Federal
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October 21, 2025
Partnership Deadline To Dispute IRS Is Fixed, Tax Court Says
A deadline to petition the U.S. Tax Court to challenge IRS adjustments to partnership returns is effectively fixed and cannot be extended, the court said Tuesday in a reviewed decision that denied an Alabama LLC's late bid to restore a $46 million deduction for donating to charity.
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October 21, 2025
Discovery Against Gem Co. Halted In Malawi's Tax Probe
Malawi's government can no longer proceed with discovery against a gemstone company that partnered with a mining outfit the country claims evaded billions of dollars in taxes and royalties on exported rubies and sapphires, a Washington federal judge ruled, vacating his own order.
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October 21, 2025
CPA Group Calls For Transition Relief For Tips, OT Deductions
Internal Revenue Service guidance related to reporting requirements for the new deductions for tips and overtime should include a safe harbor for businesses for the 2025 tax year, the American Institute of Certified Public Accountants said in a letter released Tuesday.
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October 21, 2025
IRS Publishes Guidance For Car Loan Interest Reporting
The Internal Revenue Service released transitional guidance Tuesday for businesses' reporting requirements under the budget reconciliation law's new deduction for car loan interest.
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October 21, 2025
IRS Moves Tips Deduction Hearing To Phone-Only
The Internal Revenue Service will hold its scheduled hearing on the nearly 70 occupations proposed to be subject to President Donald Trump's policy of no tax on tips via phone instead of in person, the agency announced Tuesday.
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October 21, 2025
Jones Walker Expands To Chicago With Tax Partner Hire
Jones Walker LLP has hired a Chicago-based attorney for its transactional tax team from Chapman and Cutler LLP, marking its first move into Illinois.
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October 21, 2025
Hawaii Domino's Franchisee Sues IRS Over Penalty Dispute
The IRS owes a Domino's Pizza franchisee $1.6 million in tax refunds for penalties related to failures to report its employee health coverage plan, the franchisee told a Hawaii federal court, saying the company's payroll provider was first to blame and the IRS mishandled the fallout.
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October 21, 2025
CPA Admits $1.7M Tax Fraud, Pandemic Loan Charges
A Massachusetts certified public accountant has agreed to plead guilty to failing to disclose to the IRS nearly $1.7 million in off-the-books compensation to an employee and making false certifications to obtain pandemic relief loans.
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October 21, 2025
Medtronic Says 8th Circ. Wrongly Tossed Tax Court's Method
The Eighth Circuit's rejection of the U.S. Tax Court's latest ruling on the pricing of Medtronic intangibles placed unnecessary restrictions on the court's unspecified method addressing such assets transferred to Puerto Rico, the company argued as it asked the Circuit Court to rethink its decision.
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October 20, 2025
Tax Pros Seek Clarity In Energy Supplier Certification Rules
The U.S. Treasury Department should clarify how developers can demonstrate new supplier certification compliance for some clean energy tax credits retooled by the Republican budget law, practitioners said Monday, noting uncertainty over what information could suffice under new restrictions on certain foreign suppliers.
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October 20, 2025
G7 Deal Exempting US From Min. Tax Hurts Brazil, Prof Says
Latin American countries, especially Brazil, are concerned that the deal announced by the Group of Seven countries in June exempting U.S. multinationals from a globally agreed 15% minimum tax gives the U.S. an unfair advantage over them, a professor at University of Antwerp said Monday.
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October 20, 2025
Tax Startup CEO Swindled $13M From Investors, SEC Says
The CEO of a defunct tax-compliance startup lied to investors as she raised $13 million for her company, overstating its revenues by almost 900 times and falsely claiming she was a certified public accountant, the U.S. Securities and Exchange Commission said Monday in California federal court.
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October 20, 2025
Emergency Tariffs Unlawfully Unprecedented, Justices Told
The International Emergency Economic Powers Act has never been used until President Donald Trump to impose tariffs, and nowhere does the law provide that explicit authority, a dozen states, several small businesses and a pair of Illinois toymakers told the U.S. Supreme Court Monday.
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October 20, 2025
IRS Incorrectly Adjusted LLC's Items, Tax Court Told
The Internal Revenue Service incorrectly adjusted a limited liability company's partnership items and imputed underpayment, the partnership's representative said in a petition released Monday, asking the U.S. Tax Court to redetermine the adjustments.
