Federal
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December 15, 2025
Supreme Court Declines Cannabis Ban Review
The U.S. Supreme Court on Monday declined to hear a case challenging the federal marijuana ban, leaving in place a high court precedent that has governed cannabis policy for 20 years.
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December 12, 2025
Judge Says Eaton Moved $14B Subsidiary For Tax Purposes
A U.S. Tax Court judge said Friday that he plans to find Eaton's U.S. group transferred ownership of a $14 billion subsidiary overseas in 2012 solely to justify payment of higher interest rates and guarantee fees to the company's new Irish parent.
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December 12, 2025
DOJ Shake-Up Keeps Criminal Tax Meetings, Ex-Official Says
The U.S. Department of Justice — despite recently eliminating its Tax Division as part of a broad restructuring — continues to meet with practitioners representing clients who may face federal criminal tax charges, the former division chief said Friday.
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December 12, 2025
IRS To Revamp Voluntary Disclosure Program
The Internal Revenue Service will be updating a program early next year that would allow taxpayers to voluntarily report previously undisclosed income as a way to resolve their tax issues to facilitate a simpler reporting process, the agency's criminal enforcement chief said Friday.
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December 12, 2025
Treasury Withdraws Proposed Regs On Spousal Tax Liability
The U.S. Treasury Department has withdrawn two sets of proposed regulations addressing married individuals who filed joint tax returns then later sought relief from joint and several tax liability, according to a notice issued Friday.
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December 12, 2025
New Scholarship Tax Credit Plan Open To States, IRS Says
States can make an advance election to participate in a new tax credit program for contributions made to scholarship organizations, the Treasury Department and the Internal Revenue Service announced Friday, adding that the program is set to start in 2027.
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December 12, 2025
Treasury Issues Final Rules For Taxing Foreign Gov't Income
The U.S. Treasury Department issued final regulations Friday for determining whether income of foreign governments derived within the U.S. is taxable along with proposed regulations concerning when a foreign government has effective control of a commercial entity.
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December 12, 2025
IRS Sets 2026 Wage Base For Covered Compensation
The taxable wage base used to calculate covered compensation for employee retirement plans will be $184,500 for the 2026 tax year, the Internal Revenue Service announced in a revenue ruling Friday.
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December 12, 2025
Taxation With Representation: Cravath, Skadden, Debevoise
In this week's Taxation With Representation, Paramount Skydance Corp. launches a hostile bid for Warner Bros. Discovery, challenging Netflix's deal to acquire the studio and streaming business, IBM acquires data streaming company Confluent, and natural gas company Antero Resources Corp. expands via a deal with HG Energy.
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December 12, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included final regulations for the excise tax on corporations' stock buybacks and similar transactions without what is known as the funding rule.
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December 11, 2025
IRS Plans Outreach Campaign For NIL Income Earners
The Internal Revenue Service plans to launch an outreach campaign to educate student-athletes, entertainers, artists and social media influencers about the tax implications of income earned through personal brand marketing, endorsements and similar activities, an agency official said Thursday.
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December 11, 2025
Judge Slams Eaton Expert For Offering Legal Analysis
A report submitted by one of Eaton's expert witnesses in its acquisition financing trial overstepped the limits of an expert's role, offering legal rather than economic analysis and seeming to advocate for the company, a U.S. Tax Court judge said Thursday.
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December 11, 2025
Failed ACA Credit Extension Votes Leave Costs In Limbo
The Senate failed Thursday to pass procedural votes on two healthcare proposals to address the upcoming lapse in the Affordable Care Act's enhanced premium tax credits, including a proposal by Democrats to extend the subsidies for three years.
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December 11, 2025
Fed Terminates 3 Actions Against Credit Suisse, JPMorgan
The Federal Reserve said Thursday that it has terminated a trio of enforcement actions against Credit Suisse Group AG and JPMorgan Chase & Co., lifting consent orders that were tied to alleged illicit finance practices and trade surveillance failures.
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December 11, 2025
Group Seeks Cannabis Reclassification Regarding Tax Status
Cannabis shouldn't be categorized as a Schedule 1 or 2 drug, so tax law regarding the sale of illegal drugs shouldn't be applied to cannabis sales, a coalition of cannabis industry groups told the U.S. Tax Court in an amicus brief Thursday.
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December 11, 2025
Tax Court Rejects Nevada Couple's Law Firm Deductions
A married couple who are both attorneys are subject to a federal tax lien because they are not entitled to deductions and reduced gross receipts related to their law firm, and they aren't entitled to claimed losses from real estate, the U.S. Tax Court said Thursday.
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December 10, 2025
House Advances Bill To Suspend Tax Refund Claim Limits
The House Ways and Means Committee approved several tax bills Wednesday, including legislation that suspends the limitation period to file a refund claim until an IRS collection due process hearing concludes and all appeals rights have lapsed in levy cases.
