Federal
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October 14, 2025
Relief Concerns Grow As Sectoral Tariff Actions Build
Importers' hopes for relief from industrywide tariffs are lagging alongside the trade deals President Donald Trump is trying to broker for some goods, while the administration's accelerated rollout of sectoral levies is also stoking concerns the government may be hamstringing its onshoring goals.
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October 14, 2025
Buy.com Founder's $16M Tax Bill Untimely, 10th Circ. Told
The founder of now-defunct Buy.com is challenging a nearly $16 million tax bill before the Tenth Circuit, arguing that the Internal Revenue Service failed to obtain valid consent to extend the statute of limitations for assessing the levy.
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October 14, 2025
Six Pension Plans Settle In $2.1B Danish Tax Fraud Case
Six 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 Tuesday.
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October 14, 2025
'Bitcoin Jesus' Paid $50M In Tax Deal, US Says
The U.S. asked a California federal court Tuesday to dismiss its criminal tax case against a cryptocurrency investor known as Bitcoin Jesus, disclosing that he has paid the $50 million he owed for hiding bitcoin from the IRS after renouncing his U.S. citizenship more than a decade ago.
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October 14, 2025
Floridian Must Pay $1.6M After Default Judgment In FBAR Suit
A tax preparer is on the hook for $1.6 million in penalties for foreign bank accounts that he tried to conceal, a Florida federal court found in a default judgment after he failed to respond to the U.S. government's suit.
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October 14, 2025
High Court Says Blackfeet Members Can't Join Tariff Dispute
The U.S. Supreme Court denied a bid by members of the Blackfeet Nation to join its review of suits challenging the legality of President Donald Trump's emergency tariffs, who had argued that their inclusion in the dispute is crucial to protect Indigenous rights under federal law.
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October 14, 2025
Miss. Partnership Challenges $89M Nixed Easement Deduction
A Mississippi partnership is entitled to an $89 million tax deduction for donating a conservation easement that protected land that could have been used for mining, despite the IRS' claim that the partnership failed to prove the gift's value, the partnership told the U.S. Tax Court.
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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.
Expert Analysis
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Unpacking The New Opportunity Zone Tax Incentive Program
The One Big Beautiful Bill Act brought several improvements to the opportunity zone tax incentive program that should boost investments in qualified funds, including making it permanent, increasing federal income tax benefits in rural areas, redesignating the qualified zones, and requiring more in-depth reporting, says Marc Schultz at Snell & Wilmer.
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Trump Tax Law's Most Impactful Energy Changes
The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.
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Adapting To Private Practice: From Texas AUSA To BigLaw
As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.
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Advice For 1st-Gen Lawyers Entering The Legal Profession
Nikki Hurtado at The Ferraro Law Firm tells her story of being a first-generation lawyer and how others who begin their professional journeys without the benefit of playbooks handed down by relatives can turn this disadvantage into their greatest strength.
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UK's 1st ICSID Claim Shows Bilateral Investment Treaty Reach
For the first time, the U.K. is facing a claim under the International Centre for Settlement of Investment Disputes Convention, underscoring the broader reality that treaty protections are no longer confined to investors in emerging markets, says Philipp Kurek at Signature Litigation.
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Trump Tax Law's Most Impactful Corp. And Individual Changes
The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.
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From Clerkship To Law Firm: 5 Transition Tips For Associates
Excerpt from Practical Guidance
Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.
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Trump Tax Law's Most Consequential International Changes
The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.
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Associates Can Earn Credibility By Investing In Relationships
As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.
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Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling
The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.
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What 2 Profs Noticed As Transactional Law Students Used AI
After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.
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BigLaw Settlements Should Not Spur Ethics Deregulation
A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.
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5 Ways Lawyers Can Earn Back The Public's Trust
Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.