Federal
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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.
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May 06, 2025
4th Circ. Seems Split On BofA's Post-Merger Tax Offset Claims
The Fourth Circuit seemed split Tuesday on whether Bank of America should be able to use its tax overpayments to offset interest on tax underpayments by companies that merged into it, with one judge pressing the government to respond to what he described as the bank's "common sense" argument in the $163 million case.
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May 05, 2025
Credit Suisse To Pay Feds $510.6M For Helping Hide Assets
Credit Suisse Services AG has agreed to shell out more than $510 million under agreements with federal prosecutors in which the company admitted to helping customers hide more than $4 billion from the IRS in hundreds of offshore accounts, the U.S. Department of Justice announced Monday.
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May 05, 2025
Feds Say Calif. Tribe's Challenge To Cig Ruling Is 'Fruitless'
The federal government is urging a California federal court not to pause a ruling affirming the Bureau of Alcohol, Tobacco, Firearms and Explosives' decision to place a native tribe on a noncompliance list over cigarette sales, saying the tribe shouldn't be able to upend the status quo as it pursues a "fruitless" appeal to the Ninth Circuit.
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May 05, 2025
Trump Seeks 100% Tariff On Foreign-Made Movies
President Donald Trump asked his administration to place a 100% tariff on foreign-made movies, with a spokesperson telling Law360 on Monday that a final decision on the plan hadn't been made.
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May 05, 2025
Minn. Tribe Looks To Weigh In On 3,000-Acre Land Trust Row
The Mille Lacs Band of Ojibwe has asked a Minnesota federal judge to let it file a friend of the court brief in a county's case claiming the U.S. government wrongly accepted more than 3,000 acres of land into trust for the tribe.
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May 05, 2025
Trump Admin Defends Tariff Power In Toy-Makers' Challenge
President Donald Trump's administration urged a D.C. federal court to deny a request by toy companies to halt global tariffs, arguing the government is authorized to impose trade measures under the International Emergency Economic Powers Act.
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May 05, 2025
IRS Audit Staff Slashed From Layoffs, Voluntary Resignations
Layoffs and voluntary resignations at the Internal Revenue Service have significantly reduced the agency's revenue agents responsible for conducting audits, the Treasury Inspector General for Tax Administration said Monday.
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May 05, 2025
Tax Evader Can't Fight Related Taxes, Court Says
A South Dakota business owner who admitted to hiding income from the Internal Revenue Service cannot challenge the $120,000 the agency claims he owes in additional taxes for fraudulently failing to file returns, the U.S. Tax Court ruled Monday.
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May 05, 2025
Clifford Chance Adds Paul Weiss Exec Compensation Atty In NY
Clifford Chance LLP has added a Paul Weiss Rifkind Wharton & Garrison LLP transactional attorney in New York as co-chair of its U.S. executive compensation practice, the firm announced Monday.
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May 05, 2025
Tax Court Tosses Grandmother's Levy Challenge
The U.S. Tax Court tossed Monday a levy challenge by an Alabama woman who said she was the sole caregiver for her five grandchildren, ruling that she had already received the tax relief she sought when the IRS decided not to collect her overdue taxes.
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May 05, 2025
Co. Urges Ending IRS Cost-Sharing Rule After Justices' Ruling
A controversial rule requiring U.S. companies to include employee stock-based compensation in cost-sharing agreements with offshore affiliates should be scrapped following the U.S. Supreme Court's revocation of required judicial deference to agencies, a drug distributor told a Texas federal court in seeking a nearly $10 million tax refund.
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May 05, 2025
Novelist Owes $715K In FBAR Penalties, US Says
A Japanese author with U.S. citizenship faces penalties exceeding $715,000 for failing to report accounts she held at a Swiss bank, the U.S. government told a California federal court.
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May 02, 2025
Tax Case Can Proceed Despite Late Name Change, Court Says
The owner of a mail-order medical equipment company can move forward with his lawsuit against the federal government seeking to deduct a $5 million settlement payment, even though he didn't technically add his name to the case until after the deadline, the Court of Federal Claims said.
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May 02, 2025
Money Laundering, Tax Charges Nixed Vs. Crypto Operator
An Indiana federal judge dismissed the U.S. government's cases against a man accused of operating an unlicensed money transmitting business, laundering proceeds through cryptocurrency transactions and failing to file tax returns after finding his business was not subject to registration requirements, as the government had maintained.