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October 20, 2025
Justices Won't Review Repeat Indictment For Medicare Fraud
The U.S. Supreme Court let stand Monday the repeat indictment of a health clinic manager for what the Second Circuit called a massive, yearslong scheme to submit false claims to Medicare and Medicaid, effectively rejecting the manager's claims that his original trial was irreparably delayed.
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October 17, 2025
Trump Orders Truck Tariffs, Expands Auto Rebate Program
President Donald Trump signed an executive order Friday to begin anticipated tariffs on heavy and medium trucks on Nov. 1, while expanding a program that domestic auto manufacturers are already utilizing for rebates to existing tariffs on auto vehicles.
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October 17, 2025
House Dems Call For Probe Into Reported IRS Donor Targeting
The Treasury Inspector General for Tax Administration must investigate reports that President Donald Trump's administration is encouraging the IRS to launch targeted criminal investigations into Democratic donors and left-leaning nonprofit organizations, House Ways and Means Committee Democrats said Friday.
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October 17, 2025
NM Medical Cannabis Co. Tells Tax Court 280E Does Not Apply
A New Mexico medical marijuana company said Friday that a federal policy barring cannabis enterprises from taking ordinary business deductions should not apply, and the company is entitled to a refund for overpayment.
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October 17, 2025
3rd Circ. Won't Rethink IRS Collections For Preparer Fraud
The Third Circuit declined Friday to reconsider a panel decision allowing the IRS to pursue a woman's unpaid taxes more than 20 years later — well after the normal three-year deadline — because her return preparer committed fraud on her filings without her knowledge.
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October 17, 2025
Electronic Co. Tells Justices Trump Tariffs Are The Emergency
Emergency tariffs imposed by President Donald Trump are creating extraordinary economic threats under a law that was intended to protect U.S. retailers from such harm, a Virginia-based electronics company told the U.S. Supreme Court on Friday.
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October 17, 2025
Federal Courts To Scale Back Operations Amid Shutdown
The federal court system has run out of money and will scale back operations beginning Monday as a result of the ongoing government shutdown, possibly leading to case delays.
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October 17, 2025
Covington Adds Former IRS Special Counsel In DC
Covington & Burling LLP has grown its tax practice in Washington, D.C., with the addition of a former special counsel in the Office of Chief Counsel at the Internal Revenue Service.
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October 17, 2025
Estate Fights $4M Bill In Tax Court, Citing IRS Valuation Errors
An estate challenged $4 million in taxes the Internal Revenue Service said it owes, telling the U.S. Tax Court that the agency made valuation mistakes related to loans for autism research and interests in companies that included a Caterpillar dealership.
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October 17, 2025
Steptoe Hires Corporate, Energy, Transactions Partner
Steptoe LLP has hired the former lead land use and real estate counsel for Florida's almost $3 billion I-4 ultimate highway reconstruction project, who has joined the firm's Washington, D.C., transactions practice to continue working with energy, infrastructure and real estate development matters.
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October 17, 2025
French Digital Tax Ruling Puts Spotlight On Trade Tensions
A French court decision that upheld the nation's digital services tax could bolster similar measures in other European Union member states, but legal backing may mean little if countries use DSTs as bargaining chips in tariff negotiations with the United States.
'Revenge Tax' May Reappear If Pillar 2 Talks Stall, Pros Say
Republican lawmakers are likely to revive what is commonly known as the revenge tax if countries are unable to flesh out a tentative agreement to effectively exempt U.S. companies from the 15% global corporate minimum tax regime known as Pillar Two, practitioners said Tuesday.
Treasury Floats Plan To Scrap Look-Through Rules
The U.S. Treasury Department proposed regulations Monday that would remove rules that allow revenue officials to, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.
Modeling Needed To Gauge Private Equity's Interest Deduction
The Republican budget law's revival of a more generous business interest deduction has energized private equity deals that heavily rely on loans, though investors must run detailed financial modeling to measure how much the perk might truly pay off.
'Revenge Tax' May Reappear If Pillar 2 Talks Stall, Pros Say
Republican lawmakers are likely to revive what is commonly known as the revenge tax if countries are unable to flesh out a tentative agreement to effectively exempt U.S. companies from the 15% global corporate minimum tax regime known as Pillar Two, practitioners said Tuesday.
Treasury Floats Plan To Scrap Look-Through Rules
The U.S. Treasury Department proposed regulations Monday that would remove rules that allow revenue officials to, in a manner of speaking, look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.
Modeling Needed To Gauge Private Equity's Interest Deduction
The Republican budget law's revival of a more generous business interest deduction has energized private equity deals that heavily rely on loans, though investors must run detailed financial modeling to measure how much the perk might truly pay off.
