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Federal

  • July 29, 2025

    Ex-IRS Acting Commissioner Joins KPMG's DC Office

    A former senior Internal Revenue Service employee who served as the agency's acting commissioner this year has joined KPMG LLP's Washington national tax practice as a senior managing director, the firm announced.

  • July 29, 2025

    4th Circ. Rejects BofA's Claim Of Tax Offsets After Mergers

    Bank of America cannot use its tax overpayments to offset interest on tax underpayments by Merrill Lynch just because the two companies later merged, the Fourth Circuit affirmed Tuesday in a $163 million case that affects more than 20 years' worth of tax adjustments.

  • July 29, 2025

    IRS Wrong To Fight Flexible Tax Court Deadline, 8th Circ. Told

    A couple arguing for flexibility to the 90-day deadline for challenging tax bills in the U.S. Tax Court told the Eighth Circuit that the Internal Revenue Service is wrong in claiming that such leniency would upend tax collection.

  • July 28, 2025

    New IRS Chief Rejects 'Wizard Of Oz'-Style Leadership

    New Internal Revenue Commissioner Billy Long vowed Monday to engage more directly with agency employees to improve taxpayer service, emphasizing that he does not want to be a "Wizard of Oz"-style leader hiding behind a curtain.

  • July 28, 2025

    SALT Cap Complexity Could Rewrite Tax Planning Strategies

    The new $40,000 cap on state and local tax deductibility in the GOP's 2025 tax overhaul will likely prompt a new wave of strategic tax planning activity among wealthy business owners and individuals seeking to maximize their deductions and make use of state-level workarounds before the temporary relief expires.

  • July 28, 2025

    Fired Worker Owes Tax On $1.5M Settlement, Tax Court Says

    A former PNC Investments LLC employee who won a defamation settlement after being fired must pay tax on the $1.5 million award, the U.S. Tax Court said Monday, rejecting the ex-worker's argument that the money didn't count as income.

  • July 28, 2025

    10th Circ. Says Carbon Group Can't Appeal Tax Assessment

    An entity that owns interest in a carbon producer can't appeal a $2 million tax assessment made by a Colorado county on a carbon unit operator that the entity owns interest in because the federal court doesn't have jurisdiction, the Tenth Circuit said Monday.

  • July 28, 2025

    Trailer Maker's Bid To Escape $4M Excise Taxes Dismissed

    A trailer manufacturer can't avoid more than $4 million in excise taxes, interest and penalties, a South Dakota federal court ruled, finding it couldn't rely on an exemption from a technical advice memorandum after Congress altered the definition of off-highway vehicles.

  • July 28, 2025

    US, Japanese Businessman Settle $11.6M FBAR Dispute

    A Japanese businessman and the federal government have settled their $11.6 million tax filing dispute after the man claimed a language barrier was to blame and the U.S. tried to push past a jury's verdict, according to a Hawaii federal court filing.

  • July 25, 2025

    Trump Trade Deals Do Little To Ease Importers' Concerns

    President Donald Trump's recently announced framework trade deals offer new insight into tariff rates for several countries come Aug. 1, but experts say unanswered questions about those agreements and others still at large continue to stifle longer-term planning, leaving importers in uncertain territory.

  • July 25, 2025

    Ex-Credit Suisse Client Gets 2½ Years For Hiding Assets

    A Florida federal judge on Friday sentenced a Colombian-American businesswoman and former Credit Suisse client to two and a half years in prison for conspiring with family members to hide more than $90 million in assets from the IRS through a series of foreign bank accounts.

  • July 25, 2025

    Mayo Clinic's $11.5M Tax Refund Affirmed By 8th Circ.

    The Mayo Clinic qualifies as an "educational organization" under federal tax law, making it eligible for a tax exemption for such organizations and meriting a nearly $11.5 million refund, the Eighth Circuit said Friday, affirming a federal district court.

  • July 25, 2025

    Vegas Workers Laud Tax Breaks On Tips, OT At Hearing

    The new federal tax deductions for tips and overtime pay will be extremely beneficial to working-class residents of Las Vegas, the House Ways and Means Committee heard from workers and others at a field hearing Friday, while Democrats criticized the temporary nature of the tax breaks.

  • July 25, 2025

    Rising Star: Gibson Dunn's Michael Q. Cannon

    Michael Q. Cannon of Gibson Dunn & Crutcher LLP has been the lead attorney on several high-profile cases, including playing a key role in advising on the tax aspects of the world's largest merger and acquisition deal in 2023, earning him a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 25, 2025

    IRS Provides Guidance Meant To Speed Up Corporate Audits

    The Internal Revenue Service released guidance Friday that aims to make audits more efficient for corporate taxpayers, including by phasing out a document request process taxpayers had criticized as time-consuming and of little value.

