax Court said in a ruling Wednesday.
Expert Analysis
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Calif. Bar Exam Fiasco Shows Why Attys Must Disclose AI Use
The recent revelation that a handful of questions from the controversial California bar exam administered in February were drafted using generative artificial intelligence demonstrates the continued importance of disclosure for attorneys who use AI tools, say attorneys at Troutman.
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In 2nd Place, Va. 'Rocket Docket' Remains Old Reliable
The U.S. District Court for the Eastern District of Virginia was again one of the fastest civil trial courts in the nation last year, and an interview with the court’s newest judge provides insights into why it continues to soar, says Robert Tata at Hunton.
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How Attorneys Can Become Change Agents For Racial Equity
As the administration targets diversity, equity and inclusion efforts and law firms consider pulling back from their programs, lawyers who care about racial equity and justice can employ four strategies to create microspaces of justice, which can then be parlayed into drivers of transformational change, says Susan Sturm at Columbia Law School.
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Adapting To Private Practice: From US Attorney To BigLaw
When I transitioned to private practice after government service — most recently as the U.S. attorney for the Eastern District of Virginia — I learned there are more similarities between the two jobs than many realize, with both disciplines requiring resourcefulness, zealous advocacy and foresight, says Zach Terwilliger at V&E.
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Opportunity Zone Revamp Could Improve The Program
If adopted, the budget bill's new iteration of the opportunity zone program could renew, refine and enhance the effectiveness and accountability of the original program by including structural reforms, expanded eligibility rules and incentives for rural investment, say attorneys at Pillsbury.
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The Ins And Outs Of Consensual Judicial References
As parties consider the possibility of judicial reference to resolve complex disputes, it is critical to understand how the process works, why it's gaining traction, and why carefully crafted agreements make all the difference, say attorneys at Pillsbury.
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The BigLaw Settlements Are About Risk, Not Profit
The nine Am Law 100 firms that settled with the Trump administration likely did so because of the personal risk faced by equity partners in today's billion‑dollar national practices, enabled by an ethics rule primed for modernization, says Adam Forest at Scale.
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House Bill Tax Tweaks Would Hinder Renewable Projects
Provisions in the budget reconciliation bill recently passed by the U.S. House of Representatives would rapidly phase out clean energy tax credits, constrain renewable energy financing arrangements and impose sweeping restrictions on projects with foreign ties, which may create compliance and supply chain issues for many developers, say attorneys at Paul Hastings.
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Power To The Paralegals: An Untapped Source For Biz Roles
Law firms looking to recruit legal business talent should consider turning to paralegals, who practice several key skills every day that prepare them to thrive in marketing and client development roles, says Vanessa Torres at Lowenstein Sandler.
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How Trucking Cos. Can Keep Rolling Under Tariff Burdens
Recent Trump administration tariffs present major challenges for the transportation and logistics sector — and, in particular, trucking — but providers who focus on operational efficiency, cost control, customer relationships, creative contract structures and unique offerings will stand out from the competition, say attorneys at Benesch.
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Tariff Strategies For The US Renewable Energy Sector
The Trump administration's tariff actions over the last few months are challenging for the renewable energy industry — but there are strategies for contending with the uncertainty, including diversifying supply chains, seeking certification about equipment origins, and adding tariff-related language to supply contracts and offtake agreements, say attorneys at Sheppard Mullin.
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Ch. 7 Marshaling Ruling Rests On Shaky Legal Grounds
In its recent holding in a Chapter 7 bankruptcy case that marshaling may not be applied against the IRS, a Texas federal court misapplied a bankruptcy code section and case law, leaving a draconian decision that could limit the scope of a powerful equitable estate tool, says Brian Shaw at Cozen O'Connor.
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3 Tax Issues Manufacturers Should Watch In 2025 Budget Bill
As Congress works toward a budget reconciliation bill, manufacturing companies should keep a keen eye on proposals to change bonus depreciation, the qualified business income deduction and energy tax credits, which could have a significant impact on capital-intensive industries, say attorneys at Frost Brown Todd.