Federal
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June 05, 2025
KFC Parent Co. Fights $4B IRS Bill In Tax Court
The parent company of Pizza Hut, KFC and Taco Bell is challenging $2.5 billion in taxes and penalties that the IRS claims it owes for a corporate reorganization to restructure its international operations, according to a U.S. Tax Court petition served Thursday, a figure that has topped $4 billion with interest.
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June 05, 2025
Justices Fault Wis. For Denying Tax Break To Charities
Wisconsin discriminated against a group of Catholic charities when it denied them an unemployment tax exemption, the U.S. Supreme Court said Thursday, rejecting the state's argument that the charities were not operated primarily for religious purposes.
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June 04, 2025
Cheesesteak Icon Asks 3rd Circ. If Loper Bright Slices Sentence
Counsel for a Philadelphia cheesesteak shop owner seeking a lighter sentence for paying employees off the books told the court Wednesday that he has asked the Third Circuit to consider how the U.S. Supreme Court's landmark decision striking longstanding agency deference framework might affect his case.
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June 04, 2025
NJ Man Cops To Dodging $2M Tax Bill On Real Estate
A New Jersey man linked to an intricate pension plan scheme involving refunds from the Dutch government pled guilty to evading more than $2.4 million in U.S. taxes by concealing ownership of more than $5.5 million in real estate, the U.S. Department of Justice said Wednesday.
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June 04, 2025
Trump Ordered To Explain Why Layoffs Don't Flout Injunction
A California federal judge ordered the Trump administration Wednesday to explain why preparations for layoffs at the State Department and Department of Housing and Urban Development do not violate an injunction she issued last month, saying she needed more details about the agencies' plans to evaluate their compliance.
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June 04, 2025
Biz Groups Urge US To Pressure Canada To Drop Digital Tax
A coalition of business lobbying groups have urged the U.S. government to take "decisive action" against Canada's digital services tax before the June 30 payment deadline, contending that the levy will cost U.S. companies about $2 billion this year.
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June 04, 2025
Senate May Clash With House On SALT Cap, Energy Credits
Senate Republicans are working to finalize the chamber's version of the House's nearly $4 trillion tax bill, and the Senate's bill is likely to conflict with the House's over proposed changes to the state and local tax deduction and green energy credits.
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June 04, 2025
Tax Court Rejects Frivolous Wage Classification Argument
A woman's wages from her job at Fidelity Investments should have been reported as income on her and her husband's joint tax return, the U.S. Tax Court affirmed Wednesday, upholding the IRS' deficiency finding and also hit the couple with a penalty.
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June 04, 2025
Mother-Son Car Co. Owners Owe Penalties, Tax Court Says
A mother and son who owned a used car business owe tax penalties for failing to report corporate dividends, the U.S. Tax Court ruled Wednesday, saying the pair couldn't back up their claim that the state of California had seized the records they needed to defend themselves.
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June 04, 2025
Satellite Co. Execs Released In $250M Fraud, Evasion Case
Two more satellite company executives facing charges of tricking investors out of $250 million are being released after their leader, who was additionally accused of tax crimes, was deemed a flight risk, according to D.C. federal court documents.
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June 04, 2025
Loeb & Loeb Trusts And Estates Head Jumps To Proskauer
Proskauer Rose LLP has hired the former chair of Loeb & Loeb LLP's international trusts and estates practice group to represent ultra-high-net-worth individuals and families.
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June 03, 2025
DC Circ. Rejects Tipster's Bid To Reverse IRS Award Denial
The D.C. Circuit refused to reinstate a tipster's petition for a whistleblower award before the U.S. Tax Court claiming his former employer intentionally misclassified him as an independent contractor, ruling Tuesday the Tax Court lacked jurisdiction since he failed to show the agency acted on his tip.
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June 03, 2025
NY Family Partnership Fights $4.5M Income Shift In Tax Court
A New York family partnership challenged an Internal Revenue Service determination that it formed mainly to reduce the tax liability of one of its limited partners, telling the U.S. Tax Court that the agency wrongly shifted $4.5 million in income taxable to him.
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June 03, 2025
WTO Useful For China Enforcement, US Trade Nominee Says
The U.S. should work with partners at the World Trade Organization to apply further trade pressure on China, making sure the country is complying with rules and trading fairly, a Skadden partner nominated by President Donald Trump to represent the U.S. at the WTO told lawmakers Tuesday.
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June 03, 2025
OECD Predicts Growth Slowdown From US Tariffs, Responses
Trade barriers — most notably U.S. tariffs and other countries' reciprocal measures — could result in a slowdown in global economic growth, the Organization for Economic Cooperation and Development said Tuesday, projecting a dip over the next two years.
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June 03, 2025
Senate Panel Advances Trump's Pick To Lead IRS
The Senate Finance Committee approved President Donald Trump's selection of former U.S. Rep. Billy Long to serve as commissioner of the IRS on Tuesday, sending the nomination to the full Senate.
