Federal
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October 03, 2025
Taxation With Representation: Kirkland, Paul Weiss, Cravath
In this week's Taxation With Representation, video game maker Electronic Arts agrees to be acquired by the Saudi Arabia Public Investment Fund, Silver Lake and Affinity Partners; online mortgage giant Rocket closes its acquisition of rival Mr. Cooper Group; and Berkshire Hathaway acquires international energy company Occidental's chemical business.
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October 03, 2025
8th Circ. Won't Review Teachers' Union Taxpayer Ruling
The full Eighth Circuit will not review a split panel decision ruling that taxpayers could challenge a Minnesota school district's paid leave policy that allows teachers to take paid time off to work for their union.
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October 03, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included 39 additions to the list of chemical substances subject to the Superfund excise taxes assessed to importers.
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October 02, 2025
Investors Claim $1.7M Stolen In Colorado Pot Co. Fraud
The partial owner of a now-defunct marijuana company in Boulder, Colorado, has been accused in a state court lawsuit of conning investors out of more than $1.7 million by claiming they were buying into a grow and dispensary operation while actually pocketing "some or all" of the money.
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October 02, 2025
IRS Data-Sharing Case Won't Be Paused For Gov't Shutdown
The U.S. Department of Justice must still submit court-ordered information in a lawsuit challenging the Internal Revenue Service's sharing of tax data with immigration authorities by Oct. 24, a D.C. federal judge ruled, despite the federal government shutdown that began Wednesday.
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October 02, 2025
IRS Capacity For 2026 In Danger Due To Cuts, TIGTA Warns
Staffing losses at the Internal Revenue Service could cause tax refund delays and allow $360 million in fraudulent returns to go unchecked this coming tax season, the Treasury Inspector General for Tax Administration warned Thursday.
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October 02, 2025
Yoga Biz Co-Owner Gets 2 Years For 8-Year, $2.3M Tax-Dodge
A Manhattan federal judge sentenced former Yoga to the People co-owner Michael Anderson to two years in prison Thursday, after the onetime yoga studio executive admitted failing to file tax returns for eight years as he earned some $3 million.
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October 02, 2025
11th Circ. Urged To Uphold Cut To $17M Easement Deduction
The U.S. Tax Court correctly slashed a partnership's $17 million tax deduction for donating a conservation easement, the government told the Eleventh Circuit, urging it to uphold a ruling that accused the group of trying to "fleece the public" by claiming the land was ripe for mining.
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October 02, 2025
Baker McKenzie Brings New Suit Against Ex-Associate In DC
A former Baker McKenzie tax attorney who publicly accused the firm's Washington, D.C., managing partner of sexual assault was previously in a relationship with the managing partner's son, the firm has said in a revised defamation complaint.
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October 01, 2025
Wyden Probes Crypto Investor's Possible Tax Bill Dodging
The Senate Finance Committee's Democratic staff is investigating whether a billionaire cryptocurrency investor improperly avoided more than $100 million in U.S. taxes by misrepresenting his residency in Puerto Rico and taking advantage of a tax program available to residents, committee ranking member Ron Wyden, D-Ore., said Wednesday.
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October 01, 2025
Calif. Importer, Son Both Get Prison For $8M Customs Fraud
A California federal judge sentenced a Los Angeles Fashion District business owner and his son to more than eight years and seven years in prison, respectively, after they were found guilty of ducking more than $8 million in customs duties and failing to report over $17 million in cash transactions on tax returns.
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October 01, 2025
Tax Court Backs IRS' Rejection Of Excise Tax Debt Settlement
The Internal Revenue Service was justified in rejecting an inspection company's bid to settle $9 million worth of unpaid excise taxes related to the company's failure to meet minimum funding standards for its employee pension plan, the U.S. Tax Court said Wednesday.
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October 01, 2025
Senate Panel Urged To Update Tax Code For Digital Assets
Congress needs to create tax rules for digital assets such as cryptocurrency and nonfungible tokens because the current regime creates uncertainty for taxpayers, digital asset stakeholders told the Senate Finance Committee on Wednesday.
