Federal
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September 03, 2025
Tax Court Must Reconsider Medtronic Pricing, 8th Circ. Says
The U.S. Tax Court should reconsider its use of a hybrid approach for pricing intangibles that Medtronic licensed to a Puerto Rican affiliate, the Eighth Circuit said Wednesday, vacating the ruling and directing the court to revisit the IRS' pricing method.
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September 02, 2025
11th Circ. Affirms Slashing Ex-Braves' $47M Easement Break
A $47 million conservation easement deduction for a partnership founded by two former Atlanta Braves players was overvalued, the Eleventh Circuit affirmed Tuesday, saying none of the partnership's arguments undermined the U.S. Tax Court's finding that the easement property was worth far less than it claimed.
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September 02, 2025
Jury Misled On Tax Fraud Conspiracy Charge, 10th Circ. Rules
The Tenth Circuit overturned Tuesday a conviction against a man who did not report trust income on his personal tax returns, saying the New Mexico district court erred in presenting instructions on the conspiracy charges to both the jury and defendant's counsel.
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September 02, 2025
Firm Urges 2nd Circ. To Review $142M Earnings Boost
A New York investment company has asked the Second Circuit to review a U.S. Tax Court ruling that sustained a $142 million increase to its net earnings and found its principals did not qualify as limited partners for an exception from self-employment income tax.
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September 02, 2025
Most Employers Paid Taxes After COVID Delay, Report Says
Most employers who put off paying Social Security taxes during the pandemic have paid their bills, the Treasury Inspector General for Tax Administration said Tuesday, although some employers who didn't pay were incorrectly charged penalties by the IRS.
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September 02, 2025
IRS Withdraws Rule On Tax Data Use In Passport Revocations
The IRS will scrap a 2018 proposed rule that would have allowed the U.S. State Department to share taxpayer return information with contractors that assist in the revocation or denial of passports of individuals with serious tax debts, the agency announced Monday, calling the rule unnecessary.
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September 02, 2025
Colgate-Palmolive To Shell Out $332M In Pension Payout Fight
Colgate-Palmolive retirees asked a New York federal judge to greenlight a $332 million class action deal in their suit claiming the household products company shorted them on lump-sum retirement payouts, signaling the end of a nearly decade-old case that reached the Second Circuit in 2023.
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August 29, 2025
Split Fed. Circ. Backs Limits On Presidential Tariff Powers
The Federal Circuit held that President Donald Trump's emergency tariffs were improperly imposed under the International Emergency Economic Powers Act, which it said makes no mention of "tariff," "duties" or "tax."
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August 29, 2025
Bookie Who Took Bets From Ohtani Interpreter Gets 1 Year
A resident of Orange County, California, was sentenced to a year and a day in prison on Friday after pleading guilty to operating as an unlicensed bookmaker who placed bets for current and former professional athletes as well as a Japanese language interpreter who is serving time for stealing from baseball megastar Shohei Ohtani.
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August 29, 2025
House Dems Reintroduce Marijuana Legalization Bill Again
Democrats in the U.S. House of Representatives once again reintroduced a federal marijuana legalization bill that previously passed the chamber twice when it was under Democratic control, but has never gained traction in the U.S. Senate or under a majority-Republican House.
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August 29, 2025
Federal Tax Policy To Watch In The Rest Of 2025
As Congress returns to Washington, D.C., after the August recess, the bulk of federal tax policy is expected to focus on funding the IRS past Sept. 30 and getting out guidance for retroactive deductions included in this summer's budget reconciliation bill. Here's a look at federal tax policy to watch during the rest of the year.
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August 29, 2025
Apple Must Hand Swiss User's Records To IRS, Judge Rules
Apple must provide the Internal Revenue Service with a Swiss user's internet and phone records as part of a criminal investigation by Switzerland's taxing authority, a California federal judge ruled, despite the man's protests that the records are unrelated to taxes.
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August 29, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the removal of a method for large-scale clean energy projects to establish eligible construction start dates in order to claim solar and wind tax credits.
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August 29, 2025
Taxation With Representation: White & Case, Paul Weiss
In this week's Taxation With Representation, private equity firm Sycamore Partners completes its $24 billion acquisition of Walgreens Boots Alliance Inc., telecommunications company EchoStar sells wireless spectrum licenses to AT&T and Keurig Dr Pepper acquires JDE Peet's in a deal that aims to create a "global coffee champion."
