Federal
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November 14, 2025
IRS Expert Challenges Data Used In Eaton's Projections
An expert witness for the Internal Revenue Service questioned the financial projections prepared by Eaton Corp.'s experts Friday in U.S. Tax Court, saying the data they relied on wasn't available in 2012, when the company took on debt to acquire Ireland-based Cooper Industries, a global electrical products manufacturer, for $13 billion.
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November 14, 2025
The Tax Angle: Letter Ruling Debate, Experts' Role In Policy
From a discussion on whether seeking a private letter ruling risks sparking more IRS oversight to a former Congressional Budget Office director's thoughts on tax experts' role in policymaking, here's a peek into a reporter's notebook on stories from the National Tax Association's annual conference in Boston.
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November 14, 2025
Trump Pulls IRS Chief Counsel Nomination Before Floor Vote
President Donald Trump on Friday withdrew his nomination of a Sullivan & Cromwell attorney to be the Internal Revenue Service's chief counsel just weeks after the Senate Finance Committee voted to advance the nomination to the Senate floor.
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November 14, 2025
MVP: Latham's Pardis Zomorodi
Pardis Zomorodi, partner at Latham & Watkins LLP's transactional tax practice in Los Angeles, has guided companies through the tax aspects of major complex transactions, including 2024's largest IPO and the high-profile merger between Skydance Media and Paramount Global, earning her a spot as one of the 2025 Law360 Tax MVPs.
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November 14, 2025
DC Circ. Urged To Block Trump Org. From IRS Leaker's Appeal
President Donald Trump's private business organization should not be allowed to intervene in a former IRS contractor's challenge to his prison sentence for leaking Trump's and other wealthy people's tax returns, the contractor told the D.C. Circuit, saying the organization's participation would unfairly bias the court.
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November 14, 2025
US To Slash Tariff On Swiss Imports To 15% In Trade Deal
The U.S. will reduce a 39% tariff on Swiss imports to 15% as part of a framework trade agreement reached with Switzerland, according to Friday announcements by the White House and the Swiss government.
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November 14, 2025
Taxation With Representation: Wachtell, Paul Hastings, Sidley
In this week's Taxation With Representation, Pfizer Inc. completes its acquisition of obesity drug developer Metsera Inc., motion and controls technologies company Parker-Hannifin Corp. acquires Filtration Group Corp., and fund administrator JTC PLC backs a cash offer in the billions from British private equity shop Permira.
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November 14, 2025
Biz Contests $1.7M Tax Bill After Insurance Deductions Axed
The Internal Revenue Service incorrectly hit a Colorado corporation with $1.7 million in taxes and penalties after erroneously disallowing deductions the company claimed for insurance premiums, the company told the U.S. Tax Court in a petition published Friday.
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November 14, 2025
Liquidated Captive Insurer Fights IRS Bill In Tax Court
A captive insurance company that was later dissolved challenged $800,000 in taxes and penalties in the U.S. Tax Court, saying the Internal Revenue Service wrongly claimed the company had $3 million in unreported long-term capital gains.
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November 14, 2025
US Expatriations Rise To 1,600 In 3rd Quarter, IRS Says
The number of people who lost or renounced their U.S. citizenship totaled 1,600 in the third quarter as logged by the U.S. Treasury Department, a 50% increase from the previous quarter, the IRS said Friday.
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November 14, 2025
Ala. Partnerships Say IRS Erred Rejecting Easement Breaks
The Internal Revenue Service unlawfully denied a pair of Alabama partnerships' $40 million charitable tax deduction on a conservation easement they donated in 2020, the partnerships told the U.S. Tax Court, arguing the agency offered no sufficient explanation for its determination.
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November 14, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service released its weekly internal revenue bulletin Friday, which included guidance for group health plans and health insurers to calculate out-of-network healthcare coverage for 2026.
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November 13, 2025
Eaton Witnesses Probed About Data Used For Credit Analysis
An accounting expert and a former Eaton Corp. official both advised the U.S. Tax Court on Thursday about the data used to establish the financial position of the U.S. company after its acquisition of Irish-based Cooper Industries in 2012.
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November 13, 2025
Clean Energy Cos. Tap Private Cash To Beat Tax Credit Clock
Clean energy developers are increasingly looking to privately held investors to ensure they can do enough work to keep their projects fully eligible for tax credits that start phasing out next year, energy development attorneys told Law360.