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December 10, 2025
Judge Probes IRS Expert On Method For Eaton's Credit Rating
A U.S. Tax Court judge asked an IRS expert Wednesday about his calculation of a standalone credit rating for Eaton's U.S. group in 2012, when it acquired an Irish entity and inverted, noting that the expert, unlike ratings agency Standard & Poor's, factored in Eaton's debt to the Irish parent.
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December 10, 2025
6th Circ. Chides US For Lacking Merits In Distilling Ban Case
A Sixth Circuit judge criticized the U.S. Department of Justice on Wednesday for refusing to address the merits of a suit challenging the constitutionality of the U.S. tax code's ban on home distilling, saying the government cannot decide what the appellate court reviews.
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December 10, 2025
DOJ Seeks Fairness Review From High Court In Tax Dispute
A property owner is appropriately compensated if given surplus proceeds from a government sale of their property for more than the owner owed, provided the sale was conducted fairly, the federal government told the U.S. Supreme Court.
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December 10, 2025
7th Circ. Upholds Tax Conviction Of DHS Special Agent
A jury relied on enough evidence to convict a former U.S. Department of Homeland Security agent of tax crimes related to his secret dealings with drug dealers, the Seventh Circuit said Wednesday, rejecting his claim that proof of his corruption was insufficient.
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December 10, 2025
Magistrate Backs FinCEN Rules In All-Cash Real Estate Deals
A magistrate judge in Florida federal court rejected arguments from a title insurance company in upholding a U.S. Department of Treasury rule establishing new reporting requirements for all-cash residential real estate transactions as a means of combating financial crime.
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December 09, 2025
Judge Wants Cost-Benefit Analysis Of Eaton Guarantees
A U.S. Tax Court judge asked one of Eaton's experts Tuesday how much the company could have saved by issuing debt from its new Irish parent in 2012 instead of having the parent guarantee bonds the U.S. company issued to third parties.
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December 09, 2025
7th Circ. Denies Tax Evader's New Trial Over Disciplined Atty
A man convicted of tax fraud will not get a new trial based on his lawyer's removal from the Seventh Circuit Bar two months after his conviction in an unrelated case, the appellate court ruled Tuesday, saying the discipline must relate to his own defense.
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December 09, 2025
US Asks 5th Circ. To Revive ACA Employer Tax Penalties
The IRS properly penalized a janitorial services company for failing to provide employees with healthcare coverage under the Affordable Care Act, the U.S. government said, urging the Fifth Circuit to reverse a Texas federal court ruling that voided regulations promulgating the penalties.
Expert Analysis
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We Must Allow Judges To Use Their Independent Judgment
As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.
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Preparing For Tariffs On Canadian Power In The Northeast
The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.
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Making The Case For Rest In The Legal Profession
For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.
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Mitigating Tariff Risks For Healthcare In US And Canada
Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.
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4 Ways Women Attorneys Can Build A Legal Legacy
This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.
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A Judge's Pointers For Adding Spice To Dry Legal Writing
U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.
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Why NY May Want To Reconsider Its LLC Transparency Law
Against the backdrop of the myriad challenges to the federal Corporate Transparency Act, it may be prudent for New York to reconsider its adoption of the LLC Transparency Act, since it's unclear whether the Empire State's "baby-CTA" statute is still necessary or was passed prematurely, say attorneys at Pillsbury.
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IRS Scrutiny May Underlie Move Away From NIL Collectives
The University of Colorado's January announcement that it was severing its partnership with a name, image and likeness collective is part of universities' recent push to move NIL activities in-house, seemingly motivated by tax implications and increased scrutiny by the Internal Revenue Service, say attorneys at Buchanan Ingersoll.
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7 Tips For Associates To Thrive In Hybrid Work Environments
Excerpt from Practical Guidance
As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.
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IRS Should Revise Overbroad Microcaptive Regs
Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.
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Terraform Case May Be Bellwether For Crypto Enforcement
The prosecution of crypto company Terraform Labs and its CEO, Do Kwon, offers a unique test of the line between lawful and unlawful conduct in digital transactions, and the Trump administration’s posture toward the case will provide clues about its cryptocurrency enforcement agenda in the years to come, say attorneys at Brooks Pierce.
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How Law Firms Can Counteract The Loneliness Epidemic
The legal industry is facing an urgent epidemic of loneliness, affecting lawyer well-being, productivity, retention and profitability, and law firm leaders should take concrete steps to encourage the development of genuine workplace connections, says Michelle Gomez at Littler and Gwen Mellor Romans at Herald Talent.
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Texas Fraud Case Shows Dangers Of Faulty Crypto Reporting
The recent sentencing of a man who failed to properly report capital gains from bitcoin sales is a reminder that special attention must be given to the IRS' reporting requirements in order to stay out of the government's crosshairs, says Saverio Romeo at Fox Rothschild.