Federal
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September 04, 2025
Tax Court Affirms SC Man's Tax Deficiency, Penalties
A South Carolina man owes the IRS more than $16,000 after underreporting his income for the 2018 tax year, and he is liable for a $10,000 penalty, the U.S. Tax Court said in an opinion Thursday.
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September 04, 2025
Ex-CEO Should Start Sentence For Tax Crimes, Court Told
A former software executive convicted of failing to pay employment taxes should not be allowed again to delay reporting to prison, the government told a North Carolina federal court Thursday, saying the man's new dental issues weren't serious enough to stop him from beginning his sentence.
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September 04, 2025
PBM Rule Included In DOL Benefits Arm's Regulatory Update
The U.S. Department of Labor's employee benefits arm detailed several new regulations in the works Thursday, including a new fee disclosure rule involving pharmacy benefit managers and plans to revisit retirement plan fiduciary investment advice regulations, according to the administration's latest regulatory update.
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September 04, 2025
Gov't Can Foreclose On Physician's Home Over $2M Tax Debt
A physician and his wife owe more than $2 million in unpaid taxes after failing to file returns for nearly a decade, a Texas federal court found, ruling that the U.S. government can sell the couple's home to help pay the debt.
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September 04, 2025
Gov't Urges Justices To Fast-Track Emergency Tariff Suit
The U.S. Supreme Court must consider under a proposed fast-track schedule the Federal Circuit's finding of President Donald Trump's emergency tariffs as unlawful or jeopardize the recent bilateral trade agreements and the improvements to the U.S. economy as a result of those duties, the administration said.
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September 03, 2025
House Appropriations Panel Advances $2.8B IRS Funding Cut
The House Appropriations Committee approved legislation Wednesday that would cut the Internal Revenue Service's funding by $2.8 billion for the 2026 fiscal year, sending the proposal to the full House for consideration.
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September 03, 2025
11th Circ. Affirms Prison Sentence For False Tax Returns
A Florida tax return preparer who admitted to helping prepare false returns must finish serving more than two years in prison, the Eleventh Circuit ruled Wednesday, rejecting his claim that his employees were to blame.
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September 03, 2025
Northwestern Mutual Seeks $23M Tax Refund For Free Meals
Northwestern Mutual is seeking a refund of $23 million in taxes for on-campus lunches it provided to employees, telling a Wisconsin federal court that the IRS improperly denied the company an exclusion on taxable income for the meals.
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September 03, 2025
Senate To Hold Treasury, IRS Nomination Hearings Next Week
The Senate Finance Committee said Wednesday that it has scheduled nomination hearings for high-ranking officials at the U.S. Department of the Treasury and the Internal Revenue Service for Sept. 10.
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September 03, 2025
Software Co. Founder Fights $100M Tax Bill At 11th Circ.
A software company founder facing more than $100 million in tax debt from his participation in an illegal tax shelter should have been allowed to settle with the Internal Revenue Service for $1.5 million because he can't pay the whole bill, he told the Eleventh Circuit.
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September 02, 2025
Jury Misled On Tax Fraud Conspiracy Charge, 10th Circ. Rules
The Tenth Circuit overturned Tuesday a conviction against a man who did not report trust income on his personal tax returns, saying the New Mexico district court erred in presenting instructions on the conspiracy charges to both the jury and defendant's counsel.
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September 02, 2025
Firm Urges 2nd Circ. To Review $142M Earnings Boost
A New York investment company has asked the Second Circuit to review a U.S. Tax Court ruling that sustained a $142 million increase to its net earnings and found its principals did not qualify as limited partners for an exception from self-employment income tax.
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September 02, 2025
Most Employers Paid Taxes After COVID Delay, Report Says
Most employers who put off paying Social Security taxes during the pandemic have paid their bills, the Treasury Inspector General for Tax Administration said Tuesday, although some employers who didn't pay were incorrectly charged penalties by the IRS.
