Federal
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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
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What Compensation Committees Must Keep In Mind In 2025
New disclosure obligations, an evolving discussion on the analysis of executive perks and updated proxy adviser policies — on top of a new presidential administration — are all important things compensation committees must pay close attention to in 2025, say attorneys at Simpson Thacher.
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Anticipating Direction Of Cosmetics Regulation Under Trump
It is unclear how cosmetics regulation reform from the last few years will fare under President Donald Trump, but the new administration's emphasis on deregulation and Robert F. Kennedy Jr.'s views on product safety provide some insight, say attorneys at Crowell & Moring.
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IRS Basis-Shifting Rule Poses Notable Reporting Obligations
While the IRS’ recently finalized rule requiring partnerships to report certain related-party basis adjustment transactions is narrower than originally proposed, taxpayers and their advisers will still need to comb through myriad transactions to comply, say attorneys at Debevoise.
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Imagine The Possibilities Of Openly Autistic Lawyering
Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.
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Litigation Funding Disclosure Debate: Strategy Considerations
In the ongoing debate over whether courts should require disclosure of litigation funding, funders and plaintiffs tend to argue against such mandates, but voluntarily disclosing limited details about a funding arrangement can actually confer certain benefits to plaintiffs in some scenarios, say Andrew Stulce and Marc Cavan at Longford Capital.
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Top Considerations For Insurance Companies In 2025
As insurance industry participants look to plan for the year, regulatory changes, climate-related challenges, the ongoing effects of social inflation and the potential for significant mergers and acquisitions will be among the key items for insurer boards and management to have on their radar, say attorneys at Debevoise.
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Scope And Nature Of Judicial Relief Will Affect Loper's Impact
The practical result of post-Loper Bright rulings against regulatory actions will depend on the relief courts grant — and there has been controversy in these types of cases over whether the ruling is applied just to the parties or nationwide, and whether the action can be left in place while it's corrected, says Steven Gordon at Holland & Knight.
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5 Ways To Create Effective Mock Assignments For Associates
In order to effectively develop associates’ critical thinking skills, firms should design mock assignments that contain a few key ingredients, from messy fact patterns to actionable feedback, says Abdi Shayesteh at AltaClaro.
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Congress Should Pass Sex Abuse Settlement Tax Exemptions
The proposed Survivor Justice Tax Prevention Act would expand tax exemptions more clearly for sexual abuse cases, and finally remove the stigma around compensation for emotional and psychological damage, says Rocco Strangio at Milestone & Co.
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What's Next For Accounting Enforcement After SEC's Big 2024
The U.S. Securities and Exchange Commission under the Trump administration will likely continue to focus enforcement efforts on many of the same accounting and auditing issues that it pursued over the past year — but other areas, such as ESG, internal controls and cryptocurrency cases, may fall out of focus, say attorneys at Debevoise.
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Mentorship Resolutions For The New Year
Attorneys tend to focus on personal achievements or career milestones when they set yearly goals, but one important area often gets overlooked in this process — mentoring relationships, which are some of the most effective tools for professional growth, say Kelly Galligan at Rutan & Tucker and Andra Greene at Phillips ADR.
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Coaching Little League Makes Me A Better Lawyer
While coaching poorly played Little League Baseball early in the morning doesn't sound like a good time, I love it — and the experience has taught me valuable lessons about imperfection, compassion and acceptance that have helped me grow as a person and as a lawyer, says Alex Barnett at DiCello Levitt.
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5 Litigation Funding Trends To Note In 2025
Lawyers and their clients must be prepared to navigate an evolving litigation funding market in 2025, made more complicated by a new administration and the increasing overall cost of litigation, says Jeffery Lula at GLS Capital.