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October 01, 2025
IRS Appeals Launches Post-Review Mediation Pilot Program
The IRS Office of Appeals launched a two-year mediation pilot program that reassigns cases to new teams after going through the administrative review to give taxpayers a faster and more independent process to resolve disputes before they pursue litigation, the agency announced Wednesday.
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October 01, 2025
States, Businesses Push Justices To Extend Tariff Arguments
The dozen states, several small businesses and Illinois toymakers that challenged President Donald Trump's emergency tariffs filed a joint motion Wednesday requesting more time to better represent their different claims for oral arguments at the U.S. Supreme Court in November.
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October 01, 2025
11th Circ. Denies Fla. Biz Owner's $2M Tax Challenge
The owner of a Florida marketing business is on the hook for more than $2 million in taxes and penalties after the Eleventh Circuit found that he filed his notice of appeal too late.
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October 01, 2025
Groups Seek Block On Use Of IRS, SSA Data For Deportations
A coalition of immigrant advocacy groups has asked a Massachusetts federal judge to block the government from the "unfettered" use of Internal Revenue Service and Social Security Administration data to identify and target millions of people for deportation.
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October 01, 2025
Caplin & Drysdale Adds Longtime IRS Pro To DC Office
Caplin & Drysdale has grown its Washington, D.C., office with the addition of a veteran Internal Revenue Service attorney, the firm announced Wednesday.
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October 01, 2025
IRS Sets March Deadline For Research Credit Form Comments
The Internal Revenue Service said Wednesday that the public has until the end of March to submit feedback on the draft form for reporting the research tax credit, saying the feedback deadline extension would give businesses more time to meet the incentive's requirements.
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October 01, 2025
IRS Final Property Capitalization Rule Allows More Deductions
Taxpayers will be able to deduct more interest rather than having to capitalize it when making improvements to property under final regulations released Wednesday by the Internal Revenue Service.
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October 01, 2025
8th Circ. Reverses IRS Win In 3M Transfer Pricing Case
The Eighth Circuit reversed a U.S. Tax Court ruling Wednesday that backed the Internal Revenue Service's decision to reallocate nearly $24 million of 3M Co.'s Brazilian income, holding that the transfer pricing regulations underlying the adjustment are invalid.
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September 30, 2025
IRS To Rework Corporate AMT Proposed Regs
The Internal Revenue Service plans to revise proposed regulations for the corporate alternative minimum tax, the agency announced Tuesday, including rules that would lessen businesses' compliance demands and costs tied to assessing their liability.
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September 30, 2025
ACA Tax Credit Impasse Pushes Gov't Into Shutdown
The federal government shut down Tuesday night after congressional lawmakers failed to reach an agreement with the White House on a short-term government funding bill that would also extend the enhanced tax credits for the Affordable Care Act that expire at the end of December.
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September 30, 2025
Justices Could Enable IEEPA Taxes On Any Trade, Experts Say
If the U.S. Supreme Court decides that a president's power to regulate imports and exports under the International Emergency Economic Powers Act encompasses tariffs, a president could tax services, investments and intellectual property flowing into or out of the country, trade experts said Tuesday.
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September 30, 2025
Tax Court Asked To Revive $27M Break For Historic Building
A Pennsylvania partnership is entitled to a nearly $27 million tax deduction for donating a historic preservation easement over property in Philadelphia, the partnership told the U.S. Tax Court in a challenge to the IRS' denial of the tax break.
Expert Analysis
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Writing Musicals Makes Me A Better Lawyer
My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.
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How Fashion, Tech Can Maximize New Small Biz Tax Breaks
Fashion and technology companies, which invest heavily in innovation, should consider taking advantage of provisions in the One Big Beautiful Bill Act that favor small businesses, restructuing if necessary to become eligible for expanded research and experimental expenditure credits and qualified small business stock incentives, says Aime Salazar at Olshan Frome.
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Adapting To Private Practice: From Va. AUSA To Mid-Law
Returning to the firm where I began my career after seven years as an assistant U.S. attorney in Virginia has been complex, nuanced and rewarding, and I’ve learned that the pursuit of justice remains the constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.
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7 Document Review Concepts New Attorneys Need To Know
For new associates joining firms this fall, stepping into the world of e-discovery can feel like learning a new language, but understanding a handful of fundamentals — from coding layouts to metadata — can help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.
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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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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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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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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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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.