Federal
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November 17, 2025
Judge Questions Eaton's Role In Lowered Credit Rating
Tax Court Judge Albert Lauber questioned an expert for Eaton on Monday about how he arrived at a lowered credit rating for the U.S. company in a report he prepared in January 2013, shortly after it acquired an Irish-based global electrical products manufacturer and inverted.
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November 17, 2025
Atty 'Misplaced' Trust In Par Funding Promoter, Panel Hears
A former Eckert Seamans Cherin & Mellott LLC attorney accused of ethical violations related to promoting the Par Funding merchant cash advance business told a Pennsylvania disciplinary panel Monday that all he did was zealously represent his client, who pitched the ill-fated enterprise to potential investors.
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November 17, 2025
Ex-Russian Gas CFO Resentenced To 6 Years For Tax Crimes
A Florida federal judge handed a nearly six-year prison term to a Russian gas company's former chief financial officer, who was convicted for tax evasion after the Eleventh Circuit vacated a prior sentence earlier this year.
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November 17, 2025
Feds Back IRS Agent Testimony In Goldstein Tax Case
An Internal Revenue Service agent must be allowed to testify in Tom Goldstein's tax evasion case, the U.S. government said, arguing that the agent's testimony is relevant to proving willfulness in the tax crimes the U.S. Supreme Court attorney and SCOTUSblog publisher was charged with.
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November 17, 2025
Applicable Federal Rates To Continue Monthslong Slide
Applicable federal rates for income tax purposes will decrease in December, the Internal Revenue Service said Monday, sliding for the fifth month in a row after a rebound in July.
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November 17, 2025
Fed. Circ. Finds Baby Formulas For Illnesses Duty-Free
A baby formula maker's products designed as therapies for children with chronic medical conditions qualify for duty-free treatment, the Federal Circuit ruled Monday, overturning the U.S. Court of International Trade's decision in a decade-old dispute.
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November 17, 2025
Minn. Dentist's Wife Can't Feign Ignorance, Tax Court Says
The U.S. Tax Court granted a Minnesota woman only partial relief Monday from shared tax liabilities with her former husband, holding that an Internal Revenue Service agent's visit marked "the dividing line" when she could no longer claim not to know about their unpaid taxes.
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November 17, 2025
OMB Reviewing Treasury Regs On OECD Crypto Reporting
The Office of Management and Budget is reviewing regulations proposed by the U.S. Department of the Treasury to implement automatic exchanges of information between tax authorities regarding taxpayers' cryptocurrency holdings under the OECD's crypto-asset reporting framework.
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November 17, 2025
MVP: Sullivan & Cromwell's Isaac Wheeler
Isaac Wheeler of Sullivan & Cromwell LLP's tax practice advised RedBird Capital Partners on the Skydance and Paramount deal, helped xAI and X on a $113 billion transaction related to their merger and guided Tishman Speyer on its $3.5 billion refinancing of Rockefeller Center, earning him a spot as one of the 2025 Law360 Tax MVPs.
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November 17, 2025
Fed. Circ. Backs Commerce To Nix Turkish Steel Duties
The U.S. Department of Commerce's removal of countervailing duties on Turkish steel imports was properly justified by the government, and the lower trade court correctly upheld its determination despite objections by the domestic steel industry, the Federal Circuit affirmed Monday.
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November 17, 2025
Madoff Victims Lose Bid To Claim $8.2M Theft Loss Deduction
A New York couple lost their challenge to claim a $8.2 million theft loss tax deduction on life insurance policies invested in accounts tied to Bernie Madoff's Ponzi scheme after the Second Circuit found that the husband did not own the policies' underlying assets.
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November 14, 2025
IRS Expert Challenges Data Used In Eaton's Projections
An expert witness for the Internal Revenue Service questioned the financial projections prepared by Eaton Corp.'s experts Friday in U.S. Tax Court, saying the data they relied on wasn't available in 2012, when the company took on debt to acquire Ireland-based Cooper Industries, a global electrical products manufacturer, for $13 billion.