  • July 25, 2025

    Legal Org. Urges DC Circ. To Reject Trump's Tariff Powers

    The D.C. Circuit should affirm a ruling that sided with toy makers and blocked President Donald Trump from using an international economic law to impose emergency tariffs because the law does not give the president the authority he claims, a legal organization argued.

  • July 25, 2025

    Taxation With Representation: Weil, Freshfields, Linklaters

    In this week's Taxation With Representation, CC Capital and One Investment Management acquire Insignia Financial Ltd., catering giant Compass Group PLC acquires Dutch food and hospitality company Vermaat Groep BV, drugmaker Sanofi acquires biotech company Vicebio, and The Ether Machine launches as a public company.

  • July 25, 2025

    CPA Charged With $5M Fraud Involving 2 Law Firms

    A federal grand jury has charged an accountant with defrauding two law firms and other clients by selling them false tax benefits and pocketing more than $5 million from an account into which they made their payments, according to a superseding indictment in California federal court.

  • July 25, 2025

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, issued Friday, included an announcement revoking final regulations requiring brokers to report their digital asset sales.

  • July 24, 2025

    Judge Won't Block Exela Ch. 11 Plan For Claims Dilution Suit

    A Texas bankruptcy judge Thursday declined to stop automation technology group Exela from exiting Chapter 11 next week, but said he would condition the over $1 billion debt-for-equity swap plan's effectiveness on a roughly 30% recovery rate for its general unsecured claims.

  • July 24, 2025

    IRS Can Levy Religious Group's Property, Split 9th Circ. Says

    The IRS can impose a lien on an Arizona residential property held by a religious organization to collect unpaid taxes owed by a bankrupt couple who had decision-making authority over the entity's finances and bank account, a divided Ninth Circuit ruled Thursday.

  • July 24, 2025

    EU Prepared To Impose €93B In Tariffs On US Goods

    The European Commission voted Thursday to impose tariffs on €93 billion ($109 billion) worth of U.S. goods if no trade deal is reached by August as the two sides continue negotiations.

  • July 24, 2025

    Construction Co. Owner Arrested In $2.9M Payroll Tax Scheme

    A New York City construction company owner was arrested on charges of failing to pay over $2.9 million in employment taxes and falsely claiming that his wife worked as one of his laborers, according to the U.S. Department of Justice.

  • July 24, 2025

    Rising Star: McDermott's Michael Bruno

    Michael Bruno of McDermott Will & Emery LLP was tapped as lead tax counsel by two legendary athletes — Lionel Messi and Stephen Curry — for the rollouts of their respective beverage brands, earning him recognition as one of the tax attorneys under age 40 honored by Law360 as Rising Stars.

  • July 24, 2025

    GOP Reps. Urge IRS To Roll Back Economic Substance Ruling

    The Internal Revenue Service should withdraw a revenue ruling that invokes the economic substance doctrine to disregard certain intercompany transactions, 20 Republicans on the House Ways and Means Committee said Thursday, arguing it leaves taxpayers uncertain about how to apply partnership tax laws to commercial transactions.

Expert Analysis

  • Making The Case For Rest In The Legal Profession

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    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.

  • Mitigating Tariff Risks For Healthcare In US And Canada

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    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.

  • 4 Ways Women Attorneys Can Build A Legal Legacy

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    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.

  • A Judge's Pointers For Adding Spice To Dry Legal Writing

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    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.

  • Why NY May Want To Reconsider Its LLC Transparency Law

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    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.

  • IRS Scrutiny May Underlie Move Away From NIL Collectives

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    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.

  • 7 Tips For Associates To Thrive In Hybrid Work Environments

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    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.

  • IRS Should Revise Overbroad Microcaptive Regs

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    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.

  • Terraform Case May Be Bellwether For Crypto Enforcement

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    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.

  • How Law Firms Can Counteract The Loneliness Epidemic

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    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.

  • Texas Fraud Case Shows Dangers Of Faulty Crypto Reporting

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    The recent sentencing of a man who failed to properly report capital gains from bitcoin sales is a reminder that special attention must be given to the IRS' reporting requirements in order to stay out of the government's crosshairs, says Saverio Romeo at Fox Rothschild.

  • Potential Impacts Of IRS' $1M Affiliate Pay Deduction Cap

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    If finalized, a recent Internal Revenue Service proposal expanding Section 162(m) of the Internal Revenue Code to include the highly compensated employees of affiliates would make tracking which executives may be subject to the limit from year to year far more complex, say attorneys at Debevoise.

  • 5 Keys To Building Stronger Attorney-Client Relationships

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    Attorneys are often focused on being seen as the expert, but bonding with clients and prospects by sharing a few key personal details provides the basis for a caring, trusted and profoundly deeper business relationship, says Deb Feder at Feder Development.

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