Federal
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April 04, 2025
The Tax Angle: Dueling Economic Outlooks For TCJA Renewal
From a look at opposite economic projections for renewing the 2017 Tax Cuts and Jobs Act during the Senate debate on the Republicans' fiscal 2026 budget resolution, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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April 04, 2025
China Issues Tariffs, WTO Challenge To Hit Back At Trump
Chinese officials began honing their response to the Trump administration's expansive new tariffs on Friday, setting up retaliatory duties and announcing plans for a challenge at the World Trade Organization.
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April 04, 2025
Taxation With Representation: Ropes & Gray, Paul Hastings
In this week's Taxation With Representation, Siemens AG acquires Dotmatics from Insight Partners, LPL Financial acquires Commonwealth Financial Network, Brookfield Asset Management takes a majority stake in Angel Oak Cos., and TowneBank acquires Old Point Financial Corp.
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April 04, 2025
Mortgage Lender Sues US For $5M In Worker Credit Refunds
The Internal Revenue Service owes a mortgage lender $5 million in refunds for worker tax credits after it had to suspend operations during the pandemic, the lender told a California federal court, saying the agency denied one of its claims for credits without conducting an audit.
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April 04, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the agency's latest update on its advance pricing agreement program's work.
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April 03, 2025
Ex-Judge, Profs Ask Justices To Weigh 9th Circ. Ch. 7 Ruling
A former bankruptcy judge and five law professors have asked the U.S. Supreme Court to review a Ninth Circuit opinion protecting the state of Montana from a real estate mogul and Montana ski resort founder's bid for damages over an involuntary Chapter 7 the state initiated.
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April 03, 2025
$5.5 Trillion Cost To Making TCJA Permanent, JCT Says
A permanent extension of the 2017 tax overhaul, including the law's expired business provisions, would cost $5.5 trillion including interest over the next decade, according to estimates released Thursday by the Joint Committee on Taxation.
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April 03, 2025
Tax Court Denies Couple's Claim To Energy Credits
A couple is not entitled to claim energy credits from an Arizona partnership whose manager pled guilty in a tax fraud scheme involving solar power equipment, the U.S. Tax Court ruled Thursday.
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April 03, 2025
DOGE Cuts Overlook Long-Standing Bids To Improve IRS
As President Donald Trump moves to downsize the federal government, the new administration may be missing an opportunity to evaluate long-standing proposals that aim to make the Internal Revenue Service run more efficiently, such as major technology upgrades and improving the dispute resolution process.
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April 03, 2025
'No Serious Question' Federal Firings Broke Law, Justices Told
Federal employee unions and advocacy groups urged the U.S. Supreme Court on Thursday to reject the Trump administration's bid to pause a California court order reinstating tens of thousands of probationary workers fired from six agencies, arguing the government can't escape self-inflicted harms brought on by its allegedly unlawful actions.
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April 03, 2025
Senate Passes Long-Shot Bill To End Trump's Canada Tariffs
The U.S. Senate on Wednesday evening passed a resolution to eliminate the national emergency President Donald Trump declared to impose 25% tariffs on Canadian imports, but the measure is likely to stall in the House and certain to be vetoed.
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April 03, 2025
South Korea To Support Industries Hit By US Tariffs
Acting South Korean President Han Duck-soo called Thursday for support to industries like automobiles and others affected by the "global tariff war" that he said was kicked off by the U.S. when it placed a 25% tariff on the country, according to local media.
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April 03, 2025
Family Used Home Loan Scheme To Shirk Tax Debt, DOJ Says
A man who owes more than $1 million in taxes helped his daughter fraudulently obtain a home loan so he could effectively own the house while avoiding paying his debt, the U.S. government said in a complaint in Florida federal court.
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April 03, 2025
UK Gov't Preparing List Of US Goods For Tariffs
The U.K. government revealed a list of U.S. goods it might target with tariffs in response to the tariffs on British goods announced by the Trump administration, according to a statement Thursday.
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April 03, 2025
IRS Considering 16 Additions To List Of Taxable Substances
The Internal Revenue Service is seeking comments on proposals from four companies to add 16 chemicals to the Internal Revenue Code's list of taxable substances, the agency said.
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April 02, 2025
Attys Call Ending DOJ Tax Division 'Epic Failure' In Efficiency
The U.S. Department of Justice's plan to dissolve its Tax Division would jeopardize effective tax enforcement nationwide, a slew of tax controversy lawyers told the DOJ Wednesday, saying such a move would defeat President Donald Trump's stated overarching goal to improve government efficiency.
