Federal
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June 09, 2025
States Warned Of Budget Bill's Push To Broaden PL 86-272
States and businesses should closely watch a provision in the budget reconciliation bill H.R. 1, or the One Big Beautiful Bill Act, that would expand the protections of a federal law that provides limited state income tax provisions for businesses, state tax professionals said Monday.
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June 09, 2025
Tax Court Backs Penalties In $24M Georgia Easement Feud
An Internal Revenue Service agent properly followed the procedure to secure timely supervisory approval to impose penalties against a partnership for incorrectly claiming a $24 million charitable tax deduction on its Georgia conservation easement donation, the U.S. Tax Court said Monday.
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June 09, 2025
CEOs Back Trump's Tax-Deferred Child Investment Accounts
The CEOs of several large corporations, including Dell Technologies, Uber and Goldman Sachs, pledged to contribute millions of dollars to tax-advantaged brokerage accounts for newborns that would be established under the House-passed budget bill, President Donald Trump announced at the White House on Monday.
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June 09, 2025
Russian Postdoc's Income Not Tax Exempt, Tax Court Says
A Russian permanent resident who was a postdoctoral laboratory worker at the University of South Carolina cannot escape federal taxes on her income by claiming it was a grant and thus exempt under the U.S.-Russia tax treaty, the U.S. Tax Court said Monday.
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June 09, 2025
Madigan Denied Acquittal, New Trial Ahead Of Sentencing
An Illinois federal judge on Monday denied former Illinois House Speaker Michael Madigan's bid for acquittal or a new trial, clearing the way for him to be sentenced for bribery, wire fraud and conspiracy later this week.
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June 09, 2025
Va. Woman's Overpayment Already Refunded, Tax Court Says
The Internal Revenue Service has already fully paid back the almost $90,000 it owes a Virginia woman to satisfy an overpayment determination, the U.S. Tax Court said Monday, dismissing a motion asking the court to enforce the determination.
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June 09, 2025
Businesses Warn Fed. Circ. Against Pausing Block On Tariffs
Thousands of businesses will suffer "irreparable harm" if the Federal Circuit halts the U.S. Court of International Trade's order that struck down President Donald Trump's global tariffs, a wine importer told the appellate court, urging against a long-term pause.
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June 09, 2025
US Opposes Ex-Tech CEO's Bid For Unrestricted Travel
Granting a former Florida tech CEO's request for unrestricted business travel during his probation would violate the conditions of his early prison release after he pled guilty to tax evasion, the U.S. told a federal court, urging it to reject his bid.
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June 09, 2025
Justices Urged To Keep Pause On 'Breakneck' Gov't Overhaul
The U.S. Supreme Court should leave in place a California federal judge's order barring implementation of layoffs and reorganizations at various federal departments and agencies, several unions and nonprofits argued Monday, claiming a decision allowing the changes would irreversibly harm the federal government and render Congress and the judiciary powerless.
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June 09, 2025
Taxpayer Advocacy Panel Joint Committee Sets July Meeting
The Taxpayer Advocacy Panel's Joint Committee will meet July 24 to discuss customer service, it announced Monday.
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June 09, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin included an updated list of automatic procedures for taxpayer-initiated changes to their accounting methods.
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June 06, 2025
The Tax Angle: IRS Funding, Budget Markup, Insurance Woes
From a look at upcoming Senate hearings on President Donald Trump's funding plans for the IRS to a potential markup of Republicans' $3.8 trillion budget reconciliation bill and the continuing crisis in homeowner insurance, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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June 06, 2025
8th Circ. Rejects Farm Leasing Co.'s Switch To Amortization
The Eighth Circuit denied an Arkansas farm leasing company's action to amortize federal subsidy-eligible land to reduce its tax liability, affirming Friday that the company was not authorized to make such accounting changes without approval from the Internal Revenue Service.
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June 06, 2025
11th Circ. Limits Easement Tax Break Tied To Failed Project
A Georgia partnership that formed after the failure of a resort development and donated a conservation easement in exchange for a tax break cannot take an $8.9 million deduction for the property's fair market value because the land was considered inventory, the Eleventh Circuit said Friday.
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June 06, 2025
Facebook Ruling Casts Uncertainty On Cost-Share Disputes
The U.S. Tax Court recently rejected Facebook's challenge to regulations that determine the buy-in payment for affiliated companies to share the costs of developing intangibles, raising questions about objections to similar rules by pharmaceutical multinationals.
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June 06, 2025
Taxation With Representation: Winston, Stibbe, Weil, Goodwin
In this week's Taxation With Representation, Chart Industries Inc. and Flowserve Corp. merge, Aedifica NV and Cofinimmo NV unite, Sanofi buys Blueprint Medicines Corp., and Kimberly-Clark Corp. sells a majority stake in its international tissue business to Suzano.
