Federal
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May 09, 2025
Taxation With Representation: Paul Weiss, Weil, V&E, Torys
In this week's Taxation With Representation, 3G Capital takes Skechers private, Sunoco LP buys Parkland Corp., and BCE Inc. and the Public Sector Pension Investment Board launch a wholesale network provider called Network FiberCo.
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May 09, 2025
Retired Supreme Court Justice David Souter Dies At 85
Retired Justice David H. Souter, who served on the U.S. Supreme Court from 1990 to 2009, has died at 85, the court announced Friday.
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May 08, 2025
Trump Admin Defends Gov't Restructuring As Lawful
The Trump administration defended what it says is a lawful executive order looking to reorganize agencies and terminate workers, telling a California federal judge that unions, nonprofits and local governments "waited far too long" to seek a temporary restraining order.
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May 08, 2025
Hyatt's $300M From Reward Program Is Income, 7th Circ. Told
Hyatt Hotels should have to report nearly $300 million in revenue from a rewards program fund because it benefited from spending the money, including through advertising for its properties, the U.S. government told the Seventh Circuit on Thursday, defending a U.S. Tax Court ruling.
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May 08, 2025
NFTC Warns US Against Tariffs On Semiconductors, Pharma
The Trump administration should work to avoid using tariffs to address the perceived threat to national security caused by importing semiconductors and pharmaceuticals, the National Foreign Trade Council said, calling for extreme caution.
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May 08, 2025
Widow Says Husband's Estate Liable For $2M FBAR Fines
A nonagenarian widow told an Idaho federal court Thursday that her husband's estate — not she — should be liable for more than $2 million in penalties for his unreported foreign accounts, calling the government's attempt to penalize her an unprecedented overreach.
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May 08, 2025
11th Circ. Judge Frowns On New Arguments In Easement Case
An Eleventh Circuit judge disapproved of a Georgia partnership raising new arguments on appeal as it pursues a tax deduction for a conservation easement donation, saying Thursday that perhaps "we wouldn't be here" if the partnership had argued the points before the lower court.
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May 08, 2025
Milbank Hires King & Spalding Tax Planning Atty In DC
Milbank LLP has added a former King & Spalding LLP tax attorney as a partner in its global project, energy and infrastructure finance group in Washington, D.C.
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May 07, 2025
Bessent Defends Cuts To Community Fund Amid Scrutiny
U.S. Treasury Secretary Scott Bessent on Wednesday defended the Trump administration's proposal to significantly slash the fund that operates the new markets tax credit, which is meant to boost investment in poor communities, telling lawmakers that a new $100 million program would better support affordable financing in rural areas.
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May 07, 2025
Favorable Tax Cut Baseline Won't Fool Lenders, House Told
If Congress uses a current policy baseline to permanently extend the 2017 tax overhaul's provisions, it will be a red flag to institutional investors, such as hedge funds, mutual funds and endowments, panelists told the House Budget Committee on Wednesday.
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May 07, 2025
Tax Court Rejects Couple's Case For Lacking Evidence
A couple who challenged what the Internal Revenue Service said was their more than $650,000 in tax debt provided no evidence that the number was wrong, the U.S. Tax Court said in a bench opinion released Wednesday.
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May 07, 2025
11th Circ. Backs Frivolous Argument Ruling Against Teacher
A Georgia high school teacher who claimed that he didn't have to pay taxes on his salary and that income taxes are unconstitutional must pay $25,000 in court sanctions under an Eleventh Circuit ruling affirming a U.S. Tax Court decision.
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May 07, 2025
Don't Scrap US-China Tax Treaty, Biz Groups Tell Treasury
Business lobbying groups have urged the U.S. Treasury Department to reject the White House's plans to scrutinize the U.S.-China tax treaty, warning that scrapping the accord would lead to higher Chinese taxes on U.S. companies.
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May 07, 2025
Feds Seek 13 Years In Avenatti's California Resentencing
California federal prosecutors asked a judge Wednesday to sentence Michael Avenatti to 160 months in prison for tax fraud and stealing from clients, to be served atop the five-year term imposed in a pair of New York cases where Avenatti was convicted of trying to extort Nike Inc. and defrauding former client Stormy Daniels.
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May 07, 2025
6th Circ. Skeptical Of US In Tax Court Deadline Case
Sixth Circuit judges expressed skepticism of the U.S. government's claim that the 90-day deadline to petition the U.S. Tax Court is inflexible, with one judge saying during oral arguments Wednesday in a woman's case challenging the rule that the U.S. Supreme Court seemed to back her.
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May 07, 2025
Device Seller Asks For Probation In $2.4M Tax Evasion Case
The septuagenarian owner of a Florida medical device company who pled guilty to evading $2.4 million in taxes asked a federal district court Wednesday for his sentence to entail home probation and not prison, given his health challenges and payments he already made to the Internal Revenue Service.
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May 07, 2025
IRS To Open Applications For Low-Income Tax Clinic Grants
The Internal Revenue Service will begin accepting applications May 15 for its grant program for organizations providing tax services to low-income people or people who speak English as a second language, it announced Wednesday.
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May 06, 2025
Fed. Circ. Agrees Plane Taxability Patent Doesn't Fly
The Federal Circuit on Tuesday refused to revive an Ohio company's patent that covers using Federal Aviation Administration data to determine "the taxability status of aircraft," agreeing that it covered subject matter that isn't patentable.
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May 06, 2025
Tax Court Erred In Slashing $23M Easement, 11th Circ. Told
A partnership told the Eleventh Circuit that the U.S. Tax Court erred in substantially reducing its claim to a $23 million conservation easement tax deduction, arguing the decision was tainted by error-riddled criteria used by the IRS to value the property.
