Federal
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April 25, 2025
US Seeks To Block Refund For Captive Insurance Penalties
A Pennsylvania federal court should reject a company's bid for an immediate penalty refund for operating what the IRS claimed is an abusive tax shelter through its microcaptive insurance program, the government argued Friday, saying the company is seeking protection in an unrelated U.S. Supreme Court ruling.
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April 25, 2025
IRS Says Docs In Captive Insurance Case Are Privileged
The IRS defended its refusal to release information to a tax services company seeking audit records of its captive insurance program, telling a Texas federal court that the agency's redactions of the requested records are protected by attorney-client privilege and other exceptions to the Freedom of Information Act.
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April 25, 2025
Takeaways From Justices' Questioning In Tax Collection Suit
The U.S. Supreme Court heard oral arguments this past week in a nearly 11-year-old case that could redefine taxpayers' challenges of Internal Revenue Service determinations to collect tax debts. Here, Law360 examines tax practitioners' key takeaways from the justices' remarks.
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April 25, 2025
Taxation With Representation: Dechert, Brown Rudnick
In this week's Taxation With Representation, Boeing sells parts of its digital aviation solutions business to Thoma Bravo, Baker Tilly and Moss Adams join forces, Mobico sells its U.S. school bus business to I Squared Capital, and Apollo commits to a joint venture with Bullrock Energy Ventures.
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April 25, 2025
5 Issues Benefits Attys Want The Gov't To Shed Light On
The first three months of President Donald Trump's administration have left lawyers who represent employers and benefit plans hungry for clarity on issues like cryptocurrency as a 401(k) investment and coverage for gender-affirming care. Here, Law360 looks at five areas where attorneys are hoping for guidance or regulations.
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April 25, 2025
No Weekly Internal Revenue Bulletin Articles For April 28
The Internal Revenue Service's weekly bulletin, issued Friday, said there were no articles to be published for April 28.
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April 24, 2025
Union Challenges Treasury's Suit Over CBA Executive Order
A National Treasury Employees Union affiliate urged a Kentucky federal judge Thursday not to find the U.S. Department of the Treasury can lawfully terminate its labor contracts with the national union, arguing the district court does not have jurisdiction and the agency can't request an advisory opinion.
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April 24, 2025
Gov't Stands By $1.7M In FBAR Penalties Against Texan
Constitutional law does not stop the U.S. from imposing $1.7 million in penalties against a Texan for failure to report foreign bank accounts, the U.S. told a federal court in arguing against the "myriad" of arguments she has made to dismiss the case.
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April 24, 2025
Silicon Valley Bank Liquidators Fight $41M Bill In Tax Court
The trust responsible for liquidating assets of the shuttered Silicon Valley Bank told the U.S. Tax Court that the IRS has wrongly charged the bank's operator more than $41 million in additional taxes by claiming it didn't substantiate losses and research activities in the years leading up to its bankruptcy.
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April 24, 2025
Think Tank Says Tariffs Hit Lower-Income Workers Hardest
President Donald Trump's tariffs currently being collected disproportionately harm lower- and middle-income earners in the U.S., according to an updated study by the Institute on Taxation and Economic Policy.
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April 24, 2025
Tax Cos. Head To 9th Circ. Over IRS Worker Credit Denials
Two tax assistance companies are appealing to the Ninth Circuit an Arizona federal court ruling denying their request to stop the IRS from issuing batch denials of thousands of pandemic-era worker credit claims, including those filed by their clients.
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April 24, 2025
Firm Fights IRS' $33M Boost To Self-Employment Income
The Internal Revenue Service wrongly subjected nearly $33 million of a New York investment firm's income to self-employment taxes by disqualifying the firm's limited partners and taxing their distributions, it alleged in two U.S. Tax Court petitions.
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April 23, 2025
NY, 11 Other States Sue Trump Administration To Block Tariffs
A dozen states are seeking to block tariffs the Trump administration imposed under the International Emergency Economic Powers Act, claiming in a lawsuit Wednesday the tariffs illegally constitute unprecedented tax hikes on Americans and violate constitutional separations of powers
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April 23, 2025
TurboTax Maker Fends Off H&R Block's False Ad Claims
A California federal judge tossed H&R Block's claims that competing tax-preparation company Intuit duped its customers into buying its TurboTax product by falsely claiming an expert would review returns, saying H&R Block failed to show the expert review feature influenced customers' purchasing decisions.
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April 23, 2025
11th Circ. Denies Couple's Medical, Business Deductions
The Eleventh Circuit rejected Wednesday numerous tax deductions that a couple had claimed for business and medical expenses, affirming the U.S. Tax Court's position that the pair failed to provide enough supporting documents to take advantage of the perks.
