Federal
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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
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.
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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
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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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.
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October 17, 2025
Taxation With Representation: Latham, Kirkland, Wachtell
In this week's Taxation With Representation, the Artificial Intelligence Infrastructure Partnership, MGX, and BlackRock's Global Infrastructure Partners acquire Aligned Data Centers from Macquarie Asset Management and co-investors; Rayonier Inc. and PotlatchDeltic Corp. merge to create a timber and wood products giant; and a Lone Star Funds affiliate acquires industrial processing equipment provider Hillenbrand Inc.
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October 17, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included plans to partially revoke and revise proposed regulations for the corporate alternative minimum tax.
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October 16, 2025
China's Crackdown On Rare Earth Minerals Spooks Importers
In the latest trade salvo between the U.S. and China, stricter Chinese export controls on critical earth minerals that many U.S. manufacturers rely on are causing concern for businesses, which may have difficulty diversifying supply chains for the rare materials.
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October 16, 2025
LA Developers Charged In Homeless Housing Fund Fraud
A pair of real estate developers have been charged in separate fraud cases alleging that they misused millions of dollars meant to build and operate affordable housing for people experiencing homelessness, the U.S. Attorney's Office of the Central District of California announced Oct. 16.
Expert Analysis
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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.
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7 Tips For Associates To Thrive In Hybrid Work Environments
Excerpt from Practical Guidance
As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.
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IRS Should Revise Overbroad Microcaptive Regs
Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.