Federal
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November 04, 2025
Developer Seeks To Restore Nixed $29M Easement Deduction
The Internal Revenue Service failed to explain its rejection of a $29 million charitable tax deduction claim for an Alabama-based developer's 2016 conservation easement donation to a regional water district, the developer told the U.S. Tax Court as it challenged the decision.
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November 04, 2025
Tax Court Affirms Rejection Of Co.'s Settlement Offer
The Internal Revenue Service did not abuse its discretion in rejecting an offer from a small business to settle its tax debt, the U.S. Tax Court said Tuesday, finding that the company never submitted financial documents the agency needed to accept the deal.
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November 04, 2025
Shutdown Leaves Tax Pros Few Options To Find Clients Relief
The IRS has been beset by worsening delays in addressing taxpayers' cases, driven by widespread furloughs and a wave of retirements, and the ongoing government shutdown has compounded the issue by bringing federal district courts to a halt, leaving tax practitioners few options to seek relief for clients.
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November 04, 2025
DC Circ. Skeptical Of IRS Data Leaker's Qualms About Judge
The D.C. Circuit seemed unlikely Tuesday to grant a request for resentencing by an IRS contractor serving prison time for leaking the tax returns of President Donald Trump and others to the media, suggesting his judge did nothing wrong in giving him the maximum term.
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November 03, 2025
Eaton Debt Analysis Must Trace Distinct Steps, Tax Court Told
An attorney for Eaton Corp. told the U.S. Tax Court on Monday that the interest rates and guarantee fees the company paid to its newly formed Irish parent in 2012 must be analyzed as a set of distinct steps, beginning with determining a standalone credit rating for the U.S. company — an analysis a government attorney said was "needlessly elaborate."
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November 03, 2025
4 Ways Justices' Jarkesy Ruling Could Affect Tax Controversy
As lower courts have begun to weigh the U.S. Supreme Court’s 2024 ruling that the SEC’s imposition of civil penalties without a jury trial was unconstitutional, attorneys say the decision could reshape tax disputes and potentially force the IRS to reconsider its approach to enforcement. Here, Law360 examines potential ways the Jarkesy precedent could influence tax controversy.
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November 03, 2025
'No Basis In Reality' In $10M Easement Claim, Tax Court Says
A U.S. Tax Court judge rejected a partnership's claim that its donation of a conservation easement over 200 acres in Georgia was worth a $10 million tax deduction, saying in an opinion Monday that it "has no basis in reality."
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November 03, 2025
2 Doctrines Likely To Direct Justices' Review Of Trump Tariffs
When the U.S. Supreme Court hears oral arguments Wednesday over whether President Donald Trump can impose tariffs under the International Emergency Economic Powers Act, it will likely test two doctrines the justices have recently considered: the major questions and nondelegation doctrines.
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November 03, 2025
Tribes Push Supreme Court To Overturn Okla. Tax Ruling
The Oklahoma Supreme Court incorrectly ruled that a member of the Muscogee Creek Nation owes Oklahoma income tax, groups representing Native American tribes told the U.S. Supreme Court, asking the justices to hear the case and reverse the ruling.
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November 03, 2025
Veteran Tax Controversy Atty Moves Team To Kostelanetz
A longtime New Jersey tax attorney and three of his associates have joined Kostelanetz LLP, the boutique tax firm announced Monday, saying it expected them to bolster its tax controversy practice and add to its commitment to volunteer work and legal education.
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October 31, 2025
Int'l Tax In October: Deal With China, Halt To Canada Talks
A tentative deal to reduce American tariffs on Chinese goods, ruptured trade talks between the U.S. and Canada, court defeats for the Danish and U.S. tax administrations and an end to the European Union's plan for a financial transaction tax topped the list of international tax news in October. Here, Law360 looks at the biggest developments from the past month.
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October 31, 2025
Twin Peaks Lender Says Developer Defaulted On $12M Loan
A Florida franchisee group is suing a developer in state court over a $12 million loan to build two Twin Peaks restaurants in an EB-5 visa program, alleging the developer defaulted on the note and then told the IRS that it converted the loan into equity interest.
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October 31, 2025
Up Next At High Court: Tariffs, Fugitives & Contractor Liability
The U.S. Supreme Court will begin its November oral argument session Monday, during which the justices will consider President Donald Trump's authority to impose tariffs on foreign countries under an emergency statute, whether military contractors can be held liable for alleged breaches of contracts in war zones, and if there are time limits for litigants who want to vacate a void judgment. Here, Law360 breaks down the week's oral arguments.
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October 31, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the continued monthslong slide in applicable federal rates for income tax purposes.
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October 31, 2025
Taxation With Representation: Skadden, Davis Polk
In this week's Taxation With Representation, American Water Works Co. and Essential Utilities announce a merger, semiconductor companies Skyworks and Qorvo combine to create an industry giant, and Terex Corp. and REV Group team up to form a specialty equipment manufacturer.
