Federal
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September 03, 2025
Software Co. Founder Fights $100M Tax Bill At 11th Circ.
A software company founder facing more than $100 million in tax debt from his participation in an illegal tax shelter should have been allowed to settle with the Internal Revenue Service for $1.5 million because he can't pay the whole bill, he told the Eleventh Circuit.
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September 03, 2025
Tax Court Must Reconsider Medtronic Pricing, 8th Circ. Says
The U.S. Tax Court should reconsider its use of a hybrid approach for pricing intangibles that Medtronic licensed to a Puerto Rican affiliate, the Eighth Circuit said Wednesday, vacating the ruling and directing the court to revisit the IRS' pricing method.
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September 02, 2025
11th Circ. Affirms Slashing Ex-Braves' $47M Easement Break
A $47 million conservation easement deduction for a partnership founded by two former Atlanta Braves players was overvalued, the Eleventh Circuit affirmed Tuesday, saying none of the partnership's arguments undermined the U.S. Tax Court's finding that the easement property was worth far less than it claimed.
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September 02, 2025
Jury Misled On Tax Fraud Conspiracy Charge, 10th Circ. Rules
The Tenth Circuit overturned Tuesday a conviction against a man who did not report trust income on his personal tax returns, saying the New Mexico district court erred in presenting instructions on the conspiracy charges to both the jury and defendant's counsel.
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September 02, 2025
Firm Urges 2nd Circ. To Review $142M Earnings Boost
A New York investment company has asked the Second Circuit to review a U.S. Tax Court ruling that sustained a $142 million increase to its net earnings and found its principals did not qualify as limited partners for an exception from self-employment income tax.
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September 02, 2025
Most Employers Paid Taxes After COVID Delay, Report Says
Most employers who put off paying Social Security taxes during the pandemic have paid their bills, the Treasury Inspector General for Tax Administration said Tuesday, although some employers who didn't pay were incorrectly charged penalties by the IRS.
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September 02, 2025
IRS Withdraws Rule On Tax Data Use In Passport Revocations
The IRS will scrap a 2018 proposed rule that would have allowed the U.S. State Department to share taxpayer return information with contractors that assist in the revocation or denial of passports of individuals with serious tax debts, the agency announced Monday, calling the rule unnecessary.
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September 02, 2025
Colgate-Palmolive To Shell Out $332M In Pension Payout Fight
Colgate-Palmolive retirees asked a New York federal judge to greenlight a $332 million class action deal in their suit claiming the household products company shorted them on lump-sum retirement payouts, signaling the end of a nearly decade-old case that reached the Second Circuit in 2023.
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August 29, 2025
Split Fed. Circ. Backs Limits On Presidential Tariff Powers
The Federal Circuit held that President Donald Trump's emergency tariffs were improperly imposed under the International Emergency Economic Powers Act, which it said makes no mention of "tariff," "duties" or "tax."
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August 29, 2025
Bookie Who Took Bets From Ohtani Interpreter Gets 1 Year
A resident of Orange County, California, was sentenced to a year and a day in prison on Friday after pleading guilty to operating as an unlicensed bookmaker who placed bets for current and former professional athletes as well as a Japanese language interpreter who is serving time for stealing from baseball megastar Shohei Ohtani.
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August 29, 2025
House Dems Reintroduce Marijuana Legalization Bill Again
Democrats in the U.S. House of Representatives once again reintroduced a federal marijuana legalization bill that previously passed the chamber twice when it was under Democratic control, but has never gained traction in the U.S. Senate or under a majority-Republican House.
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August 29, 2025
Federal Tax Policy To Watch In The Rest Of 2025
As Congress returns to Washington, D.C., after the August recess, the bulk of federal tax policy is expected to focus on funding the IRS past Sept. 30 and getting out guidance for retroactive deductions included in this summer's budget reconciliation bill. Here's a look at federal tax policy to watch during the rest of the year.
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August 29, 2025
Apple Must Hand Swiss User's Records To IRS, Judge Rules
Apple must provide the Internal Revenue Service with a Swiss user's internet and phone records as part of a criminal investigation by Switzerland's taxing authority, a California federal judge ruled, despite the man's protests that the records are unrelated to taxes.
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August 29, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the removal of a method for large-scale clean energy projects to establish eligible construction start dates in order to claim solar and wind tax credits.
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August 29, 2025
Taxation With Representation: White & Case, Paul Weiss
In this week's Taxation With Representation, private equity firm Sycamore Partners completes its $24 billion acquisition of Walgreens Boots Alliance Inc., telecommunications company EchoStar sells wireless spectrum licenses to AT&T and Keurig Dr Pepper acquires JDE Peet's in a deal that aims to create a "global coffee champion."