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September 02, 2025
IRS Withdraws Rule On Tax Data Use In Passport Revocations
The IRS will scrap a 2018 proposed rule that would have allowed the U.S. State Department to share taxpayer return information with contractors that assist in the revocation or denial of passports of individuals with serious tax debts, the agency announced Monday, calling the rule unnecessary.
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September 02, 2025
Colgate-Palmolive To Shell Out $332M In Pension Payout Fight
Colgate-Palmolive retirees asked a New York federal judge to greenlight a $332 million class action deal in their suit claiming the household products company shorted them on lump-sum retirement payouts, signaling the end of a nearly decade-old case that reached the Second Circuit in 2023.
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August 29, 2025
Split Fed. Circ. Backs Limits On Presidential Tariff Powers
The Federal Circuit held that President Donald Trump's emergency tariffs were improperly imposed under the International Emergency Economic Powers Act, which it said makes no mention of "tariff," "duties" or "tax."
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August 29, 2025
Bookie Who Took Bets From Ohtani Interpreter Gets 1 Year
A resident of Orange County, California, was sentenced to a year and a day in prison on Friday after pleading guilty to operating as an unlicensed bookmaker who placed bets for current and former professional athletes as well as a Japanese language interpreter who is serving time for stealing from baseball megastar Shohei Ohtani.
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August 29, 2025
House Dems Reintroduce Marijuana Legalization Bill Again
Democrats in the U.S. House of Representatives once again reintroduced a federal marijuana legalization bill that previously passed the chamber twice when it was under Democratic control, but has never gained traction in the U.S. Senate or under a majority-Republican House.
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August 29, 2025
Federal Tax Policy To Watch In The Rest Of 2025
As Congress returns to Washington, D.C., after the August recess, the bulk of federal tax policy is expected to focus on funding the IRS past Sept. 30 and getting out guidance for retroactive deductions included in this summer's budget reconciliation bill. Here's a look at federal tax policy to watch during the rest of the year.
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August 29, 2025
Apple Must Hand Swiss User's Records To IRS, Judge Rules
Apple must provide the Internal Revenue Service with a Swiss user's internet and phone records as part of a criminal investigation by Switzerland's taxing authority, a California federal judge ruled, despite the man's protests that the records are unrelated to taxes.
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August 29, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the removal of a method for large-scale clean energy projects to establish eligible construction start dates in order to claim solar and wind tax credits.
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August 29, 2025
Taxation With Representation: White & Case, Paul Weiss
In this week's Taxation With Representation, private equity firm Sycamore Partners completes its $24 billion acquisition of Walgreens Boots Alliance Inc., telecommunications company EchoStar sells wireless spectrum licenses to AT&T and Keurig Dr Pepper acquires JDE Peet's in a deal that aims to create a "global coffee champion."
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August 28, 2025
Coke Says IRS Taking 'Extreme' Position In $2.7B Dispute
The IRS is taking an "extreme" position in its defense of a $2.7 billion tax ruling against Coca-Cola by asserting that the standard prohibiting arbitrary and capricious actions by an agency doesn't apply to it, the company told the Eleventh Circuit.
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August 28, 2025
6th Circ. Affirms Dismissal Of Meritless Tax Challenge
The Sixth Circuit affirmed the dismissal of a Tennessee man's suit against the Internal Revenue Service, ruling Wednesday that his challenge to the agency's tax collections was meritless and provided no basis for federal jurisdiction.
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August 28, 2025
Illinois Atty Gets 2½ Years For Tax Fraud, Scripting Testimony
A former Chicago attorney who covered up $1 million in payments to his romantic interest and tried scripting his bookkeeper's initial trial testimony has been sentenced to two and a half years in prison, federal prosecutors announced Thursday.
ABA Tax President-Elect Plans To Build On Section's Success
Lisa Zarlenga, a Steptoe LLP partner, is serving as president-elect of the American Bar Association's Section of Taxation for the 2025–2026 term, officially taking on the role this month with the goal of building the strength of the organization for the next generation of tax attorneys. In an interview with Law360, Zarlenga discussed what she enjoys about tax practice, how the section has shaped her career and her vision for strengthening the organization to support future generations of tax attorneys.
