Federal
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May 05, 2025
Feds Say Calif. Tribe's Challenge To Cig Ruling Is 'Fruitless'
The federal government is urging a California federal court not to pause a ruling affirming the Bureau of Alcohol, Tobacco, Firearms and Explosives' decision to place a native tribe on a noncompliance list over cigarette sales, saying the tribe shouldn't be able to upend the status quo as it pursues a "fruitless" appeal to the Ninth Circuit.
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May 05, 2025
Trump Seeks 100% Tariff On Foreign-Made Movies
President Donald Trump asked his administration to place a 100% tariff on foreign-made movies, with a spokesperson telling Law360 on Monday that a final decision on the plan hadn't been made.
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May 05, 2025
Minn. Tribe Looks To Weigh In On 3,000-Acre Land Trust Row
The Mille Lacs Band of Ojibwe has asked a Minnesota federal judge to let it file a friend of the court brief in a county's case claiming the U.S. government wrongly accepted more than 3,000 acres of land into trust for the tribe.
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May 05, 2025
Trump Admin Defends Tariff Power In Toy-Makers' Challenge
President Donald Trump's administration urged a D.C. federal court to deny a request by toy companies to halt global tariffs, arguing the government is authorized to impose trade measures under the International Emergency Economic Powers Act.
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May 05, 2025
IRS Audit Staff Slashed From Layoffs, Voluntary Resignations
Layoffs and voluntary resignations at the Internal Revenue Service have significantly reduced the agency's revenue agents responsible for conducting audits, the Treasury Inspector General for Tax Administration said Monday.
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May 05, 2025
Tax Evader Can't Fight Related Taxes, Court Says
A South Dakota business owner who admitted to hiding income from the Internal Revenue Service cannot challenge the $120,000 the agency claims he owes in additional taxes for fraudulently failing to file returns, the U.S. Tax Court ruled Monday.
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May 05, 2025
Clifford Chance Adds Paul Weiss Exec Compensation Atty In NY
Clifford Chance LLP has added a Paul Weiss Rifkind Wharton & Garrison LLP transactional attorney in New York as co-chair of its U.S. executive compensation practice, the firm announced Monday.
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May 05, 2025
Tax Court Tosses Grandmother's Levy Challenge
The U.S. Tax Court tossed Monday a levy challenge by an Alabama woman who said she was the sole caregiver for her five grandchildren, ruling that she had already received the tax relief she sought when the IRS decided not to collect her overdue taxes.
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May 05, 2025
Co. Urges Ending IRS Cost-Sharing Rule After Justices' Ruling
A controversial rule requiring U.S. companies to include employee stock-based compensation in cost-sharing agreements with offshore affiliates should be scrapped following the U.S. Supreme Court's revocation of required judicial deference to agencies, a drug distributor told a Texas federal court in seeking a nearly $10 million tax refund.
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May 05, 2025
Novelist Owes $715K In FBAR Penalties, US Says
A Japanese author with U.S. citizenship faces penalties exceeding $715,000 for failing to report accounts she held at a Swiss bank, the U.S. government told a California federal court.
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May 02, 2025
Tax Case Can Proceed Despite Late Name Change, Court Says
The owner of a mail-order medical equipment company can move forward with his lawsuit against the federal government seeking to deduct a $5 million settlement payment, even though he didn't technically add his name to the case until after the deadline, the Court of Federal Claims said.
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May 02, 2025
Money Laundering, Tax Charges Nixed Vs. Crypto Operator
An Indiana federal judge dismissed the U.S. government's cases against a man accused of operating an unlicensed money transmitting business, laundering proceeds through cryptocurrency transactions and failing to file tax returns after finding his business was not subject to registration requirements, as the government had maintained.
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May 02, 2025
Nixon Peabody Appoints Finance, Tax Partner As DC Leader
Nixon Peabody LLP has appointed a more than 20-year veteran of the firm as its Washington, D.C., office managing partner, who focuses his practice on a range of corporate, finance and real estate matters, according to a Thursday announcement.
