Federal
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September 30, 2025
IRS Penalty Case Tossed For Now Over Shifting Legal Claims
A woman's shifting legal theories doomed her challenge to IRS penalties related to her delayed disclosure of a foreign inheritance, a California federal judge found, tossing the suit but allowing her to amend her complaint.
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September 30, 2025
IRS Defines Rural Areas For Opportunity Zone Tax Breaks
The Internal Revenue Service published the definitions Tuesday for rural areas that qualify for the federal opportunity zone program's rural zone expansion under the Republican budget bill signed into law this summer.
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September 30, 2025
Altria Loses Out On $38M Refund On Foreign Subsidiaries
Tobacco products maker Altria is not entitled to a $38 million tax refund on foreign subsidiaries, a Virginia federal court found, saying the company was an indirect shareholder through its interest in Anheuser-Busch and therefore owes taxes on its portion of the subsidiaries' income.
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September 30, 2025
IRS Proposed Installment Sales Regs Suit Is Early, Judge Says
A capital assets dealer's challenge to proposed Internal Revenue Service rules on monetized installment sales cannot stand, an Idaho federal judge found in dismissing the suit, saying the court cannot adjudicate on administrative law regulations that are not yet final.
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September 30, 2025
Trump Orders Lumber, Furniture Tariffs To Begin Oct. 14
In an executive order signed Monday evening, President Donald Trump outlined a series of tariff rates on imported lumber and derivative products to be imposed in two weeks.
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September 29, 2025
Diamond Mogul's Daughter Escapes Tax Claims In $41M Deal
The U.S. government agreed to stop pursuing the adult daughter of a diamond mogul to recover millions in tax liabilities from his estate after reaching an agreement in which the government will receive an additional payment of $41 million, according to a New York federal court order Monday.
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September 29, 2025
IRS Finalizes Income Rules For Housing Tax Credit Projects
The U.S. Department of the Treasury and Internal Revenue Service published finalized rules for housing tax credit developers opting to use an average-income test to set rents for affordable housing projects, aiming to reduce the risk of disqualification if a unit falls out of compliance.
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September 29, 2025
IRS Would Continue Operations Under Shutdown Plan
The Internal Revenue Service will use funds it received under former President Joe Biden to continue operations if Congress can't reach an agreement to avoid a federal government shutdown, under a contingency plan released Monday.
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September 29, 2025
Tribal Members Push For Say In Supreme Court Tariff Review
Members of the Blackfeet Nation tribe told the U.S. Supreme Court Monday their inclusion in the justices' review of suits challenging the legality of President Donald Trump's emergency tariffs is crucial to protect Native American rights under federal law.
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September 29, 2025
Solar Plant Justified $45M Easement Break, Tax Court Told
A partnership is entitled to a roughly $45 million tax deduction for donating a conservation easement that protected hundreds of acres in Texas from potentially being used to host a solar power plant, the partnership told the U.S. Tax Court.
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September 29, 2025
Calif. Tech Retailer Challenges $3.5M Bill In Tax Court
A California electronics retailer is challenging a nearly $3.5 million tax bill in the U.S. Tax Court based on the company's contention that the IRS failed to recognize that a Hong Kong affiliate carried out a portion of its sales.
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September 29, 2025
IRS Pulls Plug On Proposed Corporate Spinoff Regulations
Proposed regulations for a narrow set of tax-free corporate separation deals known as spinoffs and a multiyear reporting regime for those transactions will be withdrawn, the Internal Revenue Service announced Monday, citing widespread criticism of the framework proposed in January.
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September 29, 2025
IRS Cancels Hearing On Offshore Profit Regulations
The Internal Revenue Service said Monday that it has canceled a public hearing on proposed rules that would require U.S. multinational corporations to create annual shareholder accounts and follow new pooling concepts to account for previously taxed foreign earnings and basis adjustments.
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September 29, 2025
IRS Cuts Tax Preparer ID User Fee By $1 Amid Litigation
Tax preparers will pay $1 less for their annual tax identification number, a drop in price from $11 to $10, the Internal Revenue Service said in interim guidance Monday as the fee continues to be fought over in court.
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September 26, 2025
Trump Announces 100% Tariff On Drug Imports Starting Oct. 1
President Donald Trump announced a slew of new Section 232 tariffs to be imposed beginning Oct. 1, including a 100% tariff on drug imports and new rates for semi trucks, kitchen cabinets, bathroom vanities and upholstered furniture.
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September 26, 2025
Microsemi, IRS Reach Deal To Settle Transfer Pricing Dispute
The Internal Revenue Service has reached a settlement with semiconductor manufacturer Microsemi to resolve the agency's transfer pricing adjustment regarding an intercompany purchase of semiconductor products, according to U.S. Tax Court filings.
