Federal
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September 08, 2025
Bessent Says US Will Refund Revenue If Justices Nix Tariffs
If the U.S. Supreme Court decides President Donald Trump lacked authority to impose tariffs under the International Emergency Economic Powers Act, the U.S. government will refund revenue it has collected with tariffs under that law, Treasury Secretary Scott Bessent said.
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September 08, 2025
9th Circ. Backs Trump Donor's Tax, Foreign Agent Convictions
A venture capitalist whose 12-year prison term for evading taxes and making illegal campaign contributions through foreign clients was commuted by President Donald Trump did not plead guilty to the crimes involuntarily, the Ninth Circuit found in affirming his convictions, rejecting his claim that his attorney hid information from him.
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September 08, 2025
IRS Appeals Office Chief Joins Skadden's DC Tax Team
Skadden Arps Slate Meagher & Flom LLP has hired the leader of the IRS Independent Office of Appeals, who brings years of experience helping resolve tax disputes and controversies, to the firm's team in the nation's capital, the firm said Monday.
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September 08, 2025
Greek Pipe Co.'s Data Gaps Merit Tariff Hike, Fed. Circ. Says
Tariffs against Greek pipe importers will stay in place, the Federal Circuit found Monday, affirming a U.S. Court of International Trade holding that the companies submitted deficient financial data, requiring the U.S. Department of Commerce to fill in certain information gaps when calculating the duties.
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September 05, 2025
Judge Grills Gov't On Details Of IRS-ICE Info-Sharing Deal
A D.C. senior judge pressed a government attorney Friday over the specifics of the IRS' disclosure of tax return information to immigration enforcement agencies, saying the details were crucial to weighing a coalition of organizations' bid to block the practice.
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September 05, 2025
Former Boston Pol Gets 1 Month For Kickback Scheme
A former Boston city councilor was sentenced on Friday to a month in prison for a public corruption scheme in which she demanded a $7,000 kickback from an employee bonus at a time she was facing a state ethics commission fine.
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September 05, 2025
Sterlington Adds More Morgan Lewis Private Wealth Attys
Sterlington PLLC has announced that it is expanding its Philadelphia office, which it launched earlier this summer with a three-person private wealth team from Morgan Lewis & Bockius LLP, by bringing on a team of their former colleagues.
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September 05, 2025
Taxation With Representation: Milbank, Wachtell, Latham
In this week's Taxation With Representation, aircraft lessor Air Lease Corp. agrees to a take-private deal, Evernorth Health Services invests billions in Shields Health Solutions, Cadence Design Systems Inc. acquires the design and engineering business of Hexagon AB, and Kraft Heinz Co. plans to split into two independent, publicly traded companies.
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September 05, 2025
Fla. Magistrate Advises Arrest In $19.6M Foreign Account Case
A Florida magistrate judge recommended an order for the arrest of a dual U.S.-German citizen who has failed to pay about $19.6 million in penalties for undisclosed Swiss bank accounts, holding that imposing additional fines would be "an empty gesture."
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September 05, 2025
What Tax Pros Read During Their Summer Vacation
What do tax professionals read in their spare time? A wide variety of books, it turns out. Here, Law360 looks at the books enjoyed by tax lawyers, professors and analysts who spoke with Law360.
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September 05, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the agency's plan to remove rules that would have forced companies to recognize income from payments that are disregarded for U.S. taxes yet reduce income in a foreign jurisdiction.
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September 05, 2025
Public Hearing On Offshore Profit Regs Set For October
A public hearing is scheduled for next month on proposed rules that would require U.S. multinational companies to create annual shareholder accounts and follow new pooling concepts to account for previously taxed earnings and profits, the U.S. Treasury Department said Friday.
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September 05, 2025
IRS Security Lapses Could Put Tax Data At Risk, TIGTA Says
The Internal Revenue Service has missed deadlines for resolving security vulnerabilities in its computer systems, the U.S. Treasury Inspector General for Tax Administration said Friday, warning that the lapses could expose taxpayer data to increased risk of attack.