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August 28, 2025
Coke Says IRS Taking 'Extreme' Position In $2.7B Dispute
The IRS is taking an "extreme" position in its defense of a $2.7 billion tax ruling against Coca-Cola by asserting that the standard prohibiting arbitrary and capricious actions by an agency doesn't apply to it, the company told the Eleventh Circuit.
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August 28, 2025
6th Circ. Affirms Dismissal Of Meritless Tax Challenge
The Sixth Circuit affirmed the dismissal of a Tennessee man's suit against the Internal Revenue Service, ruling Wednesday that his challenge to the agency's tax collections was meritless and provided no basis for federal jurisdiction.
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August 28, 2025
Illinois Atty Gets 2½ Years For Tax Fraud, Scripting Testimony
A former Chicago attorney who covered up $1 million in payments to his romantic interest and tried scripting his bookkeeper's initial trial testimony has been sentenced to two and a half years in prison, federal prosecutors announced Thursday.
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August 28, 2025
IRS Provides Guidance On Renewed R&D Tax Break
The Internal Revenue Service released instructions Thursday on how to make various elections, file amended tax returns and change accounting methods for the renewed tax break for research and development costs passed under the budget reconciliation bill.
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August 28, 2025
Compliance Atty Who Duped Lender Wants New Trial
A compliance lawyer convicted of pilfering from a $20 million line of credit that a subsidiary of Emigrant Bank extended to his tax-lien business has asked a Manhattan federal judge to order a new trial, arguing that prosecutors' evidence is insufficient and that the charges were "multiplicitous," in violation of the Fifth Amendment.
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August 27, 2025
Co. Can't Challenge IRS Easement Penalties, Court Rules
The Internal Revenue Service can assess civil penalties against a property company for a disallowed conservation easement deduction, a Louisiana federal court said, agreeing with the government that the company's challenge is barred under the Anti-Injunction Act.
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August 27, 2025
Retired Air Force Officer Faces IRS Levy Over Unpaid Taxes
The Internal Revenue Service properly upheld a tax levy against a retired U.S. Air Force officer who didn't report a $245,000 military retirement distribution, the U.S. Tax Court ruled Wednesday, saying the man didn't show he couldn't afford to pay his bill.
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August 27, 2025
Church Leaders Charged In Forced Labor, Laundering Scheme
Two self-proclaimed religious leaders forced people to work in call centers to raise millions of dollars that the pair spent on jet skis and other luxuries in a money laundering scheme investigated by the IRS, according to an indictment unsealed Wednesday in Michigan federal court.
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August 27, 2025
US Tax Compliance To Cost $536 Billion In 2025, Report Says
U.S. taxpayers will spend about $536 billion this year complying with the tax code, largely in what economists call opportunity costs, an amount greater than federal revenues from corporate income tax, the Tax Foundation reported Wednesday.
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August 27, 2025
Baker Botts Adds 2 More Lateral Partners In NY
As it touts the addition of 17 lateral partners this year so far, Baker Botts LLP announced Tuesday that it has gained a former Paul Weiss Rifkind Wharton & Garrison LLP attorney focused on executive compensation and transactional tax strategy and a former McDermott Will & Schulte LLP attorney focused on public company and private equity mergers and acquisitions.
Expert Analysis
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Adapting To Private Practice: From Fed. Prosecutor To BigLaw
Making the jump from government to private practice is no small feat, but, based on my experience transitioning to a business-driven environment after 15 years as an assistant U.S. attorney, it can be incredibly rewarding and help you become a more versatile lawyer, says Michael Beckwith at Dickinson Wright.
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Justices' False Statement Ruling Curbs Half-Truth Liability
The U.S. Supreme Court’s recent Thompson v. U.S. decision clarified that a federal statute used to prosecute false statements made to bank regulators only criminalizes outright falsehoods, narrowing prosecutors’ reach and providing defense counsel a stronger basis to challenge indictments of merely misleading statements, says Tamara de Silva at De Silva Law Offices.
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Perfecting Security Interests In Renewable Energy Tax Credits
The ability to transfer renewable energy tax credits has created new opportunities for developers, investors and lenders, but it also raises important questions regarding when and how the security interests in these credits are perfected — questions that must be answered definitively to protect credit claims and transactions, says Harry Teichman at Stinson.
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Firms Still Have Lateral Market Advantage, But Risks Persist
Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
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Making The Opportunity Zones Program Great At Last
As the opportunity zone program approaches its expiration, the Republican-led government could take specific steps to extend and improve the program, address its structural flaws, encourage broader participation and enable it to live up to its promised outcomes, say attorneys at Pillsbury.
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We Must Allow Judges To Use Their Independent Judgment
As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.
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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.