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Tax
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October 15, 2025
Tax Court Says Easement Fraud Penalties Don't Require Jury
The U.S. Tax Court refused to throw out civil fraud penalties faced by a partnership accused of overvaluing a conservation easement tax deduction, rejecting the partnership's reliance on a U.S. Supreme Court ruling that limited federal agencies' authority to impose certain penalties without a jury trial.
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October 15, 2025
Sabre Says British Airways Must Reimburse For UK Digital Tax
Flight booking giant Sabre sued British Airways over a digital tax bill it says it was required to pay the U.K. on the airline's behalf, claiming the airline was contractually obligated to reimburse Sabre for the expense but has refused.
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October 15, 2025
NYC Hotel Must Hand Over Tax Credits In Bankruptcy
The owners of a boutique hotel in Brooklyn and its management company must return pandemic-era refundable tax credits that they received as the hotel filed for Chapter 11 bankruptcy protection, a New York bankruptcy judge ruled, saying they had unfairly pocketed the money at the bankruptcy estate's expense.
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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
Boston Says Celebrity Chef Moved Money To Skirt Tax Bills
The city of Boston is accusing celebrity chef Barbara Lynch of intentionally scheming to avoid paying nearly $1.7 million in property taxes by "siphoning off" corporate assets, asking a judge to pierce the corporate veil and hold her liable for the bill.
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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
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
Ore. Tax Court Denies Break For Land Claimed As Woodlot
An Oregon landowner could not prove that a portion of a parcel was used as a woodlot that would qualify for a property tax break, the state tax court ruled, noting that the standard for that classification was not clear.
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October 14, 2025
Calif. Allows Extended Property Tax Relief After LA Fires
California property owners affected by several fires in Los Angeles County in January will have extended property tax relief under legislation signed by Democratic Gov. Gavin Newsom.
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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
Colorado Business Owner Gets Prison For $1.5M Tax Fraud
The owner of a Colorado healthcare company who pled guilty to keeping over $1.5 million of her employees' withheld taxes received a one-year prison sentence on Friday.
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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
No Taxes On $137M Failed Merger Payment, UK Court Rules
A British microchip company doesn't owe taxes on $137 million it received from a U.S. company after a failed merger, a U.K. court ruled, rejecting HM Revenue & Customs's contention that the payment constituted a taxable disposal of assets.
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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
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
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 09, 2025
Dutch Gov't Summons Fund Suspected Of €200M Tax Evasion
Dutch prosecutors have summoned a foreign pension fund that they suspect evaded €200 million ($231 million) in taxes on dividends through fraudulent refund claims, the government said Thursday.
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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
Trade Court Tosses Wis. Man's Trump Tariff Suit
The U.S. Court of International Trade recently dismissed with prejudice a challenge to President Donald Trump's emergency tariffs after the Wisconsin man who filed suit failed to sufficiently amend his complaint.
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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
Group Claims Mich. 24% Pot Tax Enacted Unlawfully
Michigan's impending wholesale marijuana tax was approved by lawmakers unlawfully, an industry group alleged, saying the legislation signed by Gov. Gretchen Whitmer authorizing the tax did not have the votes of three-fourths of the majorities required in each legislative chamber.
Expert Analysis
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Agentic AI Puts A New Twist On Attorney Ethics Obligations
As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.
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Sweeping US Tax And Spending Bill May Bolster PE Returns
The One Big Beautiful Bill Act stands to benefit private equity sponsors and their investors as it alters existing law, including at the portfolio company level, making it crucial to reevaluate historic tax planning and optimize for the new tax regime, say attorneys at Paul Hastings.
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Series
Being A Professional Wrestler Makes Me A Better Lawyer
Pursuing my childhood dream of being a professional wrestler has taught me important legal career lessons about communication, adaptability, oral advocacy and professionalism, says Christopher Freiberg at Midwest Disability.
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Opportunity Zone's Future Corp. Tax Benefits Still Uncertain
Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.
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How GILTI Reform Affects M&A Golden Parachute Planning
Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.
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Series
Law School's Missed Lessons: Adapting To The Age Of AI
Though law school may not have specifically taught us how to use generative artificial intelligence to help with our daily legal tasks, it did provide us the mental building blocks necessary for adapting to this new technology — and the judgment to discern what shouldn’t be automated, says Pamela Dorian at Cozen O'Connor.
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Ch. 11 Ruling Voiding $2M Litigation Funding Sends A Warning
A recent Texas bankruptcy court decision that a postconfirmation litigation trust has no obligations to repay a completely drawn down $2 million litigation funding agreement serves as a warning for estate administrators and funders to properly disclose the intended financing, say attorneys at Kleinberg Kaplan.
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What To Expect As Trump's 401(k) Order Materializes
Following the Trump administration’s recent executive order on 401(k) plan investments in alternative assets like cryptocurrencies and real estate, the U.S. Department of Labor and the U.S. Securities and Exchange Commission will need to answer several outstanding questions before any regulatory changes are implemented, say attorneys at Cleary.
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Demystifying The Civil Procedure Rules Amendment Process
Every year, an advisory committee receives dozens of proposals to amend the Federal Rules of Civil Procedure, most of which are never adopted — but a few pointers can help maximize the likelihood that an amendment will be adopted, says Josh Gardner at DLA Piper.
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Parenting Skills That Can Help Lawyers Thrive Professionally
As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.
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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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Series
Teaching Trial Advocacy Makes Us Better Lawyers
Teaching trial advocacy skills to other lawyers makes us better litigators because it makes us question our default methods, connect to young attorneys with new perspectives and focus on the needs of the real people at the heart of every trial, say Reuben Guttman, Veronica Finkelstein and Joleen Youngers.
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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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Series
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.