Federal
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October 03, 2025
Justices To Weigh Compensation In Tax-Foreclosure Sale
The U.S. Supreme Court agreed Friday to take up a case contending that a deceased homeowner's estate was denied its constitutionally owed compensation when a Michigan county sold a tax-foreclosed property at a fraction of its fair market value.
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October 03, 2025
DC Circ. Split On Challenge To IRS-ICE Info-Sharing Deal
D.C. Circuit judges seemed split Friday over whether an information-sharing agreement between immigration authorities and the IRS complies with taxpayer privacy protections, with one judge noting during oral arguments that the government immigration arm requesting the tax information appears unauthorized to make the requests.
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October 03, 2025
Hobby Lobby's $85M Charity Case Needs Trial, Tax Court Says
A trial is needed to determine whether Hobby Lobby's owners themselves were responsible for missing important information that led the IRS to reject their nearly $85 million charitable deduction tied to artifact donations, the U.S. Tax Court ruled.
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October 03, 2025
Getting It Right: An Economist On Transfer Pricing
Michael McDonald, who retired from EY last month, spent most of his career at the U.S. Treasury Department, working on rules governing how related companies should calculate the value of intangible assets transferred between them, then later contributed to the massive rewrite of international tax rules by the OECD in 2015. McDonald reflected on both projects in an interview with Law360.
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October 03, 2025
Taxation With Representation: Kirkland, Paul Weiss, Cravath
In this week's Taxation With Representation, video game maker Electronic Arts agrees to be acquired by the Saudi Arabia Public Investment Fund, Silver Lake and Affinity Partners; online mortgage giant Rocket closes its acquisition of rival Mr. Cooper Group; and Berkshire Hathaway acquires international energy company Occidental's chemical business.
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October 03, 2025
8th Circ. Won't Review Teachers' Union Taxpayer Ruling
The full Eighth Circuit will not review a split panel decision ruling that taxpayers could challenge a Minnesota school district's paid leave policy that allows teachers to take paid time off to work for their union.
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October 03, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included 39 additions to the list of chemical substances subject to the Superfund excise taxes assessed to importers.
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October 02, 2025
Investors Claim $1.7M Stolen In Colorado Pot Co. Fraud
The partial owner of a now-defunct marijuana company in Boulder, Colorado, has been accused in a state court lawsuit of conning investors out of more than $1.7 million by claiming they were buying into a grow and dispensary operation while actually pocketing "some or all" of the money.
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October 02, 2025
IRS Data-Sharing Case Won't Be Paused For Gov't Shutdown
The U.S. Department of Justice must still submit court-ordered information in a lawsuit challenging the Internal Revenue Service's sharing of tax data with immigration authorities by Oct. 24, a D.C. federal judge ruled, despite the federal government shutdown that began Wednesday.
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October 02, 2025
IRS Capacity For 2026 In Danger Due To Cuts, TIGTA Warns
Staffing losses at the Internal Revenue Service could cause tax refund delays and allow $360 million in fraudulent returns to go unchecked this coming tax season, the Treasury Inspector General for Tax Administration warned Thursday.
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October 02, 2025
Yoga Biz Co-Owner Gets 2 Years For 8-Year, $2.3M Tax-Dodge
A Manhattan federal judge sentenced former Yoga to the People co-owner Michael Anderson to two years in prison Thursday, after the onetime yoga studio executive admitted failing to file tax returns for eight years as he earned some $3 million.
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October 02, 2025
11th Circ. Urged To Uphold Cut To $17M Easement Deduction
The U.S. Tax Court correctly slashed a partnership's $17 million tax deduction for donating a conservation easement, the government told the Eleventh Circuit, urging it to uphold a ruling that accused the group of trying to "fleece the public" by claiming the land was ripe for mining.
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October 02, 2025
Baker McKenzie Brings New Suit Against Ex-Associate In DC
A former Baker McKenzie tax attorney who publicly accused the firm's Washington, D.C., managing partner of sexual assault was previously in a relationship with the managing partner's son, the firm has said in a revised defamation complaint.
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October 01, 2025
Wyden Probes Crypto Investor's Possible Tax Bill Dodging
The Senate Finance Committee's Democratic staff is investigating whether a billionaire cryptocurrency investor improperly avoided more than $100 million in U.S. taxes by misrepresenting his residency in Puerto Rico and taking advantage of a tax program available to residents, committee ranking member Ron Wyden, D-Ore., said Wednesday.
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October 01, 2025
Calif. Importer, Son Both Get Prison For $8M Customs Fraud
A California federal judge sentenced a Los Angeles Fashion District business owner and his son to more than eight years and seven years in prison, respectively, after they were found guilty of ducking more than $8 million in customs duties and failing to report over $17 million in cash transactions on tax returns.
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October 01, 2025
Tax Court Backs IRS' Rejection Of Excise Tax Debt Settlement
The Internal Revenue Service was justified in rejecting an inspection company's bid to settle $9 million worth of unpaid excise taxes related to the company's failure to meet minimum funding standards for its employee pension plan, the U.S. Tax Court said Wednesday.
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October 01, 2025
Senate Panel Urged To Update Tax Code For Digital Assets
Congress needs to create tax rules for digital assets such as cryptocurrency and nonfungible tokens because the current regime creates uncertainty for taxpayers, digital asset stakeholders told the Senate Finance Committee on Wednesday.
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October 01, 2025
IRS Appeals Launches Post-Review Mediation Pilot Program
The IRS Office of Appeals launched a two-year mediation pilot program that reassigns cases to new teams after going through the administrative review to give taxpayers a faster and more independent process to resolve disputes before they pursue litigation, the agency announced Wednesday.
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October 01, 2025
States, Businesses Push Justices To Extend Tariff Arguments
The dozen states, several small businesses and Illinois toymakers that challenged President Donald Trump's emergency tariffs filed a joint motion Wednesday requesting more time to better represent their different claims for oral arguments at the U.S. Supreme Court in November.
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October 01, 2025
11th Circ. Denies Fla. Biz Owner's $2M Tax Challenge
The owner of a Florida marketing business is on the hook for more than $2 million in taxes and penalties after the Eleventh Circuit found that he filed his notice of appeal too late.
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October 01, 2025
Groups Seek Block On Use Of IRS, SSA Data For Deportations
A coalition of immigrant advocacy groups has asked a Massachusetts federal judge to block the government from the "unfettered" use of Internal Revenue Service and Social Security Administration data to identify and target millions of people for deportation.
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October 01, 2025
Caplin & Drysdale Adds Longtime IRS Pro To DC Office
Caplin & Drysdale has grown its Washington, D.C., office with the addition of a veteran Internal Revenue Service attorney, the firm announced Wednesday.
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October 01, 2025
IRS Sets March Deadline For Research Credit Form Comments
The Internal Revenue Service said Wednesday that the public has until the end of March to submit feedback on the draft form for reporting the research tax credit, saying the feedback deadline extension would give businesses more time to meet the incentive's requirements.
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October 01, 2025
IRS Final Property Capitalization Rule Allows More Deductions
Taxpayers will be able to deduct more interest rather than having to capitalize it when making improvements to property under final regulations released Wednesday by the Internal Revenue Service.
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October 01, 2025
8th Circ. Reverses IRS Win In 3M Transfer Pricing Case
The Eighth Circuit reversed a U.S. Tax Court ruling Wednesday that backed the Internal Revenue Service's decision to reallocate nearly $24 million of 3M Co.'s Brazilian income, holding that the transfer pricing regulations underlying the adjustment are invalid.
Expert Analysis
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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.
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Legal Jeopardy Looms Over Trump's Trade Negotiation Plans
Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.