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September 04, 2025
Ill. Toymakers Ask Justices To Resolve Tariff Suit Venue Split
A pair of toymakers asked the U.S. Supreme Court Thursday to resolve a jurisdictional dispute concerning challenges to President Donald Trump's emergency tariffs, saying the justices should hear their case at the D.C. Circuit along with the federal government's just-filed appeal of a Federal Circuit decision that invalidated Trump's tariffs.
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September 04, 2025
Tax Court Affirms SC Man's Tax Deficiency, Penalties
A South Carolina man owes the IRS more than $16,000 after underreporting his income for the 2018 tax year, and he is liable for a $10,000 penalty, the U.S. Tax Court said in an opinion Thursday.
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September 04, 2025
Ex-CEO Should Start Sentence For Tax Crimes, Court Told
A former software executive convicted of failing to pay employment taxes should not be allowed again to delay reporting to prison, the government told a North Carolina federal court Thursday, saying the man's new dental issues weren't serious enough to stop him from beginning his sentence.
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September 04, 2025
ABA Tax President-Elect Plans To Build On Section's Success
Lisa Zarlenga, a Steptoe LLP partner, is serving as president-elect of the American Bar Association's Section of Taxation for the 2025–2026 term, officially taking on the role this month with the goal of building the strength of the organization for the next generation of tax attorneys. In an interview with Law360, Zarlenga discussed what she enjoys about tax practice, how the section has shaped her career and her vision for strengthening the organization to support future generations of tax attorneys.
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September 04, 2025
PBM Rule Included In DOL Benefits Arm's Regulatory Update
The U.S. Department of Labor's employee benefits arm detailed several new regulations in the works Thursday, including a new fee disclosure rule involving pharmacy benefit managers and plans to revisit retirement plan fiduciary investment advice regulations, according to the administration's latest regulatory update.
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September 04, 2025
Gov't Can Foreclose On Physician's Home Over $2M Tax Debt
A physician and his wife owe more than $2 million in unpaid taxes after failing to file returns for nearly a decade, a Texas federal court found, ruling that the U.S. government can sell the couple's home to help pay the debt.
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September 04, 2025
Gov't Urges Justices To Fast-Track Emergency Tariff Suit
The U.S. Supreme Court must consider under a proposed fast-track schedule the Federal Circuit's finding of President Donald Trump's emergency tariffs as unlawful or jeopardize the recent bilateral trade agreements and the improvements to the U.S. economy as a result of those duties, the administration said.
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September 03, 2025
House Appropriations Panel Advances $2.8B IRS Funding Cut
The House Appropriations Committee approved legislation Wednesday that would cut the Internal Revenue Service's funding by $2.8 billion for the 2026 fiscal year, sending the proposal to the full House for consideration.Â
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September 03, 2025
11th Circ. Affirms Prison Sentence For False Tax Returns
A Florida tax return preparer who admitted to helping prepare false returns must finish serving more than two years in prison, the Eleventh Circuit ruled Wednesday, rejecting his claim that his employees were to blame.
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September 03, 2025
Northwestern Mutual Seeks $23M Tax Refund For Free Meals
Northwestern Mutual is seeking a refund of $23 million in taxes for on-campus lunches it provided to employees, telling a Wisconsin federal court that the IRS improperly denied the company an exclusion on taxable income for the meals.
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September 03, 2025
Senate To Hold Treasury, IRS Nomination Hearings Next Week
The Senate Finance Committee said Wednesday that it has scheduled nomination hearings for high-ranking officials at the U.S. Department of the Treasury and the Internal Revenue Service for Sept. 10.
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September 03, 2025
Software Co. Founder Fights $100M Tax Bill At 11th Circ.
A software company founder facing more than $100 million in tax debt from his participation in an illegal tax shelter should have been allowed to settle with the Internal Revenue Service for $1.5 million because he can't pay the whole bill, he told the Eleventh Circuit.
Expert Analysis
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Adapting To Private Practice: From ATF Director To BigLaw
As a two-time boomerang partner, returning to BigLaw after stints as a U.S. attorney and the director of the Bureau of Alcohol, Tobacco, Firearms and Explosives, people ask me how I know when to move on, but there’s no single answer — just clearly set your priorities, says Steven Dettelbach at BakerHostetler.