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April 02, 2025
Trump Unveils New Tariffs On Dozens Of Countries
President Donald Trump announced sweeping tariffs on major trading partners Wednesday, including a 10% rate on all goods entering the U.S. to take effect later this week, in a "declaration of economic independence" he says will jump-start domestic industry and production.
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April 02, 2025
Senate GOP Plan Would Extend TCJA, Allow $1.5T In Tax Cuts
Senate Budget Committee Republicans released a budget proposal Wednesday that would permanently extend the Tax Cuts and Jobs Act and allow for up to $1.5 trillion in other tax cuts.
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April 02, 2025
6th Circ. Orders Private Review Of Docs In Eaton Tax Case
The Sixth Circuit granted a request by multinational power company Eaton Corp. to order a lower court to review in chambers sensitive performance evaluations in its transfer pricing case challenging an Internal Revenue Service summons for its European employee records.
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April 02, 2025
Jailed IRS Leaker Says Judge 'Predetermined' Sentence
The IRS contractor imprisoned for leaking thousands of tax returns, including those of President Donald Trump, to national media outlets asked the D.C. Circuit to rescind his sentence, saying a federal judge held off-the-record meetings that revealed her determination to deliver the maximum punishment.
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April 02, 2025
Environmental Cleanup Co. Seeks Refund For Retention Credit
The Internal Revenue Service owes an Alabama company that does environmental cleanup work a $3.1 million tax refund, the company told a federal district court, arguing that one of its employee retention tax credit claims was wrongfully denied.
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April 02, 2025
Control Of Kyocera's $7M Refund Suit Handed To Tax Court
The U.S. Tax Court holds jurisdiction over Kyocera's case for an approximately $7 million refund after it challenged an overlapping IRS assessment in the specialized tribunal, a South Carolina federal court ruled, agreeing with the company and the U.S. Department of Justice.
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April 01, 2025
5th Circ. Judge Questions IRS Denial Of Insurance Deductions
A Fifth Circuit judge pushed back Tuesday on the Internal Revenue Service's rejection of expense deductions for two physician-led micro-captive insurance companies, saying that the businesses seemed to serve a legitimate purpose while acknowledging that doctors are "notoriously inept" businessmen.
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April 01, 2025
Trump Admin Fights Wash.'s Bid To Expand Layoff Injunction
The Trump administration has urged a California federal judge to reject the state of Washington's request to expand an injunction blocking federal agencies from firing probationary employees, saying the bid to broaden the order to other agencies is unnecessary and based on unfounded speculation of harm.Â
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April 01, 2025
Tax Court Rejects Excluding IRA Distribution From Income
A Michigan man's assertion that a $15,000 distribution from his individual retirement account was a loan to pay for his ex-wife's funeral costs after her unexpected death doesn't excuse him from needing to include that distribution on his tax return as gross income, the U.S. Tax Court said Tuesday.
Expert Analysis
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How Associates Can Build A Professional Image
As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.
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Navigating New Safe Harbor For Domestic Content Tax Credits
The U.S. Department of the Treasury’s recent notice simplifying domestic content calculations for certain solar, onshore wind and battery storage projects, which directly acknowledges the difficulty for taxpayers in gathering data to support a domestic content analysis, should make it easier to qualify additional domestic content bonus tax credits, say attorneys at A&O Shearman.
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Firms Must Rethink How They Train New Lawyers In AI Age
As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.
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'Energy Communities' Update May Clarify Tax Credit Eligibility
A recent IRS notice that includes updated lists of locations where clean energy projects can qualify for additional tax credits — based 2023 unemployment data and placed-in-service dates — should help provide clarity regarding project eligibility that sponsors and developers need, say attorneys at Troutman Pepper.
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Think Like A Lawyer: Always Be Closing
When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.
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Lean Into The 'Great Restoration' To Retain Legal Talent
As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.
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How Cannabis Rescheduling May Alter Paraphernalia Imports
The Biden administration's recent proposal to loosen federal restrictions on marijuana use raises questions about how U.S. Customs and Border Protection enforcement policies may shift when it comes to enforcing a separate federal ban on marijuana accessory imports, says R. Kevin Williams at Clark Hill.
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NCAA Settlement May End The NIL Model As We Know It
The recent House v. NCAA settlement in California federal court, in which the NCAA agreed to allow schools to directly pay March Madness television revenue to their athletes, may send outside name, image and likeness collectives in-house, says Mike Ingersoll at Womble Bond.
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Fishing Makes Me A Better Lawyer
Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.
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A Healthier Legal Industry Starts With Emotional Intelligence
The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.
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To Make Your Legal Writing Clear, Emulate A Master Chef
To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.
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Circuit Judge Writes An Opinion, AI Helps: What Now?
Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.