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April 23, 2025
Trump Says 145% Tariffs On China Will Fall Significantly
The U.S.' tariffs on China will end up nowhere near 145%, the current level for most Chinese goods, but they will not go away entirely, President Donald Trump said in the Oval Office.
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April 23, 2025
SCOTUSblog Sold Amid Goldstein's Criminal Case
SCOTUSblog has been sold to digital media company The Dispatch, according to announcements from both publications Wednesday, marking a new chapter for the U.S. Supreme Court-focused legal publication while its co-founder Tom Goldstein faces criminal charges.
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April 23, 2025
Judge Likely To Block Trump Collective-Bargaining Ban
A D.C. federal judge appeared ready on Wednesday to block President Donald Trump's executive order threatening to strip as many as 100,000 federal employees of their collective bargaining power, saying the order seems to target unions because they've challenged his actions, not because of any purported national security justification.
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April 23, 2025
Eaton Allowed To Redact Employee Docs Before Court Review
Eaton Corp. may redact information about employees' religion and sexual orientation from performance reviews before the court examines them privately in chambers in the company's transfer pricing dispute, an Ohio federal court ruled in a move the government had warned would flout a Sixth Circuit order.
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April 23, 2025
US Tariffs Will Slow Global Economic Growth, IMF Says
The "abrupt increase" in U.S. tariffs has resulted in countermeasures and uncertainty that will significantly slow global economic growth, according to a report from the International Monetary Fund.
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April 23, 2025
US Expatriations Doubled In 1st Quarter, IRS Says
The number of people who expatriated from the U.S. more than doubled during the first quarter of the year compared with the fourth quarter of 2024, the Internal Revenue Service said Wednesday.
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April 22, 2025
Justices Struggle To Grasp IRS Determination To Collect Debt
U.S. Supreme Court justices struggled Tuesday to understand the significance of an IRS determination that compelled a woman to continue litigating a 2010 tax debt that the agency zeroed out while her suit in Tax Court was pending over the determination that she still owed taxes.
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April 22, 2025
Tax Court Grants Partial Relief For Ex-Husband's Errors
The U.S. Tax Court granted partial relief Tuesday to an Ohio woman who requested relief from income tax obligations stemming from returns she filed with her former spouse from 2015 through 2018.
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April 22, 2025
Couple With $2.9M Tax Bill Ignored Tardiness, 2nd Circ. Says
A Connecticut couple must pay $2.9 million in tax liabilities, the Second Circuit affirmed Tuesday, saying they failed to address a lower court finding that they introduced evidence challenging their debt too late.
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April 22, 2025
Montana Farmers Union Asks To Join Tribe's Anti-Tariff Suit
The Montana Farmers Union wants to be included in a suit filed by members of the Blackfeet Nation challenging President Trump's tariffs on imports from Canada and abroad, arguing that the duties under scrutiny hurt the state's farmers the same way they hurt tribal members.
Expert Analysis
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What Trump's 2nd Presidency Could Mean For Crypto Sector
Trump's second term will bring a fundamental shift from the Biden administration's approach to crypto-asset regulation and banking supervision, with the most significant changes likely taking effect in the first two quarters of 2025 and broader policy shifts emerging over the next year, say attorneys at Cahill.
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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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Takeaways From The IRS' Crypto Doc Summons Win
A recent First Circuit decision holding that taxpayers do not have a Fourth Amendment reasonable expectation of privacy in cryptocurrency transaction records should prompt both taxpayers and exchanges to take stock of past transactions and future plans, say attorneys at BakerHostetler.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Ex-Chicago Politician's Case May Further Curb Fraud Theories
The U.S. Supreme Court recently agreed to hear Thompson v. U.S. to determine whether a statement that is misleading but not false still violates federal law, potentially heralding the court’s largest check yet on prosecutors’ expansive fraud theories, with significant implications for sentencing, say attorneys at the Law Offices of Alan Ellis.
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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Tariffs' Economic Downsides Outweigh Potential Revenue
Import tariffs proposed by the campaign of former president Donald Trump would generate revenue like other taxes, but policymakers must consider the net-negative impact of associated consumer and downstream-industry costs, harm to exporters, potential foreign retaliation and reduction in economic output, says Erica York at the Tax Foundation.
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Navigating The Last Leg Of The Worker Retention Tax Credit
Whether a business has applied for the pandemic-era employee retention tax credit, received a denial letter or is still considering making a claim before the April 15 deadline, it should examine recent developments significantly affecting the program before planning next steps, say attorneys at Nixon Peabody.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.