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September 26, 2025
11th Circ. Told $33M Easement Deduction Improperly Cut
The U.S. Tax Court ignored evidence of land values that the IRS had failed to rebut — or even backed — when it drastically reduced a partnership's $33 million tax deduction for donating a Georgia conservation easement, the partnership told the Eleventh Circuit.
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September 26, 2025
Taxation With Representation: De Brauw, Hengeler Mueller
In this week's Taxation With Representation, power grid operator TenneT Holding sells a stake in its German transmission business to institutional investors, Pfizer Inc. acquires biotechnology company Metsera Inc., and Dutch brewer Heineken NV buys most of Costa Rica's FIFCO beverage and retail operations.
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September 26, 2025
Trump Targets Tax-Exempt Orgs' Funding Of Political Violence
The Internal Revenue Service is required to take steps to ensure that no tax-exempt entities are financing political violence, President Donald Trump said Friday in a national security memorandum decrying anti-fascist rhetoric and related domestic terrorism and organized political violence.
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September 26, 2025
Tip Tax Regs Prompt Questions On Eligibility, Withholding
The IRS has released preliminary guidance implementing Republicans' tax deduction for tip income, but tax professionals say more clarity is needed before next tax season on topics including who's eligible for the deduction and how employers must account for it.
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September 26, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included final rules that allow workers reaching retirement age to catch up on their savings by making additional contributions above the annual limits to their employer-sponsored retirement plans.
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September 25, 2025
Perrigo Mostly Beats US In $163M Tax Refund Dispute
A Michigan federal court largely sided Thursday with pharmaceutical company Perrigo in a $163 million tax refund case, rejecting the government's claim that the company's transactions with a foreign entity lacked economic substance and were meant only to avoid taxes.
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September 25, 2025
Imprisoned Pearl Token Founder Hit With Default In SEC Suit
The incarcerated founder of an unregistered crypto offering known as Pearl tokens has been barred from issuing, offering or selling securities after failing to respond to parallel U.S. Securities and Exchange Commission claims.
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September 25, 2025
Convicted Atty Lacks Moral Fitness, Ethics Panel Says
Connecticut's statewide grievance committee says an attorney convicted 10 years ago for filing false federal tax returns doesn't have the moral character to return to the legal profession.
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September 25, 2025
DC Circ. Backs Whistleblower In IRS Award Dispute
A whistleblower who received millions of dollars in awards for helping the IRS nab prominent Wall Street firms that helped offshore hedge funds evade taxes was wrongly blocked from receiving millions more, the D.C. Circuit ruled.
Expert Analysis
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Making The Opportunity Zones Program Great At Last
As the opportunity zone program approaches its expiration, the Republican-led government could take specific steps to extend and improve the program, address its structural flaws, encourage broader participation and enable it to live up to its promised outcomes, say attorneys at Pillsbury.
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We Must Allow Judges To Use Their Independent Judgment
As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.
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Preparing For Tariffs On Canadian Power In The Northeast
The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.
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Making The Case For Rest In The Legal Profession
For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.
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Mitigating Tariff Risks For Healthcare In US And Canada
Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.
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4 Ways Women Attorneys Can Build A Legal Legacy
This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.
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A Judge's Pointers For Adding Spice To Dry Legal Writing
U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.
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Why NY May Want To Reconsider Its LLC Transparency Law
Against the backdrop of the myriad challenges to the federal Corporate Transparency Act, it may be prudent for New York to reconsider its adoption of the LLC Transparency Act, since it's unclear whether the Empire State's "baby-CTA" statute is still necessary or was passed prematurely, say attorneys at Pillsbury.
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IRS Scrutiny May Underlie Move Away From NIL Collectives
The University of Colorado's January announcement that it was severing its partnership with a name, image and likeness collective is part of universities' recent push to move NIL activities in-house, seemingly motivated by tax implications and increased scrutiny by the Internal Revenue Service, say attorneys at Buchanan Ingersoll.
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7 Tips For Associates To Thrive In Hybrid Work Environments
Excerpt from Practical Guidance
As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.
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IRS Should Revise Overbroad Microcaptive Regs
Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.
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Terraform Case May Be Bellwether For Crypto Enforcement
The prosecution of crypto company Terraform Labs and its CEO, Do Kwon, offers a unique test of the line between lawful and unlawful conduct in digital transactions, and the Trump administration’s posture toward the case will provide clues about its cryptocurrency enforcement agenda in the years to come, say attorneys at Brooks Pierce.
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How Law Firms Can Counteract The Loneliness Epidemic
The legal industry is facing an urgent epidemic of loneliness, affecting lawyer well-being, productivity, retention and profitability, and law firm leaders should take concrete steps to encourage the development of genuine workplace connections, says Michelle Gomez at Littler and Gwen Mellor Romans at Herald Talent.