Federal
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June 24, 2025
Eaton Urges 6th Circ. To Shield Worker Reviews From IRS
An Ohio federal judge should have shielded Eaton Corp.'s evaluations of more than a dozen overseas workers from an IRS investigation of the company's sale of intellectual property, not just the records for workers whose jobs were unrelated to the tax issue, the company told the Sixth Circuit.
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June 23, 2025
US Rules On Amount B 'May Take Some Time,' Official Says
A team is working on draft Internal Revenue Service regulations implementing the simplified transfer pricing approach for baseline marketing and distribution activities known as Amount B, a U.S. Treasury official said Monday, adding that the guidance "may take some time" given the project's unusual origins.
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June 23, 2025
Tax Court Upholds IRS Collection Action Against Calif. Couple
The U.S. Tax Court sustained the IRS' collection action against a California couple for unpaid 2015 and 2021 taxes Monday, saying the agency did not abuse its discretion when it declined the taxpayers' request to withdraw the lien.
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June 23, 2025
New IRS Chief Calls For Culture Change At Agency
New IRS Commissioner Billy Long has called for a transformation of the agency's culture, telling employees that he plans to make the IRS friendlier to both taxpayers and workers during his term, the agency said Monday.
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June 23, 2025
Litigation Funders Fight 'Kill Shot' In 'Big Beautiful Bill'
Litigation funders are in panic mode over a provision in the massive federal spending bill that would impose a 41% punitive tax on the $16 billion industry, with one executive calling it a "kill shot" and an academic warning it amounts to "unprecedented" weaponization of the U.S. tax code.
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June 23, 2025
OECD Official Signals Skepticism About US-Pillar 2 Harmony
Countries are questioning the U.S. Treasury Department's position that the U.S. international tax system can coexist alongside the Pillar Two worldwide minimum tax regime without undermining the global framework, an Organization for Economic Cooperation and Development official said Monday.
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June 23, 2025
Weil Gotshal Hires Akin Gump Tax Partner In NY
Weil Gotshal & Manges LLP announced Monday the hiring of a partner at Akin Gump Strauss Hauer & Feld LLP as a tax partner out of Weil's New York office.
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June 23, 2025
IRS Updates Coal Closure Areas For Energy Community Perk
The IRS released Monday an updated list of counties with shuttered coal manufacturing operations and other locations used to determine a clean energy development project's eligibility to get a boost in tax credits for being in communities that historically relied on the fossil fuel industry.
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June 23, 2025
Crypto Exec Seeks 5th Circ. Redo Over IRS Summonses
A cryptocurrency executive asked the Fifth Circuit to reconsider his request to quash IRS summonses for his bank records, saying its decision that he was prematurely trying to appeal a lower court's ruling ignored his claims that the agency's documents were incomplete and lacked legal power.
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June 20, 2025
Supreme Court Won't Leapfrog DC Circ. Over Trump's Tariffs
The U.S. Supreme Court rejected a request from two Illinois-based toy makers challenging President Donald Trump's emergency tariffs to consider their case before it is reviewed by the D.C. Circuit.
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June 20, 2025
Senate's Ƶ, PCAOB Cuts Hit Parliamentarian Roadblock
The U.S. Senate parliamentarian has thrown cold water on the Senate Banking Committee's bids to defund the Consumer Financial Protection Bureau and eliminate the Public Company Accounting Oversight Board as part of the "One Big Beautiful" budget megabill, but the panel's top Republican is vowing to keep seeking further spending cuts.
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June 20, 2025
Major Nations Endorse New Payment Transparency Standards
Authorities from the U.S., China and other major countries have endorsed payment transparency standards slated to take effect in 2030 that would require information on peer-to-peer cross-border payments above $1,000, according to the Financial Action Task Force.
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June 20, 2025
Norton Rose Adds Holland & Knight Tax Partner In DC
Norton Rose Fulbright has expanded its tax insurance underwriting offerings in the nation's capital with the addition of a partner from Holland & Knight LLP.
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June 20, 2025
Taxation With Representation: Latham, Paul Weiss, Covington
In this week's Taxation With Representation, Nippon Steel closes its purchase of U.S. Steel, Hunter Point Capital buys a minority stake in Equitix, Eaton acquires Ultra PCS Ltd. from the Cobham Ultra Group, and Eli Lilly and Co. acquires Verve Therapeutics.
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June 20, 2025
80% Back Energy Co. Taxes For Climate Damage, Oxfam Says
About 80% of people surveyed across the world support taxing oil, gas and coal corporations as a way to pay for environmental damages caused by pollution, including 75% in the U.S., according to a survey by nongovernmental organization Oxfam International and environmentalist organization Greenpeace International.
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June 18, 2025
Toyota Says DOJ Has Closed Thai Bribery Probe
Toyota said Wednesday that the U.S. Department of Justice has closed a long-running Foreign Corrupt Practices Act investigation concerning allegations of bribery at its Thai subsidiary, the latest such probe to be dropped under the Trump administration.
