Federal
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August 08, 2025
Midyear Review: A Look At The Tax Trends Shaping 2025
Tax professionals had a lot to keep up with in the first half of 2025, from congressional action to extend the 2017 GOP tax overhaul to a tumultuous international trade scene. And the back half of the year is poised to be just as busy, with litigation over how the IRS handles employee retention tax credits, an Amazon suit in South Carolina over sales tax, and an uncertain future for global minimum tax rules. Here, dive into our slate of analysis pieces to help guide you through evolving tax litigation and policy.
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August 07, 2025
IRS Can Collect From Incarcerated Man, Tax Court Says
The IRS properly denied a request by an incarcerated man to stop collecting his nearly $160,000 tax debt, the U.S. Tax Court ruled Thursday, saying the man admitted to having hundreds of thousands of dollars in assets.
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August 07, 2025
Toyota Forecasts $9.5B Annual Hit From US Tariffs
U.S. tariffs would cost Toyota Motor Corp. 1.4 trillion yen ($9.5 billion) during its fiscal year ending March 2026, including 450 billion yen in its first quarter, the automaker said Thursday.
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August 07, 2025
Siemens Contests Nix Of $315M Foreign-Dividend Tax Break
Regulatory missteps caused the IRS to wrongly slash $315 million from a foreign-dividend tax deduction Siemens claimed on shareholder payments it received from an overseas affiliate, the medical giant told the U.S. Tax Court.
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August 07, 2025
Man Pleads Guilty To Tax Evasion, Faces $50M In Restitution
A man accused of numerous financial crimes related to his operation of promoting abusive and illegal tax shelters pled guilty to three charges across two different cases in Colorado federal court on Thursday.
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August 07, 2025
Hodgson Russ Adds Former NY Tax Pros To SALT Group
Hodgson Russ LLP has announced that two former New York state and city tax professionals have joined the firm's state and local tax practice in New York City, advising the team on complex regional tax issues.
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August 07, 2025
No Changes To Tax Forms Yet After Budget Bill, IRS Says
Withholding tables and information returns for the current tax year as related to the federal budget bill will remain unchanged, the Internal Revenue Service announced Thursday, saying it wants to avoid disruptions to tax filing season.
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August 07, 2025
Trump Greenlights Private Equity, Crypto 401(k) Investing
President Donald Trump signed an executive order Thursday that aims to make it easier for retirement plans to invest in a wider range of assets, including cryptocurrency, private equity and real estate.
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August 07, 2025
Vanguard, Investors Agree To Settle After Axed $40M Tax Deal
Vanguard and investors have reached a second deal in a suit over allegations of surprise tax bills from a fund restructuring after a Pennsylvania federal judge scrapped a previous settlement in which the class would have fetched $40 million, the parties said Thursday.
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August 07, 2025
Fed. Circ. Skeptical Of Realty Co.'s IRS Contract Dispute
Federal Circuit judges seemed skeptical Thursday of a realty company's claim that the IRS improperly blocked its bid to continue leasing office space to the agency after IRS employees complained about the building, with one judge challenging whether evidence actually showed the agency acted in bad faith.
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August 07, 2025
German Carmakers Press EU To Secure Tariff Relief Quickly
A German automaker association urged the European Union to finalize its trade deal with the U.S. to relieve the car manufacturing industry of the pressure of tariffs.
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August 06, 2025
Under Pressure, Higher Ed Leans On Real Estate
As institutions of higher education contend with declining enrollment and federal funding cuts, some are finding creative ways to monetize their real estate, which comes with important legal considerations, according to attorneys.
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August 06, 2025
Ex-Homeowners Seek OK On Tax Foreclosure Suit Deal
A proposed class of former property owners asked a Michigan federal judge Tuesday to give initial support to a settlement with several counties that would allow the ex-homeowners to receive the surplus profits they allege the county treasurers made selling their tax-delinquent properties.
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August 06, 2025
No IRS Error In Lien Against Lawyer, Tax Court Says
The IRS' appeals office did nothing wrong in sustaining a tax lien against an attorney who asked for other ways of paying what the agency said was her $43,000 tax debt, the U.S. Tax Court ruled Wednesday, saying the lawyer was offered lower payment options.
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August 06, 2025
Troutman Adds Former Fannie Mae Associate GC In DC
The former associate general counsel at the Federal National Mortgage Association, who spent the past decade as a tax partner with Morris Manning & Martin LLP, has joined Troutman Pepper Locke LLP in the nation's capital, the firm announced Wednesday.
