Federal
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October 23, 2025
US Oil Cos. Pay More Tax Abroad Than At Home, Report Says
American oil and gas companies with foreign extraction operations paid more than 80% of their total taxes abroad in recent years despite producing more oil and gas in the U.S. than everywhere else combined, a corporate transparency group said Thursday.
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October 23, 2025
IRS To Float Sourcing Rules For Certain Securities Loans
The Internal Revenue Service said Thursday it intends to propose regulations that would have it look to the borrower of certain securities, rather than the lender, when determining whether related payments are sourced from the United States.
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October 23, 2025
IRS FAQs Include $20K Payment Reporting Requirement
The Internal Revenue Service updated its FAQs on Thursday to include the budget reconciliation bill's reversal of a law requiring peer-to-peer payment platforms such as Venmo and PayPal to report aggregate payments of $600 or more.
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October 23, 2025
Court Won't Rethink 'Survivor' Winner's $3M Tax Bill
A Rhode Island federal judge won't reconsider his opinion that the first winner of reality show "Survivor" must pay $3.3 million in taxes, maintaining that it is unclear whether the federal government can take his sister's property to pay down the debt.
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October 22, 2025
Tax Co.'s Push To Escape Sex Harassment Verdict Falls Short
An Idaho federal judge rejected a tax business's bid Wednesday to escape potential liability for a $111,000 sexual harassment verdict won by a worker who claimed that the tax company acquired her former employer so that her ex-boss could avoid paying out on her lawsuit.
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October 22, 2025
US Among Few Places With Amount B Rules, OECD Reports
The U.S. is a significant exception to a swath of countries, including China, Japan and the U.K., that lack domestic rules allowing companies to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, the OECD reported Wednesday.
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October 22, 2025
Innocent Spouse Claim Is Barred, Tax Court Says
The wife of a man who failed to report overseas income is on the hook for the couple's shared tax liabilities, the U.S. Tax Court ruled Wednesday, rejecting her request to be cleared under a provision protecting spouses who are unaware of a partner's dealings.
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October 22, 2025
IRS Releases FAQs For Employee Retention Credits
The IRS issued answers Wednesday to a set of frequently asked questions related to the limitations for the fraud-riddled employee retention tax credit program that were implemented under the budget reconciliation law.
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October 22, 2025
'The Right Facts' Can Reduce Cos.' Tariff Impacts, Atty Says
Multinational companies with U.S. distributors that typically bear fewer business risks and earn low profit margins may be able to mitigate the effect of U.S. tariffs on their business as a whole by having a foreign principal bear the tariff costs, an attorney said Wednesday.
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October 22, 2025
Belgian Gov't Looks To Overturn US Tax Data Transfer Ruling
Belgium's data privacy watchdog was wrong to rule that the transfer of personal tax information to the U.S. breaks European Union law, the Belgian government told a Brussels court Wednesday, because the practice was established before the EU's data protection law took effect.
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October 22, 2025
Presidential Firing Limits Fight Builds At High Court
The ousted U.S. Merit Systems Protection Board chair has encouraged the U.S. Supreme Court to include a caveat for "legislative courts" if it overturns precedent that empowers Congress to limit the president's authority to fire certain agency officials, but opponents of independent agencies want a clean break from the status quo.
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October 22, 2025
Senate Sends IRS Clerical Error Correction Bill To Trump
A bill that would allow the IRS to adjust tax assessments to correct mathematical or clerical errors is headed to President Donald Trump's desk for his signature after the Senate approved the legislation, a senator who co-sponsored a related bill said Wednesday.
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October 22, 2025
Trade Court OKs $235K Tax Bill On Korean Soju Imports
South Korean alcoholic beverages were improperly classified upon entering the U.S., and U.S. Customs and Border Protection correctly calculated a nearly $235,000 bill in unpaid federal excise taxes plus interest, according to the U.S. Court of International Trade.
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October 22, 2025
Widow Not Liable For Husband's Tax Debt, 4th Circ. Told
An 80-year-old widow whose husband was imprisoned after hiding more than $20 million from the IRS told the Fourth Circuit that he was "abusive and controlling" and that she shouldn't have to pay the millions of dollars they jointly owe, despite contrary claims by the government.
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October 22, 2025
Construction Co. Owner Hid Income, Tax Court Says
A man who said he was a former officer of a California construction company was actually a 50% shareholder and failed to report income for 2016, including money diverted from a client to the purchase of a motor home, the U.S. Tax Court found.