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June 06, 2025
Lobbyist Seeks No Prison After Admitting $1.3M Tax Evasion
A Miami lobbyist who admitted to evading $1.3 million in taxes asked a Florida federal court not to sentence him to prison, saying he reported his tax obligations in full, even for the years when he didn't pay, and was overwhelmed by family expenses.
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June 06, 2025
PE Firms Are Top Opportunity Zone Investors, Report Finds
A group tracking private equity activity said each of the 15 largest investors in the federal opportunity zone program are private equity firms, with Salt Lake City, Utah-based Bridge Investment Holdings topping the list with $3.7 billion in opportunity zone funds.
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June 05, 2025
'Sparse' OPM Record On Mass Firings Backs Win, Unions Say
A "sparse and self-serving" record provided by the U.S. Office of Personnel Management still shows the agency unlawfully directed federal agencies to fire probationary employees en masse, so a California federal court can reach a final decision now and "unwind" those terminations, a coalition including unions and advocacy groups said Thursday.
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June 05, 2025
Texas Plastics Co. Challenges IRS Over Microcaptive Rules
A Texas plastics company sued the IRS over regulations flagging microcaptive insurance plans as potentially abusive tax avoidance schemes, telling a Texas federal court that the agency exceeded its authority by imposing broad disclosure requirements that could penalize even legitimate arrangements.
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June 05, 2025
Ex-Atty Says IRS Suit Over Property Sale Tactic Is Retaliatory
A former attorney has asked an Idaho federal court to toss the government's suit accusing him and his company of promoting an abusive tax scheme, arguing that the underlying property sale transactions were above board but the government targeted him as punishment for suing the IRS and to gain backdoor access into confidential business records.
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June 05, 2025
Tax Court Upholds IRS' Proposed Tax Levy Against Neb. Man
The Internal Revenue Service did not abuse its discretion when sustaining a proposed levy against a Nebraska man aimed at collecting unpaid assessments for the 2006 and 2007 tax years, the U.S. Tax Court said Thursday, supporting the agency's determination.
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June 05, 2025
'Longtime Tax Protester' Must Pay On $226K In Income
A Texas man characterized by the U.S. Tax Court as a "longtime tax protester" was incorrect when he claimed his more than $226,000 in wages and retirement distributions aren't taxable, a judge ruled Thursday, also hitting him with a penalty.
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June 05, 2025
Trump Expects China Trade Talks To Resume After Xi Phone Call
President Donald Trump said he and Chinese President Xi Jinping spoke over the phone Thursday about an impasse in ongoing trade talks over U.S. claims China was slow-walking the exports of rare earths, with Trump saying he expects meetings between the countries' negotiating teams to resume.
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June 05, 2025
9th Circ. Backs Denial Of Biz Owner's Bad Debt Deduction
A businessman cannot take a worthless debt deduction for millions of dollars he transferred between his companies and said were loans, the Ninth Circuit said Thursday, affirming a U.S. Tax Court ruling that he owed more than $5 million in taxes.
Expert Analysis
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What Trump's 2nd Presidency Could Mean For Crypto Sector
Trump's second term will bring a fundamental shift from the Biden administration's approach to crypto-asset regulation and banking supervision, with the most significant changes likely taking effect in the first two quarters of 2025 and broader policy shifts emerging over the next year, say attorneys at Cahill.
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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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Takeaways From The IRS' Crypto Doc Summons Win
A recent First Circuit decision holding that taxpayers do not have a Fourth Amendment reasonable expectation of privacy in cryptocurrency transaction records should prompt both taxpayers and exchanges to take stock of past transactions and future plans, say attorneys at BakerHostetler.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Ex-Chicago Politician's Case May Further Curb Fraud Theories
The U.S. Supreme Court recently agreed to hear Thompson v. U.S. to determine whether a statement that is misleading but not false still violates federal law, potentially heralding the court’s largest check yet on prosecutors’ expansive fraud theories, with significant implications for sentencing, say attorneys at the Law Offices of Alan Ellis.
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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Tariffs' Economic Downsides Outweigh Potential Revenue
Import tariffs proposed by the campaign of former president Donald Trump would generate revenue like other taxes, but policymakers must consider the net-negative impact of associated consumer and downstream-industry costs, harm to exporters, potential foreign retaliation and reduction in economic output, says Erica York at the Tax Foundation.
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Navigating The Last Leg Of The Worker Retention Tax Credit
Whether a business has applied for the pandemic-era employee retention tax credit, received a denial letter or is still considering making a claim before the April 15 deadline, it should examine recent developments significantly affecting the program before planning next steps, say attorneys at Nixon Peabody.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.