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May 06, 2025
Military Moving-Cost Deduction Nixed For Civilian Contractor
A civilian contractor for the U.S. Air Force cannot deduct her moving expenses because she is not considered a member of the military for purposes of the deduction, the U.S. Tax Court said in a bench opinion released Tuesday.
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May 06, 2025
Actor Voight, Film Biz Adviser To Trump, Floats Tax Incentives
Actor Jon Voight, whom President Donald Trump tapped as an adviser on the Hollywood film industry, told Trump that tax incentives, international treaties and limited tariffs could revitalize production, while California Gov. Gavin Newsom separately floated a $7.5 billion federal film tax credit, according to statements shared Tuesday with Law360.
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May 06, 2025
Stationery Co. Fights Bid To Move Tariff Case To Trade Court
The U.S. Court of International Trade does not have exclusive jurisdiction to hear disputes over President Donald Trump's global tariffs, a stationery company told a Florida federal court Monday in opposing the administration's bid to transfer to the suit.
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May 06, 2025
IRS Narrows Benefit Plan Sponsors Subject To New Rules
The Internal Revenue Service on Tuesday narrowed the group of defined benefit plan sponsors that will be subject to certain requirements related to agency approval to use mortality tables that start in January.
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May 06, 2025
Bessent Eyes IRS' Technology Budget For Major Cuts
The Internal Revenue Service must cut its bloated technology budget and decrease the agency's overall spending, U.S. Treasury Secretary Scott Bessent told a House Appropriations panel Tuesday.
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May 06, 2025
Eversheds Sutherland Brings On EY Tax Pro In Atlanta
Eversheds Sutherland has added a former EY senior manager of international tax and transaction services to its Atlanta office, further strengthening its tax practice after adding a dozen tax controversy attorneys from Chamberlain Hrdlicka White Williams & Aughtry PC in March, the firm announced Tuesday.
Expert Analysis
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The Trade And Tax Issues Behind US-Canada Digital Tax Clash
The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.
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Litigation Inspiration: Honoring Your Learned Profession
About 30,000 people who took the bar exam in July will learn they passed this fall, marking a fitting time for all attorneys to remember that they are members in a specialty club of learned professionals — and the more they can keep this in mind, the more benefits they will see, says Bennett Rawicki at Hilgers Graben.
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AI May Limit Key Learning Opportunities For Young Attorneys
The thing that’s so powerful about artificial intelligence is also what’s most scary about it — its ability to detect patterns may curtail young attorneys’ chance to practice the lower-level work of managing cases, preventing them from ever honing the pattern recognition skills that undergird creative lawyering, says Sarah Murray at Trialcraft.
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A Look At How De Minimis Import Rules May Soon Change
The planned implementation of executive actions focused on the de minimis rule as it applies to shipments means companies should use this interval to evaluate the potential applicability and impact of Section 301, Section 201 or Section 232 duties on their products, say attorneys at Holland & Knight.
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Ruling On Foreign Dividend Break Offers 2 Tax Court Insights
In Varian v. Commissioner, the U.S. Tax Court allowed a taxpayer's deduction for dividends from foreign subsidiaries, providing clarity on how the U.S. Supreme Court’s Loper Bright decision may affect challenges to Treasury regulations, and revealing a potential disallowance of foreign tax credits, say attorneys at Davis Polk.
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Why Now Is The Time For Law Firms To Hire Lateral Partners
Partner and associate mobility data from the second quarter of this year suggest that there's never been a better time in recent years for law firms to hire lateral candidates, particularly experienced partners — though this necessitates an understanding of potential red flags, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
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Considering Possible PR Risks Of Certain Legal Tactics
Disney and American Airlines recently abandoned certain litigation tactics in two lawsuits after fierce public backlash, illustrating why corporate counsel should consider the reputational implications of any legal strategy and partner with their communications teams to preempt public relations concerns, says Chris Gidez at G7 Reputation Advisory.
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It's No Longer Enough For Firms To Be Trusted Advisers
Amid fierce competition for business, the transactional “trusted adviser” paradigm from which most firms operate is no longer sufficient — they should instead aim to become trusted partners with their most valuable clients, says Stuart Maister at Strategic Narrative.
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Avoid Getting Burned By Agencies' Solar Financing Spotlight
Recently coordinated reports and advisories from the U.S. Department of the Treasury, the Consumer Financial Protection Bureau and the Federal Trade Commission maximize the spotlight on the consumer solar financing market and highlight pitfalls for lenders to avoid in this burgeoning field, says Mercedes Tunstall at Cadwalader.
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Tax Traps In Acquisitions Of Financially Distressed Targets
Excerpt from Practical Guidance
Parties to the acquisition of an insolvent or bankrupt company face myriad tax considerations, including limitations on using the distressed company's tax benefits, cancellation of indebtedness income, tax lien issues and potential tax reorganizations.
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Navigating A Potpourri Of Possible Transparency Act Pitfalls
Despite the Financial Crimes Enforcement Network's continued release of guidance for complying with the Corporate Transparency Act, its interpretation remains in flux, making it important for companies to understand potentially problematic areas of ambiguity in the practical application of the law, say attorneys at Sidley.
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How Methods Are Evolving In Textualist Interpretations
Textualists at the U.S. Supreme Court are increasingly considering new methods such as corpus linguistics and surveys to evaluate what a statute's text communicates to an ordinary reader, while lower courts even mull large language models like ChatGPT as supplements, says Kevin Tobia at Georgetown Law.
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Why Attorneys Should Consider Community Leadership Roles
Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.