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October 21, 2025
Nonprofits Face Pressure From GOP Tax Changes, Aides Say
Nonprofit organizations, charities and universities face sweeping changes under the Republicans' 2025 tax overhaul, Capitol Hill staffers said Tuesday, pointing to higher taxes on executive pay and endowments alongside revamped limits and incentives for individuals and corporations claiming charitable deductions.
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October 21, 2025
Partnership Deadline To Dispute IRS Is Fixed, Tax Court Says
A deadline to petition the U.S. Tax Court to challenge IRS adjustments to partnership returns is effectively fixed and cannot be extended, the court said Tuesday in a reviewed decision that denied an Alabama LLC's late bid to restore a $46 million deduction for donating to charity.
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October 21, 2025
Discovery Against Gem Company Halted In Malawi's Tax Probe
Malawi's government can no longer proceed with discovery against a gemstone company that partnered with a mining outfit the country claims evaded billions of dollars in taxes and royalties on exported rubies and sapphires, a Washington federal judge ruled, vacating his own order.
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October 21, 2025
CPA Group Calls For Transition Relief For Tips, OT Deductions
Internal Revenue Service guidance related to reporting requirements for the new deductions for tips and overtime should include a safe harbor for businesses for the 2025 tax year, the American Institute of Certified Public Accountants said in a letter released Tuesday.
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October 21, 2025
IRS Publishes Guidance For Car Loan Interest Reporting
The Internal Revenue Service released transitional guidance Tuesday for businesses' reporting requirements under the budget reconciliation law's new deduction for car loan interest.
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October 21, 2025
IRS Moves Tips Deduction Hearing To Phone-Only
The Internal Revenue Service will hold its scheduled hearing on the nearly 70 occupations proposed to be subject to President Donald Trump's policy of no tax on tips via phone instead of in person, the agency announced Tuesday.
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October 21, 2025
Jones Walker Expands To Chicago With Tax Partner Hire
Jones Walker LLP has hired a Chicago-based attorney for its transactional tax team from Chapman and Cutler LLP, marking its first move into Illinois.
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October 21, 2025
Hawaii Domino's Franchisee Sues IRS Over Penalty Dispute
The IRS owes a Domino's Pizza franchisee $1.6 million in tax refunds for penalties related to failures to report its employee health coverage plan, the franchisee told a Hawaii federal court, saying the company's payroll provider was first to blame and the IRS mishandled the fallout.
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October 21, 2025
CPA Admits $1.7M Tax Fraud, Pandemic Loan Charges
A Massachusetts certified public accountant has agreed to plead guilty to failing to disclose to the IRS nearly $1.7 million in off-the-books compensation to an employee and making false certifications to obtain pandemic relief loans.
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October 21, 2025
Medtronic Says 8th Circ. Wrongly Tossed Tax Court's Method
The Eighth Circuit's rejection of the U.S. Tax Court's latest ruling on the pricing of Medtronic intangibles placed unnecessary restrictions on the court's unspecified method addressing such assets transferred to Puerto Rico, the company argued as it asked the circuit court to rethink its decision.

Eaton To Defend Interest Rates, Fees Paid After 2012 Inversion
Eaton is preparing to defend the interest rates and guarantee fees paid by entities in the U.S. to their newly formed Irish parent after the company's 2012 acquisition and inversion at a U.S. Tax Court trial scheduled to start Nov. 3.

Tax Court Judge Warns Against Unchecked AI Use In Filings
A U.S. Tax Court judge cautioned attorneys Wednesday against relying on artificial intelligence to write filings without verifying the information it generates, saying recent "unfortunate incidents" have prompted the court to double down on accuracy in using such tools.

'Revenge Tax' May Reappear If Pillar 2 Talks Stall, Pros Say
Republican lawmakers are likely to revive what is commonly known as the revenge tax if countries are unable to flesh out a tentative agreement to effectively exempt U.S. companies from the 15% global corporate minimum tax regime known as Pillar Two, practitioners said Tuesday.
Featured Stories
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Modeling Needed To Gauge Private Equity's Interest Deduction
The Republican budget law's revival of a more generous business interest deduction has energized private equity deals that heavily rely on loans, though investors must run detailed financial modeling to measure how much the perk might truly pay off.
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French Digital Tax Ruling Puts Spotlight On Trade Tensions
A French court decision that upheld the nation's digital services tax could bolster similar measures in other European Union member states, but legal backing may mean little if countries use DSTs as bargaining chips in tariff negotiations with the United States.
