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Federal
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November 24, 2025
Federal Claims Court Claws Back Couple's $444K Refund
The Internal Revenue Service erroneously issued a Florida couple a $444,000 refund after they misrepresented facts to the agency, the U.S. Court of Federal Claims said.
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November 24, 2025
Trusts' Identical $2M Tax Bills Don't Add Up, Tax Court Told
A pair of related trusts challenged nearly $2 million each in taxes and penalties, telling the U.S. Tax Court that the Internal Revenue Service had asserted identical deficiencies despite making different adjustments to the respective tax returns.
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November 21, 2025
Judge Halts IRS-ICE Info-Sharing Agreement
A D.C. federal judge temporarily stopped the IRS on Friday from sharing confidential taxpayer addresses with immigration enforcement officials, saying the agency's disclosures of addresses in August under an information-sharing deal were unlawful.
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November 21, 2025
IRS Finalizes Stock Buyback Tax Regs Without 'Funding Rule'
The Internal Revenue Service released final regulations Friday for the excise tax on corporations' stock buybacks and similar transactions without what is known as the funding rule, which would apply the levy to a U.S. subsidiary of a foreign parent company.
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November 21, 2025
Bill Proposes Bitcoin Tax Payments To Build Crypto Reserve
A House Republican introduced a bill that would allow Americans to pay federal taxes in bitcoin and direct the government to use all bitcoin tax payments to build the Strategic Bitcoin Reserve.
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November 21, 2025
Justices Urged To Uphold $268M Tax Break For Truck Co.
The U.S. Supreme Court should let stand the denial of $268 million in excise tax exemptions for a Tennessee truck company, the federal government urged, saying the case doesn't meet any of the traditional requirements for high court review and raises an isolated issue.
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November 21, 2025
IRS Issues Guidelines For Claiming Tip Tax Relief In 2025
The Internal Revenue Service published guidance Friday for taxpayers looking to claim the new tax deductions for tips and overtime in 2025, as relevant tax forms haven't yet been updated to more easily account for them.
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November 21, 2025
Ga. Tax Worker Granted Interest On Chrisley Slander Verdict
A Georgia tax official will collect interest on top of a $755,000 slander verdict she won from former reality TV personality and convicted felon Todd Chrisley after a jury found he falsely accused her of unethical and illegal behavior, a Georgia federal judge said.
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November 21, 2025
Key Issues Facing The IRS Amid Looming Budget Cuts
The Internal Revenue Service is facing steep budget cuts in 2026, raising concerns about the agency's ability to handle taxpayer services and enforcement operations that are crucial for bringing in revenue and maintaining compliance with the voluntary system. Here, Law360 looks at the key areas where resource constraints are expected to hamper the IRS and what practitioners can do in response.
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November 21, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included updated rules allowing investment and grantor trusts to stake their digital assets without losing their tax benefits as long as they meet certain requirements.
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November 20, 2025
Importers Left With Uncertainty After US-China Trade Truce
U.S. importers have welcomed the latest trade truce with China and the ability to obtain key minerals without new licensing requirements for the next year, but continue to have questions about how commitments in the bilateral agreement will be met and concerns about risks of escalation.
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November 20, 2025
Treasury To Curtail Tax Credits For Unauthorized Immigrants
The U.S. Department of the Treasury plans to propose rules that would bar unauthorized immigrants from receiving popular refundable individual tax credits such as the earned income tax credit, the department announced Thursday.
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November 20, 2025
6th Circ. Urged To Affirm High Bar For Donor Reporting Rule
A libertarian organization urged the Sixth Circuit to affirm a finding that the federal government must meet a relatively high bar before it can force nonprofits to reveal the identities of their donors, saying the standard acknowledges the burden of the disclosures on First Amendment rights.
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November 20, 2025
FBAR Penalty Against Ex-Prof Is Constitutional, Court Says
A former professor must pay the entire nearly $438,000 penalty the Internal Revenue Service assessed against him for his failure to timely disclose foreign bank accounts, a California magistrate judge held, finding the amount is not unconstitutionally excessive and declining to reduce it.
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November 20, 2025
Trump Pardons Nursing Home Owner In $39M Tax Fraud
President Donald Trump granted clemency to a nursing home operator who had been sentenced to three years in prison for a $39 million employment tax fraud scheme involving care centers he owned across the country.
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November 20, 2025
IRS Unveils Interim Rules For Tax Perk For Rural Loan Interest
The IRS released temporary guidance Thursday on a new incentive that would exclude from taxable income 25% of interest from loans secured by a rural or agricultural property, including the definition of an eligible loan and the determination of the property's fair market value.
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November 19, 2025
Judge Unlikely To Find Eaton's Debt To Parent Wasn't Real
A U.S. Tax Court judge said Wednesday that he's unlikely to find that the intercompany debt U.S.-based Eaton Inc. owed its Irish parent was unreal and should be recharacterized as equity, all but dismissing an alternative argument raised by the Internal Revenue Service.
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November 19, 2025
Senate GOP Resists Extending Expanded ACA Tax Premiums
Senate Finance Committee Democrats on Wednesday urged their Republican counterparts to extend the enhanced tax credits for the Affordable Care Act, which is set to expire at the end of the year, but Republicans said they were looking for other options to address rising healthcare costs.
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November 19, 2025
Tax Court Upholds Rejection Of Tax Tipster's Award
The IRS did not improperly reject a man's claim to a whistleblower award for tips he claimed helped the agency collect money from a foreign financial institution that he said held secret accounts for U.S. citizens, the U.S. Tax Court said Wednesday.
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November 19, 2025
$24M Tax Case Against Couple Tossed For Missing Deadline
The federal government's effort to collect on what it claimed was a couple's $24 million tax bill came too late, a North Carolina federal judge ruled, saying the U.S. didn't show why a 10-year collections deadline should be extended.
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November 19, 2025
Tax Court Substance Ruling Offers Silver Lining For Taxpayers
Even though the U.S. Tax Court upheld stiff penalties under the economic substance doctrine against an eye doctor's microcaptive arrangements, the opinion generally favored taxpayers by clarifying that the IRS faces limits on when it can invoke the doctrine to audit transactions.
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November 19, 2025
Doctor, Husband Admit $16M Healthcare Fraud, Tax Evasion
A physician and her husband admitted to committing more than $16 million in healthcare fraud and tax evasion as part of a scheme that injected sick patients with the wrong medications or dosages, according to their plea agreements in Alaska federal court.
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November 19, 2025
OECD Releases Model Tax Treaty Updates For Amount B
The Organization for Economic Cooperation and Development released updates Wednesday to its model bilateral tax treaty, including language that incorporates a simplified transfer pricing approach under an international tax framework known as Amount B.
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November 19, 2025
Trump's Global Tariffs Curtailed Trade, Data Shows
U.S. imports dropped by 5.1% in August, the month when many of President Donald Trump's global tariffs took effect, according to data released Wednesday by the Bureau of Economic Analysis.
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November 18, 2025
Conn. Tobacco Wholesaler Gets Prison Time For $1.2M Fraud
A Connecticut-based tobacco wholesaler who admitted defrauding the state out of $1.2 million in tax revenue was sentenced Tuesday to nearly two years in federal prison.
Expert Analysis
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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.
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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
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.