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June 03, 2025
Irish Court Says US Co.'s Irish Units Not Owed Treaty Benefits
Three Irish subsidiaries cannot benefit from the U.S.-Ireland tax treaty's provision of equally favorable treatment between U.S. and Irish residents because their ultimate parent entity, a Delaware financial firm, is disregarded for U.S. tax purposes, Ireland's Court of Appeal said in a judgment.
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June 03, 2025
The Law360 400: A Look At The Top 100 Firms
A rebound in client work sent the nation’s largest law firms into growth mode last year, driving a wave of hiring, mergers and strategic moves that reshaped the top tier of the Law360 400. Here's a preview of the 100 firms with the largest U.S. attorney headcounts.
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June 03, 2025
Precedent Does Apply To $6.6M Microcaptive Case, Court Told
A captive insurance program operator challenging $6.6 million in tax fraud penalties told a Pennsylvania federal court that the government boldly and incorrectly claimed that the U.S. Supreme Court's landmark ruling requiring a jury to make certain fraud findings doesn't apply to its case.
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June 02, 2025
Budget Bill Would Deepen Residential Solar's Woes
A Sunnova unit's bankruptcy declaration — the latest among dozens of solar companies that have struggled to stay afloat — adds to evidence of a floundering residential solar industry, which now faces further diminishing prospects under the federal budget reconciliation bill.
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June 02, 2025
1st Circ. Largely Backs Convictions For Cop Union Kickbacks
The First Circuit on Monday mostly upheld the convictions of a former Massachusetts state police union president and a Beacon Hill lobbyist who were found guilty of running a kickback scheme, but ordered new sentencing hearings for them after vacating some of the guilty findings.
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June 02, 2025
IRS Issues Interim Regs To Simplify Corp. AMT Determination
The Internal Revenue Service released temporary regulations Monday that offered a simplified method for large companies seeking to determine whether the 15% corporate alternative minimum tax applies to them, as well as penalty relief for those that underpaid the levy this year.
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June 02, 2025
Justices Urged To Reject Bid Disputing IRS Crypto Summons
The U.S. Supreme Court should not take up the case of a bitcoin investor who claimed the IRS violated his privacy when it seized his records from the cryptocurrency exchange, the government argued, saying the case is a poor vehicle for addressing concerns about digital-era transactions.
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June 02, 2025
4 Mass. Rulings You May Have Missed In May
Massachusetts judges grappled with accusations of fraud in the sale of a struggling life sciences company and gave the benefit of the doubt to a vendor who allegedly sold the state gallons of ineffective hand sanitizer, among other notable rulings last month.
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June 02, 2025
Tax Court Finds No Abuse By IRS In Rejecting Man's Tax Offer
The Internal Revenue Service did not abuse its discretion in rejecting a man's offer in compromise for the balance on a $400,000 tax bill, the U.S. Tax Court ruled Monday, saying the agency properly considered cash in the man's bank account and his current wages.
Expert Analysis
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.
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Congress Can And Must Enact A Supreme Court Ethics Code
As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.
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What To Make Of Dueling Corporate Transparency Act Rulings
Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.
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The Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan
Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.
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State Of The States' AI Legal Ethics Landscape
Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.
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8 Childhood Lessons That Can Help You Be A Better Attorney
A new school year is underway, marking a fitting time for attorneys to reflect on some fundamental life lessons from early childhood that offer a framework for problems that no legal textbook can solve, say Chris Gismondi and Chris Campbell at DLA Piper.
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How The 2025 Tax Policy Debate Will Affect The Energy Sector
Regardless of the outcome of the upcoming U.S. election, 2025 will bring a major tax policy debate that could affect the energy sector more than any other part of the economy — so stakeholders who could be affected should be engaging now to make sure they understand the stakes, say attorneys at Mayer Brown.
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This Election, We Need To Talk About Court Process
In recent decades, the U.S. Supreme Court has markedly transformed judicial processes — from summary judgment standards to notice pleadings — which has, in turn, affected individuals’ substantive rights, and we need to consider how the upcoming presidential election may continue this pattern, says Reuben Guttman at Guttman Buschner.
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Mental Health First Aid: A Brief Primer For Attorneys
Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.
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The Trade And Tax Issues Behind US-Canada Digital Tax Clash
The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.
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Litigation Inspiration: Honoring Your Learned Profession
About 30,000 people who took the bar exam in July will learn they passed this fall, marking a fitting time for all attorneys to remember that they are members in a specialty club of learned professionals — and the more they can keep this in mind, the more benefits they will see, says Bennett Rawicki at Hilgers Graben.
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AI May Limit Key Learning Opportunities For Young Attorneys
The thing that’s so powerful about artificial intelligence is also what’s most scary about it — its ability to detect patterns may curtail young attorneys’ chance to practice the lower-level work of managing cases, preventing them from ever honing the pattern recognition skills that undergird creative lawyering, says Sarah Murray at Trialcraft.
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A Look At How De Minimis Import Rules May Soon Change
The planned implementation of executive actions focused on the de minimis rule as it applies to shipments means companies should use this interval to evaluate the potential applicability and impact of Section 301, Section 201 or Section 232 duties on their products, say attorneys at Holland & Knight.