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November 14, 2025
The Tax Angle: Letter Ruling Debate, Experts' Role In Policy
From a discussion on whether seeking a private letter ruling risks sparking more IRS oversight to a former Congressional Budget Office director's thoughts on tax experts' role in policymaking, here's a peek into a reporter's notebook on stories from the National Tax Association's annual conference in Boston.
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November 14, 2025
Trump Pulls IRS Chief Counsel Nomination Before Floor Vote
President Donald Trump on Friday withdrew his nomination of a Sullivan & Cromwell attorney to be the Internal Revenue Service's chief counsel just weeks after the Senate Finance Committee voted to advance the nomination to the Senate floor.
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November 14, 2025
MVP: Latham's Pardis Zomorodi
Pardis Zomorodi, partner at Latham & Watkins LLP's transactional tax practice in Los Angeles, has guided companies through the tax aspects of major complex transactions, including 2024's largest IPO and the high-profile merger between Skydance Media and Paramount Global, earning her a spot as one of the 2025 Law360 Tax MVPs.
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November 14, 2025
DC Circ. Urged To Block Trump Org. From IRS Leaker's Appeal
President Donald Trump's private business organization should not be allowed to intervene in a former IRS contractor's challenge to his prison sentence for leaking Trump's and other wealthy people's tax returns, the contractor told the D.C. Circuit, saying the organization's participation would unfairly bias the court.
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November 14, 2025
US To Slash Tariff On Swiss Imports To 15% In Trade Deal
The U.S. will reduce a 39% tariff on Swiss imports to 15% as part of a framework trade agreement reached with Switzerland, according to Friday announcements by the White House and the Swiss government.
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November 14, 2025
Taxation With Representation: Wachtell, Paul Hastings, Sidley
In this week's Taxation With Representation, Pfizer Inc. completes its acquisition of obesity drug developer Metsera Inc., motion and controls technologies company Parker-Hannifin Corp. acquires Filtration Group Corp., and fund administrator JTC PLC backs a cash offer in the billions from British private equity shop Permira.
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November 14, 2025
Biz Contests $1.7M Tax Bill After Insurance Deductions Axed
The Internal Revenue Service incorrectly hit a Colorado corporation with $1.7 million in taxes and penalties after erroneously disallowing deductions the company claimed for insurance premiums, the company told the U.S. Tax Court in a petition published Friday.
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November 14, 2025
Liquidated Captive Insurer Fights IRS Bill In Tax Court
A captive insurance company that was later dissolved challenged $800,000 in taxes and penalties in the U.S. Tax Court, saying the Internal Revenue Service wrongly claimed the company had $3 million in unreported long-term capital gains.
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November 14, 2025
US Expatriations Rise To 1,600 In 3rd Quarter, IRS Says
The number of people who lost or renounced their U.S. citizenship totaled 1,600 in the third quarter as logged by the U.S. Treasury Department, a 50% increase from the previous quarter, the IRS said Friday.
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November 14, 2025
Ala. Partnerships Say IRS Erred Rejecting Easement Breaks
The Internal Revenue Service unlawfully denied a pair of Alabama partnerships' $40 million charitable tax deduction on a conservation easement they donated in 2020, the partnerships told the U.S. Tax Court, arguing the agency offered no sufficient explanation for its determination.
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November 14, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service released its weekly internal revenue bulletin Friday, which included guidance for group health plans and health insurers to calculate out-of-network healthcare coverage for 2026.
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November 13, 2025
Eaton Witnesses Probed About Data Used For Credit Analysis
An accounting expert and a former Eaton Corp. official both advised the U.S. Tax Court on Thursday about the data used to establish the financial position of the U.S. company after its acquisition of Irish-based Cooper Industries in 2012.
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November 13, 2025
Clean Energy Cos. Tap Private Cash To Beat Tax Credit Clock
Clean energy developers are increasingly looking to privately held investors to ensure they can do enough work to keep their projects fully eligible for tax credits that start phasing out next year, energy development attorneys told Law360.