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May 02, 2025
Groups Seek Order Halting Trump's Restructuring Of Gov't
A California district court must stop federal agencies from moving ahead with President Donald Trump's directive to reorganize and terminate government workers, unions and other groups argued, calling for a temporary restraining order based on alleged harms from the administration's "radical restructuring."
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May 02, 2025
IRS Updates Rates For Foreign Insurance Company Equations
The Internal Revenue Service on Friday published updated domestic asset/liability and yields percentages for 2024 that foreign life insurance companies and foreign property and liability insurance companies need to compute their minimum effectively connected net investment income.
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May 02, 2025
Taxation With Representation: Goodwin, Haynes Boone
In this week's Taxation With Representation, Merck buys SpringWorks Therapeutics, Novartis AG acquires Regulus Therapeutics Inc., Sabre Corp. sells its Hospitality Solutions business to private equity shop TPG, and TWG Global and Mubadala Capital team up to bolster their investments.
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May 02, 2025
Community Groups Accept Pause In CTA Litigation
A group of community associations has told the Fourth Circuit they aren't opposed to a government motion to pause litigation over the Corporate Transparency Act, even as they maintained the information disclosure law aimed at small businesses still carries constitutional flaws.
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May 02, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included its announcement of plans to revoke partnership basis-shifting regulations that were finalized earlier this year.
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May 01, 2025
IRS Successfully Targeting Rich Nonfilers, But Can Improve
The Internal Revenue Service's targeted sweeps of so-called high-income nonfilers have largely been successful in closing cases and collecting revenue, but the agency could do more to target certain areas and collect tracking data better, the Treasury Inspector General for Tax Administration said.
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May 01, 2025
Trump Picks Tax Controversy Pro For IRS Chief Counsel Spot
President Donald Trump has tapped a former Internal Revenue Service chief counsel to return to the role, and if he is confirmed, it will represent the second time in his career that the veteran tax controversy professional will be the agency's top attorney.
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May 01, 2025
Tax Court Shuts Out Indirect Partners In Easement Dispute
Indirect partners who owned a small percentage of a partnership that settled a conservation easement deduction dispute with the IRS cannot intervene before the deal is final, the U.S. Tax Court ruled Thursday, saying they missed their chance to participate.
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May 01, 2025
Estate Pushes Back On IRS In DC Circ. Lost Records Case
The estate of a man whose offshore businesses were raided by the IRS, giving rise to a nearly $18 million tax judgment, criticized the agency's effort to rebuff the estate's claims to the D.C. Circuit that the IRS fraudulently claimed that boxes of evidence in ensuing litigation were lost.
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May 01, 2025
IRS Updates Inflation-Adjusted HSA Amounts For 2026
The Internal Revenue Service issued inflation-adjusted amounts Thursday for health savings accounts for 2026, as well as the maximum amount that may be made available for excepted benefit health reimbursement arrangements.
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May 01, 2025
Ex-Informant Who Smeared Bidens, Evaded Tax A 'Flight Risk'
A former FBI informant won't be released while he appeals his six-year prison sentence for tax evasion and falsely telling federal agents that a Ukrainian energy company paid off President Joe Biden and his son Hunter, a California federal judge ruled, saying he's a "flight risk."
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May 01, 2025
Hunter Biden Drops Tax Privacy Case Against IRS
Hunter Biden dropped his suit against the federal government alleging the unauthorized disclosure of his tax return information by special agents and their attorneys who talked publicly about an investigation that culminated in Biden's copping to criminal tax charges.
White House Budget Seeks $2.5B Cut From IRS Funding
The Internal Revenue Service's budget would be cut by nearly $2.5 billion compared with 2025 under the 2026 budget request released Friday by President Donald Trump's administration.