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June 18, 2025
Fed. Circ. OKs How Commerce Filled Blank In Steel Duty Case
The U.S. Department of Commerce may apply adverse facts to a company that fails to propose reasonable alternatives for collecting information that would be unreasonably hard to obtain in an antidumping investigation, the Federal Circuit said in a precedential opinion upholding steel duties on German companies.
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June 18, 2025
Tax Court Rejects IRS Deficiency Case Over Address Error
The U.S. Tax Court dismissed a lawsuit over a 2020 tax deficiency notice, saying Wednesday the case lacked jurisdiction because the IRS failed to prove that the agency fulfilled its obligation to find the taxpayer's last known address to mail the correspondence.
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June 18, 2025
Feds Want Pa. Inmate To Face $810K Tax Refund Case
Massachusetts federal prosecutors want a Pennsylvania inmate returned to the Bay State by July to face claims he impersonated a corporate executive and swiped an $810,000 tax refund bound for a Stamford, Connecticut, investment firm.
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June 18, 2025
Mushroom Farm Faces $6M Tax Liens Tied To Fraud Case
A defunct Pennsylvania mushroom farm failed to pay the outstanding balance in a payroll tax fraud case that sent its owner to jail last year and owes more than $6 million worth of tax liens, the U.S. Department of Justice told a federal court.
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June 18, 2025
Mich. Housing Co-Op Suit On Hold After Disclosure Exemption
A Michigan federal judge hit pause on a lawsuit from a group of housing cooperatives to escape requirements of the Corporate Transparency Act after the Financial Crimes Enforcement Network said it would give U.S.-based entities a break from the rules.
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June 17, 2025
Wyden Vows To Fight For Energy Credits Facing GOP Repeal
The top Senate Democratic tax writer vowed Tuesday to try to protect clean energy tax provisions of the 2022 Inflation Reduction Act that would face an early repeal under the sweeping tax and budget legislation released by Republicans in the Senate Finance Committee.
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June 17, 2025
AbbVie Can Get Deduction For $1.6B Payment, Tax Court Says
AbbVie can claim a deduction for the $1.6 billion it paid under a merger agreement, the U.S. Tax Court held Tuesday, rejecting the IRS' contention that the payment was a capital loss that raised the pharmaceutical giant's tax bill by $572 million.
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June 17, 2025
Ill. Toy Makers Seek Justices' Early Review Of Trump Tariff Suit
Illinois-based toy makers challenging President Donald Trump's emergency tariffs on Tuesday requested the U.S. Supreme Court consider their case before it is reviewed by the D.C. Circuit, arguing a stay to an injunction is allowing duty collections to continue and is damaging the companies.
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June 17, 2025
Tax Court Slashes Conservation Easement Value By $11M
The U.S. Tax Court on Tuesday lopped off nearly $11 million of the claimed value of a property donated as a conservation easement, saying the land's best use case would be for low-density residential housing, timber and recreation, not a vacation resort.
Expert Analysis
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How Law Firms Can Avoid 'Collaboration Drag'
Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.
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Litigation Funding Disclosure Key To Open, Impartial Process
Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.
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Whistleblowers Must Note 5 Key Differences Of DOJ Program
The U.S. Department of Justice’s recently unveiled whistleblower awards program diverges in key ways from similar programs at other agencies, and individuals must weigh these differences and look first to programs with stronger, proven protections before blowing the whistle, say Stephen Kohn and Geoff Schweller at Kohn Kohn.
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What NFL Draft Picks Have In Common With Lateral Law Hires
Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.
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Replacing The Stigma Of Menopause With Law Firm Support
A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.
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Planning Law Firm Content Calendars: What, When, Where
During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.
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Brownfield Questions Surround IRS Tax Credit Bonus
Though the IRS has published guidance regarding the Inflation Reduction Act's 10% adder for tax credits generated by renewable energy projects constructed on brownfield sites, considerable guesswork remains as potential implications seem contrary to IRS intentions, say Megan Caldwell and Jon Micah Goeller at Husch Blackwell.
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Law Firms Should Move From Reactive To Proactive Marketing
Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.
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The Big Issues A BigLaw Associates' Union Could Address
A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.
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It's Time For A BigLaw Associates' Union
As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.
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Why DOJ's Whistleblower Program May Have Limited Impact
The U.S. Department of Justice’s new whistleblower pilot program aims to incentivize individuals to report corporate misconduct, but the program's effectiveness may be undercut by its differences from other federal agencies’ whistleblower programs and its interplay with other DOJ policies, say attorneys at Milbank.
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How Justices Upended The Administrative Procedure Act
In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.
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Trump's Best Hush Money Appeal Options Still Likely To Fail
The two strongest potential arguments former President Donald Trump could raise in appealing his New York hush money conviction seem promising at first, but precedent strongly suggests they will still ultimately fail — though, of course, Trump's unique position could lead to surprising results, says former New York Supreme Court Justice Ethan Greenberg, now at Anderson Kill.