Tax Court Must Reconsider Medtronic Pricing, 8th Circ. Says
The U.S. Tax Court should reconsider its use of a hybrid approach for pricing intangibles that Medtronic licensed to a Puerto Rican affiliate, the Eighth Circuit said Wednesday, vacating the ruling and directing the court to revisit the IRS' pricing method.
11th Circ. Affirms Slashing Ex-Braves' $47M Easement Break
A $47 million conservation easement deduction for a partnership founded by two former Atlanta Braves players was overvalued, the Eleventh Circuit affirmed Tuesday, saying none of the partnership's arguments undermined the U.S. Tax Court's finding that the easement property was worth far less than it claimed.
ABA Tax President-Elect Plans To Build On Section's Success
Lisa Zarlenga, a Steptoe LLP partner, is serving as president-elect of the American Bar Association's Section of Taxation for the 2025–2026 term, officially taking on the role this month with the goal of building the strength of the organization for the next generation of tax attorneys. In an interview with Law360, Zarlenga discussed what she enjoys about tax practice, how the section has shaped her career and her vision for strengthening the organization to support future generations of tax attorneys.
Tax Court Must Reconsider Medtronic Pricing, 8th Circ. Says
The U.S. Tax Court should reconsider its use of a hybrid approach for pricing intangibles that Medtronic licensed to a Puerto Rican affiliate, the Eighth Circuit said Wednesday, vacating the ruling and directing the court to revisit the IRS' pricing method.
11th Circ. Affirms Slashing Ex-Braves' $47M Easement Break
A $47 million conservation easement deduction for a partnership founded by two former Atlanta Braves players was overvalued, the Eleventh Circuit affirmed Tuesday, saying none of the partnership's arguments undermined the U.S. Tax Court's finding that the easement property was worth far less than it claimed.
Featured Stories
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ABA Tax President-Elect Plans To Build On Section's Success
Lisa Zarlenga, a Steptoe LLP partner, is serving as president-elect of the American Bar Association's Section of Taxation for the 2025–2026 term, officially taking on the role this month with the goal of building the strength of the organization for the next generation of tax attorneys. In an interview with Law360, Zarlenga discussed what she enjoys about tax practice, how the section has shaped her career and her vision for strengthening the organization to support future generations of tax attorneys.
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Federal Tax Policy To Watch In The Rest Of 2025
As Congress returns to Washington, D.C., after the August recess, the bulk of federal tax policy is expected to focus on funding the IRS past Sept. 30 and getting out guidance for retroactive deductions included in this summer's budget reconciliation bill. Here's a look at federal tax policy to watch during the rest of the year.
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The Tax Angle: Tariff Troubles, Tipped Income
From a look at the impact of rising tariffs on energy tax credits and issues arising from the deduction for taxes on tips, here's a peek into a reporter's notebook on a few developing tax stories.
Expert Analysis
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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
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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.
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Advice For 1st-Gen Lawyers Entering The Legal Profession
Nikki Hurtado at The Ferraro Law Firm tells her story of being a first-generation lawyer and how others who begin their professional journeys without the benefit of playbooks handed down by relatives can turn this disadvantage into their greatest strength.
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UK's 1st ICSID Claim Shows Bilateral Investment Treaty Reach
For the first time, the U.K. is facing a claim under the International Centre for Settlement of Investment Disputes Convention, underscoring the broader reality that treaty protections are no longer confined to investors in emerging markets, says Philipp Kurek at Signature Litigation.
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Trump Tax Law's Most Impactful Corp. And Individual Changes
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The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.
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From Clerkship To Law Firm: 5 Transition Tips For Associates
Excerpt from Practical Guidance
Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.
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Trump Tax Law's Most Consequential International Changes
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The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.
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Associates Can Earn Credibility By Investing In Relationships
As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.
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Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling
The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.
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What 2 Profs Noticed As Transactional Law Students Used AI
After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.
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BigLaw Settlements Should Not Spur Ethics Deregulation
A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.
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5 Ways Lawyers Can Earn Back The Public's Trust
Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.