Multinationals Grapple With Tariff-Induced Pricing Issues
President Donald Trump's flurry of tariff actions since taking office has created new questions for multinationals and their transfer pricing tax planners, including how to properly account for cost increases associated with new duties in related party transactions.
IRS Likely To Feel Strain Of Layoffs Now Filing Season's Over
The IRS's filing season ran relatively smoothly with minimal disruptions to customer service and taxpayer assistance, but the impending loss of a quarter of the agency's employees is already wearing on its workforce and will likely erode customer service, refund processing and institutional knowledge, experts say.
White House Budget Seeks $2.5B Cut From IRS Funding
The Internal Revenue Service's budget would be cut by nearly $2.5 billion compared with 2025 under the 2026 budget request released Friday by President Donald Trump's administration.
Multinationals Grapple With Tariff-Induced Pricing Issues
President Donald Trump's flurry of tariff actions since taking office has created new questions for multinationals and their transfer pricing tax planners, including how to properly account for cost increases associated with new duties in related party transactions.
IRS Likely To Feel Strain Of Layoffs Now Filing Season's Over
The IRS's filing season ran relatively smoothly with minimal disruptions to customer service and taxpayer assistance, but the impending loss of a quarter of the agency's employees is already wearing on its workforce and will likely erode customer service, refund processing and institutional knowledge, experts say.
Featured Stories
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Tax Breaks For Offshore Production Could Thwart Tariffs' Goal
President Donald Trump has said that his wide-ranging tariffs will jump-start domestic industry and production, but an international tax policy created under the 2017 federal overhaul may undermine the goal of bringing manufacturing back to the U.S.
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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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Bill To Ax Church Politics Ban Reignites Free-Speech Debate
More than a dozen congressional Republicans support what they characterize as free-speech legislation to overturn a 1954 tax law barring churches from endorsing candidates, despite warnings from some lawmakers and others that it could weaken church-state separation and flood politics with a new source of dark money.
Expert Analysis
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How Attys Can Use A Therapy Model To Help Triggered Clients
Attorneys can lean on key principles from a psychotherapeutic paradigm known as the "Internal Family Systems" model to help manage triggered clients and get settlement negotiations back on track, says Jennifer Gibbs at Zelle.
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3 Steps For In-House Counsel To Assess Litigation Claims
Before a potential economic downturn, in-house attorneys should investigate whether their company is sitting on hidden litigation claims that could unlock large recoveries to help the business withstand tough times, says Will Burgess at Hilgers Graben.
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IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement
Tax crimes are historically difficult to prosecute, but the Internal Revenue Services’ recent agreement with U.S. Immigration and Customs Enforcement to share taxpayer records of non-U.S. citizens could be used to enhance payroll tax-related enforcement against their employers, say attorneys at Holland & Knight.
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Adapting To Private Practice: From DOJ Enviro To Mid-Law
Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares their principles, values their experience and will invest in their transition, says John Cruden at Beveridge & Diamond.
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Legal Ethics Considerations For Law Firm Pro Bono Deals
If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.
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10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks
The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.
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Notable Q1 Updates In Insurance Class Actions
The first quarter of 2025 was filled with the refinement of old theories in the property and casualty space, including in vehicle valuation, time to seek appraisal and materials depreciation, says Mathew Drocton at BakerHostetler.
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The Benefits Of Aligning States On Legal Paraprofessionals
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.
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10 Soft Skills Every GC Should Master
As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.
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An Unrestrained, Bright-Eyed View Of Legal AI's Future
Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.
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Tracking The Evolution In Litigation Finance
Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.
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E-Discovery Quarterly: The Perils Of Digital Data Protocols
Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.
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Maximizing Exemptions Before TCJA Rides Into The Sunset
Excerpt from Practical Guidance
Individuals with taxable estates can optimize the benefits of estate planning strategies like spousal lifetime access trusts by setting them up before increases in estate and gift tax exemptions under the 2017 Tax Cuts and Jobs Act sunset in January, say attorneys at Katten.