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Tax
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October 24, 2025
Taxation With Representation: Latham, Wachtell, Gibson Dunn
In this week's Taxation With Representation, Meta announces a joint venture with Blue Owl Capital to fund the development of a data center campus in Louisiana, private equity giants acquire medical technology company Hologic Inc., and National Fuel Gas Co. buys CenterPoint Energy Inc.'s Ohio natural gas utility business.
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October 24, 2025
Talks On Shipping Carbon Price Continue Despite Plan's Delay
The United Nations' maritime agency continued talks on the details of a global carbon price plan for shipping this past week despite the recent postponement of the plan amid U.S. opposition, experts taking part in the process said Friday.
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October 24, 2025
Mass. Appeals Court Finds No Evidence To Drop Home's Value
A Massachusetts homeowner failed to show that a local assessor overvalued his property and made procedural errors, the state appeals court ruled Friday, upholding his property's value.
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October 24, 2025
Partnership Fights For $15M Easement Deduction In Tax Court
The Internal Revenue Service didn't explain its determinations and therefore violated administrative law when it denied an Alabama partnership a $14.8 million deduction for donating a conservation easement in 2020, the partnership told the U.S. Tax Court.
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October 23, 2025
Ex-Mich. Speaker Aide Cops To Embezzlement, Will Testify
A former top staffer for former Michigan House Speaker Lee Chatfield pled guilty to embezzling from a political nonprofit while working for the state and, as part of a plea deal, has agreed to provide "truthful testimony in future hearings," according to an announcement made Thursday.
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October 23, 2025
Legislation May Fix Tax Court Jurisdiction Feud, Judge Says
Senate legislation to expand the U.S. Tax Court's authority to order refunds and credits in collection cases could settle a long-running dispute revived by the U.S. Supreme Court's decision to limit the tax tribunal's jurisdiction, a judge said Thursday.
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October 23, 2025
Fed. Circ. Affirms No Tax Refunds For Retired United Pilots
United Airlines pilots who said they overpaid payroll taxes because of the early termination of their retirement plan in the company's bankruptcy can't get partial refunds, the Federal Circuit affirmed Thursday, saying procedural issues doomed their case.
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October 23, 2025
French Legislators Advance 15% DST To Mirror US Tariffs
France's digital services tax rate would rise from 3% to 15% under an amendment adopted by the lower house of Parliament's Finance Committee, which characterized the action as a "proportionate response" to tariffs imposed by the United States.
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October 23, 2025
Mass. Tax Break Bill For Urban Farms Advances
Massachusetts would allow municipalities to create an agricultural property tax break for small urban farm plots under a bill reported favorably by a state legislative panel.
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October 23, 2025
US Oil Cos. Pay More Tax Abroad Than At Home, Report Says
American oil and gas companies with foreign extraction operations paid more than 80% of their total taxes abroad in recent years despite producing more oil and gas in the U.S. than everywhere else combined, a corporate transparency group said Thursday.
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October 23, 2025
UK Court Denies Leisure Firm's Bid For Extra VAT Interest
A leisure services company can't claim additional interest of £8.2 million ($11 million) on value-added tax overpaid to HM Revenue & Customs because statutory interest provided full compensation, a British court ruled.
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October 23, 2025
Court Won't Rethink 'Survivor' Winner's $3M Tax Bill
A Rhode Island federal judge won't reconsider his opinion that the first winner of reality show "Survivor" must pay $3.3 million in taxes, maintaining that it is unclear whether the federal government can take his sister's property to pay down the debt.
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October 23, 2025
Eaton To Defend Interest Rates, Fees Paid After 2012 Inversion
Eaton is preparing to defend the interest rates and guarantee fees paid by entities in the U.S. to their newly formed Irish parent after the company's 2012 acquisition and inversion at a U.S. Tax Court trial scheduled to start Nov. 3.
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October 22, 2025
Banks Want Ill. Fee Law Block Extended To Card Networks
Banking industry groups urged an Illinois federal judge Wednesday to permanently block an Illinois law that bans swipe fees on tax and tip portions of payment card transactions, arguing she has already correctly held that national banks are federally preempted from its reach, and that the court should extend that relief to card networks and others involved in the payment process.
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October 22, 2025
Australia Issues Guidance For Minimum Tax Safe Harbor
Australia released guidance Wednesday detailing when companies can forgo detailed top-up tax calculations for a jurisdiction under a safe harbor for the 15% global minimum tax that is based on country-by-country reporting.
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October 22, 2025
US Among Few Places With Amount B Rules, OECD Reports
The U.S. is a significant exception to a swath of countries, including China, Japan and the U.K., that lack domestic rules allowing companies to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, the OECD reported Wednesday.
