Federal
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August 26, 2025
Facebook Urges Tax Court To Toss IRS' Royalty Calculations
Facebook asked the U.S. Tax Court to reject the IRS' proposed royalty rate and other calculations for the social media giant's deal with an Irish affiliate to develop intangibles, arguing the agency is attempting to recharacterize the transaction.
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August 26, 2025
IRS Urged To Avoid Retroactive Solar, Wind Tax Changes
Changes to the beginning-of-construction definition under rules to determine large solar and wind energy development projects' eligibility for certain tax credits should not be applied retroactively, several groups said in letters to the U.S. Department of the Treasury released Tuesday.
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August 26, 2025
EU Defends Digital Taxes Following Trump's Tariff Threat
The European Commission said Tuesday that it stands by European Union member states keeping digital taxes in place despite President Donald Trump's renewed threats to impose tariffs on countries with measures hitting the U.S. tech giants.
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August 25, 2025
6th Circ. Says Tax Court Filing Deadline Can Be Tolled
The 90-day deadline to petition the U.S. Tax Court is not a jurisdictional bar and may be extended for certain reasons, the Sixth Circuit found Monday, reviving a woman's late challenge to an IRS tax deficiency.
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August 25, 2025
Tax Court Tosses Suit From Accountant Who Copped To Fraud
An accountant who admitted to tax and healthcare fraud in connection with an Alabama group home for disabled people can't challenge a tax debt because the underlying IRS notice stating the amount due was a reminder, not a determination, the U.S. Tax Court said Monday.
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August 25, 2025
NC Man Gets Nearly 20 Years For Tax Fraud, Ponzi Scheme
A North Carolina man was sentenced to nearly 20 years in prison after willfully failing to report nearly $9 million in income to the Internal Revenue Service and evading more than $3 million in taxes in connection with a $20 million Ponzi scheme, federal prosecutors said.
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August 25, 2025
Tax Interest Rates To Stay Steady In 4th Quarter
The Internal Revenue Service's interest rates for overpayments and underpayments of tax will remain the same in the quarter starting in October, the agency said Monday.
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August 25, 2025
Advocate Orgs. Ask DC Circ. To Stop IRS Sharing Info With ICE
Immigrant advocacy groups urged the D.C. Circuit to stop the IRS from sharing taxpayer addresses with immigration authorities, saying the court should consider the substance of their challenge to an unprecedented information sharing deal rather than toss their case on procedural grounds put forward by the government.
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August 25, 2025
Ex-TSA Attorney Among 3 New Lawyers At Kaplan Kirsch
A former Transportation Security Administration attorney is among three lawyers who recently joined Kaplan Kirsch LLP, a Denver-based law firm that specializes in representing state, local and tribal government agencies on projects such as airport expansions and new rail lines.
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August 25, 2025
Connecticut Court Backs Ouster Of Tax Atty Over Rogue Email
Connecticut's former tax legal director was properly terminated after she used her work computer to send unauthorized draft legislation from her personal email account to a lobbyist who assumed that it was the state tax department's official position, a Connecticut appeals panel has ruled.
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August 25, 2025
Woman Who Beat $1.7M In Tax Liens Can't Recover Costs
A woman blamed by the government for the employment tax failures of her husband's construction company cannot recover her legal costs after a jury cleared her, a New York federal judge ruled, saying the U.S. was justified in trying to uphold $1.7 million in liens against her.
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August 22, 2025
Liberty Global $240M Foreign Tax Credit Bid Fails At 10th Circ.
Liberty Global cannot claim $240 million in foreign tax credits for the sale of a Japanese affiliate, the Tenth Circuit ruled Friday, rejecting the telecommunications giant's contention that a statutory provision allows it to recharacterize the proceeds as overseas income.
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August 22, 2025
Canada To Toss Tariffs On US Goods Under USMCA
The Canadian government will remove retaliatory tariffs on U.S. goods that comply with the United States-Mexico-Canada Agreement, excluding steel, aluminum and automobiles, in a move aimed at jump-starting trade talks akin to an exemption made by the U.S. government, Canada's prime minister said Friday.
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August 22, 2025
Tribe Member Can't Discharge Tax Debt, 10th Circ. Affirms
An Oklahoma federal court correctly affirmed a bankruptcy court's refusal to reopen a case brought by a member of the Muscogee Creek Nation who claimed his tax debt should have been discharged in bankruptcy, the Tenth Circuit said.
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August 22, 2025
Taxation With Representation: Kirkland, Weil, Fried Frank
In this week's Taxation With Representation, private equity firm Thoma Bravo buys human resources software provider Dayforce Inc. in a take-private deal, Lowe's buys Foundation Building Materials, Nexstar Media Group Inc. acquires fellow media company Tegna Inc., and Soho House & Co. Inc. inks a take-private deal with hotel operator MCR.