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November 13, 2025
Latin American Trade Deals With US Include Zero Tariff Rates
Latin American countries including El Salvador, Guatemala, Ecuador and Argentina committed to nontariff reductions for U.S. producers in exchange for a zero tariff rate on many imports not readily available in the U.S., under details of framework trade agreements the White House unveiled Thursday.
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November 13, 2025
Tax Court Lets Oil Co. Split Losses In $72M Carryback Dispute
An oil and gas company was allowed to give up the normal carryback period for its net operating losses without waiving the 10-year period for $72 million in specified liability losses, a divided U.S. Tax Court ruled Thursday, with two judges saying the rules aren't so flexible.
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November 13, 2025
Tax Court Upholds Levy Action For $186K Deficiency In Ala.
The U.S. Tax Court affirmed an Internal Revenue Service decision to collect an Alabama couple's $186,000 tax debt, ruling Thursday that despite sympathy for the wife's severe medical condition, the husband had failed to participate in proceedings to make his case.
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November 13, 2025
High Court's Tariff Ruling May Trigger Refunds, Reimposition
Importers are being advised to prepare for potential refunds in the event the U.S. Supreme Court rules President Donald Trump's emergency tariffs are unlawful, leaving questions about how a refund process might play out and whether the duties would be reimposed.
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November 13, 2025
Tax Court Denies Couple's EITC Claim Over Lack Of Proof
An Alabama couple who claimed a $3,600 earned income tax credit did not prove that they are entitled to it, the U.S. Tax Court said Thursday, ruling that the pair are not eligible to claim the credit for the wife's sister.
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November 13, 2025
MVP: Kirkland's Adam Kool
Adam Kool, a tax partner at Kirkland & Ellis LLP, spent the past year advising on high-profile, industry-transforming transactions. Kool's work on AbbVie's $63 billion acquisition of the pharmaceutical giant Allergan, GTCR's pending $24.25 billion sale of global payment processing company Worldpay and other billion-dollar transactions has earned him a spot as one of the 2025 Law360 Tax MVPs.
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November 13, 2025
Trump Org. Pushes DC Circ. To Back IRS Leaker's Sentence
President Donald Trump's private business organization said it opposes any reduction to the five-year prison sentence of the former IRS contractor who leaked Trump's tax returns and thousands of others, telling the D.C. Circuit the leaker has been shown enough leniency.
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November 13, 2025
Tax Interest Rates To Hold Steady In 1st Quarter
The Internal Revenue Service's interest rates for overpayments and underpayments of tax will remain the same for the calendar quarter beginning Jan. 1, the agency said Thursday.
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November 13, 2025
IRS Increases Retirement Fund Contribution Limits
The Internal Revenue Service on Thursday announced the increased limit for contributions to various retirement accounts, including upping the 401(k) limit to $24,500.
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November 13, 2025
In-House Tax Controversy Director Joins Miller & Chevalier
The former director of tax controversy at Cleveland, Ohio-based real estate company GBX Group LLC has moved to Miller & Chevalier Chtd.'s Washington, D.C., office, where she'll continue working on a range of tax-related matters.
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November 12, 2025
Ports Warn USTR Against China Ship Fees, Crane Tariffs
The U.S. Trade Representative should reconsider tariffs on Chinese cranes and fees on Chinese and other foreign ships while those measures are suspended for the next year as part of a trade truce between China and the U.S., according to comments recently submitted by a U.S. port industry association.
Expert Analysis
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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.
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5 Real Estate Takeaways From Trump's Sweeping Tax Law
Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.
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Evaluating The Current State Of Trump's Tariff Deals
As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.
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How Hyperlinks Are Changing E-Discovery Responsibilities
A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.
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Preserving Refunds As Tariffs Await Supreme Court Weigh-In
In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.
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Revamped Opportunity Zones Can Aid Clean Energy Projects
The Qualified Opportunity Zone program, introduced in 2017 and reshaped in the One Big Beautiful Bill Act, offers investors federal tax incentives for development in low-income communities — incentives that are especially meaningful for clean energy projects, where capital-intensive infrastructure and long-term planning are essential, say attorneys at Dentons.
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Writing Musicals Makes Me A Better Lawyer
My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.
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How Fashion, Tech Can Maximize New Small Biz Tax Breaks
Fashion and technology companies, which invest heavily in innovation, should consider taking advantage of provisions in the One Big Beautiful Bill Act that favor small businesses, restructuing if necessary to become eligible for expanded research and experimental expenditure credits and qualified small business stock incentives, says Aime Salazar at Olshan Frome.