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October 22, 2025
Tax Court Judge Warns Against Unchecked AI Use In Filings
A U.S. Tax Court judge cautioned attorneys Wednesday against relying on artificial intelligence to write filings without verifying the information it generates, saying recent "unfortunate incidents" have prompted the court to double down on accuracy in using such tools.
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October 22, 2025
'The Right Facts' Can Reduce Cos.' Tariff Impacts, Atty Says
Multinational companies with U.S. distributors that typically bear fewer business risks and earn low profit margins may be able to mitigate the effect of U.S. tariffs on their business as a whole by having a foreign principal bear the tariff costs, an attorney said Wednesday.
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October 22, 2025
COST Urges Ky. Justices To Reject Walgreens' Tax Valuations
Kentucky's Supreme Court should reverse an appeal court's ruling finding that a local assessor correctly took above-market contract rents into consideration when valuing several Walgreen store properties, the Council on State Taxation said, because it unfairly raised their assessed values.
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October 22, 2025
Presidential Firing Limits Fight Builds At High Court
The ousted U.S. Merit Systems Protection Board chair has encouraged the U.S. Supreme Court to include a caveat for "legislative courts" if it overturns precedent that empowers Congress to limit the president's authority to fire certain agency officials, but opponents of independent agencies want a clean break from the status quo.
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October 22, 2025
Trade Court OKs $235K Tax Bill On Korean Soju Imports
South Korean alcoholic beverages were improperly classified upon entering the U.S., and U.S. Customs and Border Protection correctly calculated a nearly $235,000 bill in unpaid federal excise taxes plus interest, according to the U.S. Court of International Trade.
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October 22, 2025
Widow Not Liable For Husband's Tax Debt, 4th Circ. Told
An 80-year-old widow whose husband was imprisoned after hiding more than $20 million from the IRS told the Fourth Circuit that he was "abusive and controlling" and that she shouldn't have to pay the millions of dollars they jointly owe, despite contrary claims by the government.
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October 22, 2025
NY Bill Seeks Clean Energy Payment Exemption For Tax Caps
New York would exempt payments in lieu of taxes for renewable energy projects from local governments' property tax cap calculations under a bill introduced in the state Assembly.
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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 Company 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.
Expert Analysis
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Series
Birding Makes Me A Better Lawyer
Observing and documenting birds in their natural habitats fosters patience, sharpens observational skills and provides moments of pure wonder — qualities that foster personal growth and enrich my legal career, says Allison Raley at Arnall Golden.
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Measuring And Mitigating Harm From Discriminatory Taxes
In response to new tariffs and other recent "America First Trade Policy" pronouncements, corporations should assess and take steps to minimize their potential exposure to discriminatory and reciprocal tax measures that are likely to come, say economists at Charles River Associates.
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Series
Adapting To Private Practice: From DOJ Leadership To BigLaw
The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.
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How The CRE Industry Is Adapting To Tariff Uncertainty
Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.
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Law Firm Executive Orders Create A Legal Ethics Minefield
Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.
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Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike
The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.
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Firms Must Embrace Alternative Billing Models Or Fall Behind
As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.
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How Trump Policies Are Affecting The Right To Repair
Recent policy changes by the second Trump administration — ranging from deregulatory initiatives to tariff increases — are likely to have both positive and negative effects on the ability of independent repair shops and individual consumers to exercise their right to repair electronic devices, say attorneys at Carter Ledyard.
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How Attorneys Can Master The Art Of On-Camera Presence
As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.
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Series
Baseball Fantasy Camp Makes Me A Better Lawyer
With six baseball fantasy experiences under my belt, I've learned time and again that I didn't make the wrong career choice, but I've also learned that baseball lessons are life lessons, and I'm a better lawyer for my time at St. Louis Cardinals fantasy camp, says Scott Felder at Wiley.
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Series
Adapting To Private Practice: From Fed. Prosecutor To BigLaw
Making the jump from government to private practice is no small feat, but, based on my experience transitioning to a business-driven environment after 15 years as an assistant U.S. attorney, it can be incredibly rewarding and help you become a more versatile lawyer, says Michael Beckwith at Dickinson Wright.
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Justices' False Statement Ruling Curbs Half-Truth Liability
The U.S. Supreme Court’s recent Thompson v. U.S. decision clarified that a federal statute used to prosecute false statements made to bank regulators only criminalizes outright falsehoods, narrowing prosecutors’ reach and providing defense counsel a stronger basis to challenge indictments of merely misleading statements, says Tamara de Silva at De Silva Law Offices.
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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.