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Mulling Worker Reclassification In Light Of No Tax On OT
The One Big Beautiful Bill Act's no-tax-on-overtime provisions provide tax relief for employees who regularly work overtime and are nonexempt from the Fair Labor Standards Act, but reclassifying employees may lead to higher compliance costs and increased wage and hour litigation for employers, says Steve Bronars at Edgeworth Economics.
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Clean Energy Tax Changes Cut Timelines, Add Red Tape
With its dramatic changes to energy tax credits, the One Big Beautiful Bill Act will reshape project financing and investment planning — and wind and solar developers, especially those in the early stages of projects, face stricter timelines and heightened compliance challenges, says Dan Ruth at Balch & Bingham.
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Playing Baseball Makes Me A Better Lawyer
Playing baseball in college, and now Wiffle ball in a local league, has taught me that teamwork, mental endurance and emotional intelligence are not only important to success in the sport, but also to success as a trial attorney, says Kevan Dorsey at Swift Currie.
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Reform Partly Modernizes Small Biz Stock Gains Exclusion
Changes to the Internal Revenue Code in the One Big Beautiful Bill Act update the qualified small business stock gains exclusion to reflect inflation, but the regime would be more in line with current business realities if Congress had also made the exemption available to additional business structures, says Mark Parthemer at Glenmede.
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How Real Estate Funds Can Leverage Del. Statutory Trusts
Over the last two years, traditional real estate fund sponsors have begun to more frequently adopt Delaware Statutory Trust programs, which can help diversify capital-raising strategies and access to new sources of capital, among other benefits, say attorneys at Polsinelli.
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DOJ Crypto Enforcement Is Shifting To Target Willfulness
Three pending criminal prosecutions could be an indication of how the U.S. Department of Justice's recent digital assets memo is shaping enforcement of the area, and show a growing focus on executives who knowingly allow their platforms to be used for criminal conduct involving sanctions offenses, say attorneys at Gibson Dunn.
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4 Former Justices Would Likely Frown On Litigation Funding
As courts increasingly confront cases involving hidden litigation finance contracts, the jurisprudence of four former U.S. Supreme Court justices establishes a constitutional framework that risks erosion by undisclosed financial interests, says Roland Eisenhuth at the American Property Casualty Insurance Association.
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Practical Implications Of SEC's New Crypto Staking Guidance
The U.S. Securities and Exchange Commission's recent staff guidance that protocol staking does not constitute securities offerings provides a workable compliance blueprint for crypto developers, validators and custodial platforms willing to keep staking strictly limited to protocol-driven rewards, say attorneys at Cahill.
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How Attys Can Use AI To Surface Narratives In E-Discovery
E-discovery has reached a turning point where document review is no longer just about procedural tasks like identifying relevance and redacting privilege — rather, generative artificial intelligence tools now allow attorneys to draw connections, extract meaning and tell a coherent story, says Rose Jones at Hilgers Graben.
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AbbVie Frees Taxpayers From M&A Capital Loss Limitations
The U.S. Tax Court’s June 17 opinion in AbbVie v. Commissioner, finding that a $1.6 billion break fee was an ordinary and necessary business expense, marks a pivotal rejection of the Internal Revenue Service’s position on the tax treatment of termination fees related to failed mergers or acquisitions, say attorneys at Holland & Knight.
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ABA Opinion Makes It A Bit Easier To Drop A 'Hot Potato'
The American Bar Association's recent ethics opinion clarifies when attorneys may terminate clients without good cause, though courts may still disqualify a lawyer who drops a client like a hot potato, so sending a closeout letter is always a best practice, say attorneys at Thompson Hine.
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Federal Construction Considerations Amid Policy Overhaul
The rapid overhaul of federal procurement, heightened domestic sourcing rules and aggressive immigration enforcement are reshaping U.S. construction, but several pragmatic considerations can help federal contractors engaged in infrastructure and public construction avoid the legal, financial and operational fallout, say attorneys at Cozen O'Connor.