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August 22, 2025
Michigan Judge Gives Initial OK To Tax Foreclosure Deal
A Michigan federal judge has granted preliminary approval to a settlement that would allow former property owners to receive the surplus profits they allege county treasurers made selling their tax-delinquent properties.
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August 22, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included proposed rules that would change its system of business classification for employees hoping to exclude fringe benefits and employee discounts from their gross income.
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August 22, 2025
Treasury Doubles Statutory Value Of Clean Energy Credit
The U.S. Department of the Treasury is nearly doubling the statutory value of an income tax credit for producing electricity in line with a regularly scheduled increase tied to inflation, according to a Friday notice.
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August 22, 2025
IRS Guidance Sparks Mixed Reaction For Solar, Wind Projects
The IRS recently narrowed the way large solar and wind energy development projects can set their construction start dates to qualify for certain tax credits, a change offering relief for some developers but new hurdles for others depending on the stage, type and size of the project.
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August 21, 2025
Tax Court Says Civil Fraud Penalty Cases Don't Require Juries
The U.S. Tax Court rejected Thursday a Mississippi partnership's bid, based on the Supreme Court's landmark 2024 decision requiring a jury to adjudicate common law fraud penalties, to dismiss civil fraud penalties the IRS imposed on a conservation easement transaction.
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August 21, 2025
Man Who Hid Account From Wife Owes FBAR Fines, US Says
A claim by the owner of a check-cashing business that he only meant to hide a foreign bank account from his wife during divorce proceedings doesn't excuse his failure to report the money to the Internal Revenue Service, the U.S. told a California federal court.
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August 21, 2025
EU, US Agree To Eliminate Industrial Tariffs
The European Union and the U.S. have agreed on new terms to the trade agreement to eliminate EU tariffs on U.S. industrial products and implement a 15% U.S. tariff cap for most other sectors, according to a joint statement issued Thursday.
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August 21, 2025
Treasury Gets New Acting International Tax Counsel
A deputy international tax counsel for the U.S. Department of the Treasury has been elevated to serve as acting counsel, he said in a post on LinkedIn.
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August 21, 2025
IRS Asks For Input On Free Filing Programs
The Internal Revenue Service is surveying the public on tax preparation and filing as part of efforts to prepare a report for Congress on key issues surrounding free tax filing options, the agency said Thursday.
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August 21, 2025
Gov't Shrugs Off Sentencing Errors, IRS Leaker Tells DC Circ.
The IRS contractor appealing his five-year prison sentence for leaking thousands of wealthy people's tax returns to the media accused the U.S. of glossing over sentencing errors that unfairly burdened him with "the harshest sentence possible," he told the D.C. Circuit.
Expert Analysis
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Expect Surging Oil And Gas Industry Under New Trump Admin
Throughout his recent campaign, President-elect Donald Trump promised increased oil and natural gas production and reduced reliance on renewables — and his administration will likely bring more oil and gas dealmaking, faster federal permitting and attempts to roll back incentives for green energy, say attorneys at Sidley.
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The Bar Needs More Clarity On The Discovery Objection Rule
Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.
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Cos. Should Inventory Issues To Prep For New Congress
As the legislative and oversight agendas of the 119th Congress come into sharper focus, corporate counsel should assess and plan for areas of potential oversight risk — from tax policy changes to supply chain integrity — even as much uncertainty remains, say attorneys at WilmerHale.
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Conservation Easement Cases Weave Web Of Uncertainty
Much of the IRS and Justice Department’s recent success in prosecuting syndicated conservation easement cases can be attributed to the government’s focus on the so-called PropCo ratio, which could indicate treacherous waters ahead for participants and their advisers, even under the incoming Trump administration, say attorneys at Polsinelli.
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So You Want To Move Your Law Practice To Canada, Eh?
Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.
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Legislation Most Likely To Pass In Lame Duck Session
As Congress begins its five-week post-election lame duck session, attorneys at Greenberg Traurig break down the legislative priorities and which proposals can be expected to pass.
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What Trump's 2nd Presidency Could Mean For Crypto Sector
Trump's second term will bring a fundamental shift from the Biden administration's approach to crypto-asset regulation and banking supervision, with the most significant changes likely taking effect in the first two quarters of 2025 and broader policy shifts emerging over the next year, say attorneys at Cahill.
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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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Takeaways From The IRS' Crypto Doc Summons Win
A recent First Circuit decision holding that taxpayers do not have a Fourth Amendment reasonable expectation of privacy in cryptocurrency transaction records should prompt both taxpayers and exchanges to take stock of past transactions and future plans, say attorneys at BakerHostetler.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Ex-Chicago Politician's Case May Further Curb Fraud Theories
The U.S. Supreme Court recently agreed to hear Thompson v. U.S. to determine whether a statement that is misleading but not false still violates federal law, potentially heralding the court’s largest check yet on prosecutors’ expansive fraud theories, with significant implications for sentencing, say attorneys at the Law Offices of Alan Ellis.