Expert Analysis
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Adapting To Private Practice: From US Attorney To BigLaw
When I transitioned to private practice after government service — most recently as the U.S. attorney for the Eastern District of Virginia — I learned there are more similarities between the two jobs than many realize, with both disciplines requiring resourcefulness, zealous advocacy and foresight, says Zach Terwilliger at V&E.
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Opportunity Zone Revamp Could Improve The Program
If adopted, the budget bill's new iteration of the opportunity zone program could renew, refine and enhance the effectiveness and accountability of the original program by including structural reforms, expanded eligibility rules and incentives for rural investment, say attorneys at Pillsbury.
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The Ins And Outs Of Consensual Judicial References
As parties consider the possibility of judicial reference to resolve complex disputes, it is critical to understand how the process works, why it's gaining traction, and why carefully crafted agreements make all the difference, say attorneys at Pillsbury.
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The BigLaw Settlements Are About Risk, Not Profit
The nine Am Law 100 firms that settled with the Trump administration likely did so because of the personal risk faced by equity partners in today's billion‑dollar national practices, enabled by an ethics rule primed for modernization, says Adam Forest at Scale.
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House Bill Tax Tweaks Would Hinder Renewable Projects
Provisions in the budget reconciliation bill recently passed by the U.S. House of Representatives would rapidly phase out clean energy tax credits, constrain renewable energy financing arrangements and impose sweeping restrictions on projects with foreign ties, which may create compliance and supply chain issues for many developers, say attorneys at Paul Hastings.
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Power To The Paralegals: An Untapped Source For Biz Roles
Law firms looking to recruit legal business talent should consider turning to paralegals, who practice several key skills every day that prepare them to thrive in marketing and client development roles, says Vanessa Torres at Lowenstein Sandler.
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How Trucking Cos. Can Keep Rolling Under Tariff Burdens
Recent Trump administration tariffs present major challenges for the transportation and logistics sector — and, in particular, trucking — but providers who focus on operational efficiency, cost control, customer relationships, creative contract structures and unique offerings will stand out from the competition, say attorneys at Benesch.
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Tariff Strategies For The US Renewable Energy Sector
The Trump administration's tariff actions over the last few months are challenging for the renewable energy industry — but there are strategies for contending with the uncertainty, including diversifying supply chains, seeking certification about equipment origins, and adding tariff-related language to supply contracts and offtake agreements, say attorneys at Sheppard Mullin.
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Ch. 7 Marshaling Ruling Rests On Shaky Legal Grounds
In its recent holding in a Chapter 7 bankruptcy case that marshaling may not be applied against the IRS, a Texas federal court misapplied a bankruptcy code section and case law, leaving a draconian decision that could limit the scope of a powerful equitable estate tool, says Brian Shaw at Cozen O'Connor.
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3 Tax Issues Manufacturers Should Watch In 2025 Budget Bill
As Congress works toward a budget reconciliation bill, manufacturing companies should keep a keen eye on proposals to change bonus depreciation, the qualified business income deduction and energy tax credits, which could have a significant impact on capital-intensive industries, say attorneys at Frost Brown Todd.
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$38M Law Firm Settlement Highlights 'Unworthy Client' Perils
A recent settlement of claims against law firm Eckert Seamans for allegedly abetting a Ponzi scheme underscores the continuing threat of clients who seek to exploit their lawyers in perpetrating fraud, and the critical importance of preemptive measures to avoid these clients, say attorneys at Lockton Companies.
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Jurisdictional Issues At Play In 9th Circ.'s FCA Trade Case
A decision by the Ninth Circuit in Island Industries v. Sigma Corp. could result in the U.S. Court of International Trade’s exclusive jurisdiction over trade-related FCA cases, a big shift in the enforcement landscape just as tariffs take center stage in trade policy, say attorneys at Haynes Boone.
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Evolving Federal Rules Pose Further Obstacles To NY LLC Act
Following the Financial Crimes Enforcement Network's recent changes to beneficial ownership information reporting under the federal Corporate Transparency Act — dramatically reducing the number of companies required to make disclosures — the utility of New York's LLC Transparency Act becomes less apparent, say attorneys at Pillsbury.