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May 02, 2025
Nixon Peabody Appoints Finance, Tax Partner As DC Leader
Nixon Peabody LLP has appointed a more than 20-year veteran of the firm as its Washington, D.C., office managing partner, who focuses his practice on a range of corporate, finance and real estate matters, according to a Thursday announcement.
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May 02, 2025
Groups Seek Order Halting Trump's Restructuring Of Gov't
A California district court must stop federal agencies from moving ahead with President Donald Trump's directive to reorganize and terminate government workers, unions and other groups argued, calling for a temporary restraining order based on alleged harms from the administration's "radical restructuring."
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May 02, 2025
White House Budget Seeks $2.5B Cut From IRS Funding
The Internal Revenue Service's budget would be cut by nearly $2.5 billion compared with 2025 under the 2026 budget request released Friday by President Donald Trump's administration.
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May 02, 2025
IRS Updates Rates For Foreign Insurance Company Equations
The Internal Revenue Service on Friday published updated domestic asset/liability and yields percentages for 2024 that foreign life insurance companies and foreign property and liability insurance companies need to compute their minimum effectively connected net investment income.
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May 02, 2025
Taxation With Representation: Goodwin, Haynes Boone
In this week's Taxation With Representation, Merck buys SpringWorks Therapeutics, Novartis AG acquires Regulus Therapeutics Inc., Sabre Corp. sells its Hospitality Solutions business to private equity shop TPG, and TWG Global and Mubadala Capital team up to bolster their investments.
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May 02, 2025
Community Groups Accept Pause In CTA Litigation
A group of community associations has told the Fourth Circuit they aren't opposed to a government motion to pause litigation over the Corporate Transparency Act, even as they maintained the information disclosure law aimed at small businesses still carries constitutional flaws.
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May 02, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included its announcement of plans to revoke partnership basis-shifting regulations that were finalized earlier this year.
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May 01, 2025
IRS Successfully Targeting Rich Nonfilers, But Can Improve
The Internal Revenue Service's targeted sweeps of so-called high-income nonfilers have largely been successful in closing cases and collecting revenue, but the agency could do more to target certain areas and collect tracking data better, the Treasury Inspector General for Tax Administration said.
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May 01, 2025
Multinationals Grapple With Tariff-Induced Pricing Issues
President Donald Trump's flurry of tariff actions since taking office has created new questions for multinationals and their transfer pricing tax planners, including how to properly account for cost increases associated with new duties in related party transactions.
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May 01, 2025
Trump Picks Tax Controversy Pro For IRS Chief Counsel Spot
President Donald Trump has tapped a former Internal Revenue Service chief counsel to return to the role, and if he is confirmed, it will represent the second time in his career that the veteran tax controversy professional will be the agency's top attorney.
Expert Analysis
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3 Ways To Train Junior Lawyers In 30 Minutes Or Less
Today’s junior lawyers are experiencing a skills gap due to pandemic-era disruptions, but firms can help bring them up to speed by offering high-impact skill building content in bite-sized, interactive training sessions, say Stacey Schwartz at Katten, Diane Costigan at Winston & Strawn and Lauren Tierney at Freshfields.
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Expect Surging Oil And Gas Industry Under New Trump Admin
Throughout his recent campaign, President-elect Donald Trump promised increased oil and natural gas production and reduced reliance on renewables — and his administration will likely bring more oil and gas dealmaking, faster federal permitting and attempts to roll back incentives for green energy, say attorneys at Sidley.
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The Bar Needs More Clarity On The Discovery Objection Rule
Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.
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Cos. Should Inventory Issues To Prep For New Congress
As the legislative and oversight agendas of the 119th Congress come into sharper focus, corporate counsel should assess and plan for areas of potential oversight risk — from tax policy changes to supply chain integrity — even as much uncertainty remains, say attorneys at WilmerHale.
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Conservation Easement Cases Weave Web Of Uncertainty
Much of the IRS and Justice Department’s recent success in prosecuting syndicated conservation easement cases can be attributed to the government’s focus on the so-called PropCo ratio, which could indicate treacherous waters ahead for participants and their advisers, even under the incoming Trump administration, say attorneys at Polsinelli.
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So You Want To Move Your Law Practice To Canada, Eh?
Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.
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Legislation Most Likely To Pass In Lame Duck Session
As Congress begins its five-week post-election lame duck session, attorneys at Greenberg Traurig break down the legislative priorities and which proposals can be expected to pass.
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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
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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.