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August 06, 2025
G7's Tax Carveout For US Cos. Raises EU State Aid Questions
The Group of Seven nations' deal to exclude U.S. companies from Pillar Two minimum tax rules would give those companies a competitive advantage, experts say, prompting questions about the carveout's compatibility with EU state aid rules and whether a viable path exists to challenge the deal.
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August 06, 2025
3 Key Foreign Entity Issues In Claiming Clean Energy Credits
Stricter foreign supply chain and business ownership rules were tacked onto clean energy tax credits that weren't eliminated under the new budget reconciliation law, raising major compliance hurdles that have practitioners eagerly awaiting implementation rules from the U.S. Treasury Department. Here, Law360 outlines key issues the agencies need to address in coming guidance on restrictions targeting projects linked to foreign entities of concern.
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August 06, 2025
DOJ Says $47M Fat Brands Tax Case Not A Priority
The U.S. Department of Justice quit prosecuting Fat Brands and its founder on charges of helping hide $47 million from the IRS because of guidance from DOJ leaders that emphasized other priorities, including enforcement against cartels, the department told a California federal court.
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August 05, 2025
GAO Denies Co.'s Protest Of $49M IRS Task Order
The U.S. Government Accountability Office denied a Virginia company's protest of a $49 million task order issued by the U.S. Department of the Treasury for information technology services support, saying it was not competitively prejudiced during the procurement process.
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August 05, 2025
AICPA Pushes For Guidance On Renewed R&D Tax Break
The U.S. Department of the Treasury needs to issue guidance immediately allowing taxpayers to deduct research and development costs incurred in 2024 on their originally filed federal income tax returns for that year, the American Institute of CPAs said in a letter released Tuesday.
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August 05, 2025
McGuireWoods Adds Loeb & Loeb Tax Pro In Los Angeles
McGuireWoods LLP is enhancing its corporate team, announcing Tuesday it is bringing in a Loeb & Loeb LLP tax expert as a partner in its Los Angeles office in Century City.
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August 05, 2025
Simpson Thacher Adds Tax, Funds Pro From Dechert
Simpson Thacher & Bartlett LLP announced Monday that it has continued its growth in the tax and registered funds spaces, welcoming a partner from Dechert LLP to its New York office.
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August 05, 2025
Swiss President Hustles To DC To Address 39% Tariff
Swiss President Karin Keller-Sutter traveled Tuesday to Washington, D.C., for trade talks with the White House after Switzerland was hit with a 39% tariff on exports to the United States.
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August 05, 2025
IRS Floats Update To System For Fringe Benefits
The Internal Revenue Service floated rules Tuesday that would change its system of business classification for employees hoping to exclude fringe benefits and employee discounts from their gross income at tax time.
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August 05, 2025
Fed. Circ. Won't Revive Tax Whistleblower's Reward Suit
The government was not required to give a bigger whistleblower award to a former auditor who helped the Internal Revenue Service recover $180,000 in taxes, the Federal Circuit said Tuesday, affirming a ruling that a lower court lacked authority to hear her case.
Expert Analysis
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What Trump's 2nd Presidency Could Mean For Crypto Sector
Trump's second term will bring a fundamental shift from the Biden administration's approach to crypto-asset regulation and banking supervision, with the most significant changes likely taking effect in the first two quarters of 2025 and broader policy shifts emerging over the next year, say attorneys at Cahill.
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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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Takeaways From The IRS' Crypto Doc Summons Win
A recent First Circuit decision holding that taxpayers do not have a Fourth Amendment reasonable expectation of privacy in cryptocurrency transaction records should prompt both taxpayers and exchanges to take stock of past transactions and future plans, say attorneys at BakerHostetler.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Ex-Chicago Politician's Case May Further Curb Fraud Theories
The U.S. Supreme Court recently agreed to hear Thompson v. U.S. to determine whether a statement that is misleading but not false still violates federal law, potentially heralding the court’s largest check yet on prosecutors’ expansive fraud theories, with significant implications for sentencing, say attorneys at the Law Offices of Alan Ellis.
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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Tariffs' Economic Downsides Outweigh Potential Revenue
Import tariffs proposed by the campaign of former president Donald Trump would generate revenue like other taxes, but policymakers must consider the net-negative impact of associated consumer and downstream-industry costs, harm to exporters, potential foreign retaliation and reduction in economic output, says Erica York at the Tax Foundation.
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Navigating The Last Leg Of The Worker Retention Tax Credit
Whether a business has applied for the pandemic-era employee retention tax credit, received a denial letter or is still considering making a claim before the April 15 deadline, it should examine recent developments significantly affecting the program before planning next steps, say attorneys at Nixon Peabody.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.