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October 31, 2025
Ruling Dispute In Limbo As 6th Circ. Rebuffs Shutdown Pause
The Sixth Circuit denied a federal government attorney's request to pause a closely watched case about a U.S. Tax Court filing deadline after he told the court he was barred from working during the shutdown, leaving his plan to request a rehearing in limbo.
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October 30, 2025
Trade Deals At Risk In Trump Tariff Case, Feds Tell Justices
The federal government told the U.S. Supreme Court on Thursday that President Donald Trump's global tariffs have led to significant trade deals addressing the underlying national emergencies he declared, and a ruling determining them unlawful would prove catastrophic.
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October 30, 2025
China Delays Expanded Mineral Export Controls, Trump Says
China has agreed to delay for a year an expansion to export controls for key minerals and is set to start purchasing more U.S. agricultural products including soybeans, while U.S. tariffs on Chinese goods will decrease 10%, President Donald Trump said early Thursday morning.
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October 30, 2025
Kansas Doctor Loses Collection Dispute In Tax Court
The U.S. Tax Court upheld Thursday an Internal Revenue Service action to collect nearly $730,000 from a Kansas-based doctor with years of unpaid taxes, finding that her silence on the agency's judgment request prompted the decision.
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October 30, 2025
Senate Votes To Ax Global Tariffs, But House Path Blocked
The Senate passed legislation Thursday to end the declared national emergency propping up President Donald Trump's global tariff regime shortly after passing similar bills regarding tariffs on Canada and Brazil, though the House previously moved its deadline for action on the matter to next year.
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October 30, 2025
IRS Discloses Record In ICE Data Sharing Case
The IRS, following a judge's order, has released its administrative record in a lawsuit over its agreement to share taxpayer information with federal immigration authorities, including emails in which officials discuss U.S. Immigration and Customs Enforcement's request for information on nearly 1.3 million taxpayers.
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October 30, 2025
Pa. Couple Ordered To Pay $1.77M IRS Debt
A Pennsylvania couple who purchased a Maserati and a Porsche and took trips to international destinations while owing the Internal Revenue Service $1.77 million must pay those tax debts, a Pennsylvania federal judge ruled Thursday, adopting a magistrate judge's report.
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October 30, 2025
Sidley's 'Incomplete' Story Hid Fraud Scheme, Family Says
A family alleging it was roped into an illegal tax sheltering scheme on the advice of a former Sidley Austin LLP attorney has urged a Georgia federal judge to keep its suit against the firm alive, arguing a jury should decide when the family knew enough about the fraud to move forward with its claims.
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October 30, 2025
3rd Circ. Affirms Tax On Interest In $191M Pharma Family Feud
A pharmaceutical company's $191 million payment settling a family feud was for the sale of a family trust's ownership shares and included interest taxed as ordinary income, the Third Circuit said Thursday, rejecting the trust's claim that the money should be taxed at the lower, capital gains rate.
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October 29, 2025
Tax Atty Group Backs Fund Manager's $1.9M Refund Bid
A tax attorneys professional association told the Eleventh Circuit that a Florida district court improperly blocked a fund manager and his wife's appeal to receive a $1.9 million tax refund under a rule that bars taxpayers from making new claims in federal court.
Expert Analysis
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Parenting Skills That Can Help Lawyers Thrive Professionally
As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.
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Unpacking The New Opportunity Zone Tax Incentive Program
The One Big Beautiful Bill Act brought several improvements to the opportunity zone tax incentive program that should boost investments in qualified funds, including making it permanent, increasing federal income tax benefits in rural areas, redesignating the qualified zones, and requiring more in-depth reporting, says Marc Schultz at Snell & Wilmer.
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Trump Tax Law's Most Impactful Energy Changes
The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.
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Adapting To Private Practice: From Texas AUSA To BigLaw
As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.
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Advice For 1st-Gen Lawyers Entering The Legal Profession
Nikki Hurtado at The Ferraro Law Firm tells her story of being a first-generation lawyer and how others who begin their professional journeys without the benefit of playbooks handed down by relatives can turn this disadvantage into their greatest strength.
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UK's 1st ICSID Claim Shows Bilateral Investment Treaty Reach
For the first time, the U.K. is facing a claim under the International Centre for Settlement of Investment Disputes Convention, underscoring the broader reality that treaty protections are no longer confined to investors in emerging markets, says Philipp Kurek at Signature Litigation.
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Trump Tax Law's Most Impactful Corp. And Individual Changes
The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.
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From Clerkship To Law Firm: 5 Transition Tips For Associates
Excerpt from Practical Guidance
Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.
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Trump Tax Law's Most Consequential International Changes
The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.
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Associates Can Earn Credibility By Investing In Relationships
As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.
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Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling
The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.
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What 2 Profs Noticed As Transactional Law Students Used AI
After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.
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BigLaw Settlements Should Not Spur Ethics Deregulation
A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.