Featured Stories
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Modeling Needed To Gauge Private Equity's Interest Deduction
The Republican budget law's revival of a more generous business interest deduction has energized private equity deals that heavily rely on loans, though investors must run detailed financial modeling to measure how much the perk might truly pay off.
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French Digital Tax Ruling Puts Spotlight On Trade Tensions
A French court decision that upheld the nation's digital services tax could bolster similar measures in other European Union member states, but legal backing may mean little if countries use DSTs as bargaining chips in tariff negotiations with the United States.
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Tarter Krinsky Real Estate Chair Sees Office Market 'Normalcy'
Despite lingering economic questions, the office market is starting to reach a state of "normalcy," Tarter Krinsky's real estate leader told Law360 in a recent interview.
Expert Analysis
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High Court, Not A Single Justice, Should Decide On Recusal
As public trust in the U.S. Supreme Court continues to decline, the court should adopt a collegial framework in which all justices decide questions of recusal together — a reform that respects both judicial independence and due process for litigants, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.
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Adapting To Private Practice: 3 Tips On Finding The Right Job
After 23 years as a state and federal prosecutor, when I contemplated moving to a law firm, practicing solo or going in-house, I found there's a critical first step — deep self-reflection on what you truly want to do and where your strengths lie, says Rachael Jones at McKool Smith.
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Painting Makes Me A Better Lawyer
Painting trains me to see both the fine detail and the whole composition at once, enabling me to identify friction points while keeping sight of a client's bigger vision, but the most significant lesson I've brought to my legal work has been the value of originality, says Jana Gouchev at Gouchev Law.
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Compliance Pointers Amid Domestic Terrorism Clampdown
A recent presidential memorandum marks a shift in federal domestic-terrorism enforcement that should prompt nonprofits to enhance diligence related to grantees, vendors and events, and financial institutions to shore up their internal resources for increased suspicious-activity monitoring and reporting obligations, say attorneys at Morgan Lewis.
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Trump Tax Law Has Mixed Impacts On Commercial Real Estate
The One Big Beautiful Bill Act brings sweeping changes to the real estate industry — and while the permanency of opportunity zones and bonus depreciation creates predictability for some taxpayers, sunsetting incentives for renewable energy projects will leave others with hard choices, says Jordan Metzger at Cole Schotz.
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Protecting Sensitive Court Filings After Recent Cyber Breach
In the wake of a recent cyberattack on federal courts' Case Management/Electronic Case Files system, civil litigants should consider seeking enhanced protections for sensitive materials filed under seal to mitigate the risk of unauthorized exposure, say attorneys at Redgrave.
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What Ethics Rules Say On Atty Discipline For Online Speech
Though law firms are free to discipline employees for their online commentary about Charlie Kirk or other social media activity, saying crude or insensitive things on the internet generally doesn’t subject attorneys to professional discipline under the Model Rules of Professional Conduct, says Stacie H. Rosenzweig at Halling & Cayo.
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2 Rulings Highlight IRS' Uncertain Civil Fraud Penalty Powers
Conflicting decisions from the U.S. Tax Court and the Northern District of Texas that hinge on whether the IRS can administratively assert civil fraud penalties since the U.S. Supreme Court’s 2024 decision in SEC v. Jarkesy provide both opportunities and potential pitfalls for taxpayers, says Michael Landman at Bird Marella.
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Junior Attys Must Beware Of 5 Common Legal Brief Mistakes
Excerpt from Practical Guidance
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Junior law firm associates must be careful to avoid five common pitfalls when drafting legal briefs — from including every possible argument to not developing a theme — to build the reputation of a sought-after litigator, says James Argionis at Cozen O'Connor.
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Digital Asset Report Opens Doors For Banks, But Risks Linger
A recent report from a White House working group discussing digital asset market structure signals how banks may elect to expand into digital asset custody, trading and related services in the years ahead, but the road remains layered with challenges, say attorneys at Foley & Lardner.
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Power To The Paralegals: How And Why Training Must Evolve
Empowering paralegals through new models of education that emphasize digital fluency, interdisciplinary collaboration and human-centered lawyering could help solve workforce challenges and the justice gap — if firms, educators and policymakers get on board, say Kristine Custodio Suero and Kelli Radnothy.
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5 Real Estate Takeaways From Trump's Sweeping Tax Law
Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.
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Evaluating The Current State Of Trump's Tariff Deals
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As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.