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Tarter Krinsky Real Estate Chair Sees Office Market 'Normalcy'
Despite lingering economic questions, the office market is starting to reach a state of "normalcy," Tarter Krinsky's real estate leader told Law360 in a recent interview.
Expert Analysis
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IRS Shutdown Backlog May Trigger Collection, Refund Chaos
As the IRS continues to send automated collection notices amid the ongoing federal government shutdown, a mounting backlog of unprocessed refunds, collections filings and mail is causing problems for taxpayers that will continue even after the shutdown ends, says Meeren Amin at Fox Rothschild.
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SDNY OpenAI Order Clarifies Preservation Standards For AI
The Southern District of New York’s recent order in the OpenAI copyright infringement litigation, denying discovery of The New York Times' artificial intelligence technology use, clarifies that traditional preservation benchmarks apply to AI content, relieving organizations from using a “keep everything” approach, says Philip Favro at Favro Law.
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High Court, Not A Single Justice, Should Decide On Recusal
As public trust in the U.S. Supreme Court continues to decline, the court should adopt a collegial framework in which all justices decide questions of recusal together — a reform that respects both judicial independence and due process for litigants, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.
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Adapting To Private Practice: 3 Tips On Finding The Right Job
After 23 years as a state and federal prosecutor, when I contemplated moving to a law firm, practicing solo or going in-house, I found there's a critical first step — deep self-reflection on what you truly want to do and where your strengths lie, says Rachael Jones at McKool Smith.
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Painting Makes Me A Better Lawyer
Painting trains me to see both the fine detail and the whole composition at once, enabling me to identify friction points while keeping sight of a client's bigger vision, but the most significant lesson I've brought to my legal work has been the value of originality, says Jana Gouchev at Gouchev Law.
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Compliance Pointers Amid Domestic Terrorism Clampdown
A recent presidential memorandum marks a shift in federal domestic-terrorism enforcement that should prompt nonprofits to enhance diligence related to grantees, vendors and events, and financial institutions to shore up their internal resources for increased suspicious-activity monitoring and reporting obligations, say attorneys at Morgan Lewis.
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Trump Tax Law Has Mixed Impacts On Commercial Real Estate
The One Big Beautiful Bill Act brings sweeping changes to the real estate industry — and while the permanency of opportunity zones and bonus depreciation creates predictability for some taxpayers, sunsetting incentives for renewable energy projects will leave others with hard choices, says Jordan Metzger at Cole Schotz.
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Protecting Sensitive Court Filings After Recent Cyber Breach
In the wake of a recent cyberattack on federal courts' Case Management/Electronic Case Files system, civil litigants should consider seeking enhanced protections for sensitive materials filed under seal to mitigate the risk of unauthorized exposure, say attorneys at Redgrave.
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What Ethics Rules Say On Atty Discipline For Online Speech
Though law firms are free to discipline employees for their online commentary about Charlie Kirk or other social media activity, saying crude or insensitive things on the internet generally doesn’t subject attorneys to professional discipline under the Model Rules of Professional Conduct, says Stacie H. Rosenzweig at Halling & Cayo.
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2 Rulings Highlight IRS' Uncertain Civil Fraud Penalty Powers
Conflicting decisions from the U.S. Tax Court and the Northern District of Texas that hinge on whether the IRS can administratively assert civil fraud penalties since the U.S. Supreme Court’s 2024 decision in SEC v. Jarkesy provide both opportunities and potential pitfalls for taxpayers, says Michael Landman at Bird Marella.
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Junior Attys Must Beware Of 5 Common Legal Brief Mistakes
Excerpt from Practical Guidance
Junior law firm associates must be careful to avoid five common pitfalls when drafting legal briefs — from including every possible argument to not developing a theme — to build the reputation of a sought-after litigator, says James Argionis at Cozen O'Connor.
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Digital Asset Report Opens Doors For Banks, But Risks Linger
A recent report from a White House working group discussing digital asset market structure signals how banks may elect to expand into digital asset custody, trading and related services in the years ahead, but the road remains layered with challenges, say attorneys at Foley & Lardner.
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Power To The Paralegals: How And Why Training Must Evolve
Empowering paralegals through new models of education that emphasize digital fluency, interdisciplinary collaboration and human-centered lawyering could help solve workforce challenges and the justice gap — if firms, educators and policymakers get on board, say Kristine Custodio Suero and Kelli Radnothy.