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August 28, 2025
Coke Says IRS Taking 'Extreme' Position In $2.7B Dispute
The IRS is taking an "extreme" position in its defense of a $2.7 billion tax ruling against Coca-Cola by asserting that the standard prohibiting arbitrary and capricious actions by an agency doesn't apply to it, the company told the Eleventh Circuit.
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August 28, 2025
6th Circ. Affirms Dismissal Of Meritless Tax Challenge
The Sixth Circuit affirmed the dismissal of a Tennessee man's suit against the Internal Revenue Service, ruling Wednesday that his challenge to the agency's tax collections was meritless and provided no basis for federal jurisdiction.
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August 28, 2025
Illinois Atty Gets 2½ Years For Tax Fraud, Scripting Testimony
A former Chicago attorney who covered up $1 million in payments to his romantic interest and tried scripting his bookkeeper's initial trial testimony has been sentenced to two and a half years in prison, federal prosecutors announced Thursday.
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August 28, 2025
IRS Provides Guidance On Renewed R&D Tax Break
The Internal Revenue Service released instructions Thursday on how to make various elections, file amended tax returns and change accounting methods for the renewed tax break for research and development costs passed under the budget reconciliation bill.
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August 28, 2025
Compliance Atty Who Duped Lender Wants New Trial
A compliance lawyer convicted of pilfering from a $20 million line of credit that a subsidiary of Emigrant Bank extended to his tax-lien business has asked a Manhattan federal judge to order a new trial, arguing that prosecutors' evidence is insufficient and that the charges were "multiplicitous," in violation of the Fifth Amendment.
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August 27, 2025
Co. Can't Challenge IRS Easement Penalties, Court Rules
The Internal Revenue Service can assess civil penalties against a property company for a disallowed conservation easement deduction, a Louisiana federal court said, agreeing with the government that the company's challenge is barred under the Anti-Injunction Act.
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August 27, 2025
Retired Air Force Officer Faces IRS Levy Over Unpaid Taxes
The Internal Revenue Service properly upheld a tax levy against a retired U.S. Air Force officer who didn't report a $245,000 military retirement distribution, the U.S. Tax Court ruled Wednesday, saying the man didn't show he couldn't afford to pay his bill.
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August 27, 2025
Church Leaders Charged In Forced Labor, Laundering Scheme
Two self-proclaimed religious leaders forced people to work in call centers to raise millions of dollars that the pair spent on jet skis and other luxuries in a money laundering scheme investigated by the IRS, according to an indictment unsealed Wednesday in Michigan federal court.
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August 27, 2025
US Tax Compliance To Cost $536 Billion In 2025, Report Says
U.S. taxpayers will spend about $536 billion this year complying with the tax code, largely in what economists call opportunity costs, an amount greater than federal revenues from corporate income tax, the Tax Foundation reported Wednesday.
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August 27, 2025
Baker Botts Adds 2 More Lateral Partners In NY
As it touts the addition of 17 lateral partners this year so far, Baker Botts LLP announced Tuesday that it has gained a former Paul Weiss Rifkind Wharton & Garrison LLP attorney focused on executive compensation and transactional tax strategy and a former McDermott Will & Schulte LLP attorney focused on public company and private equity mergers and acquisitions.
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August 26, 2025
Joseph Nocella Jr. Appointed US Attorney For EDNY
Joseph Nocella Jr. on Tuesday was reportedly appointed as the U.S. attorney for the Eastern District of New York, having served as the district's interim top prosecutor since early May.
Expert Analysis
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The Legal Education Status Quo Is No Longer Tenable
As underscored by the fallout from California’s February bar exam, legal education and licensure are tethered to outdated systems, and the industry must implement several key reforms to remain relevant and responsive to 21st century legal needs, says Matthew Nehmer at The Colleges of Law.
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6 Questions We Should Ask About The Trump Trade Deals
Whenever the text becomes available, certain questions will help determine whether the Trump administration’s trade deals with U.S. trading partners have been crafted to form durable economic relationships, or ephemeral ties likely to break upon interpretive disagreement or a change in political will, says Ted Posner at Baker Botts.
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E-Discovery Quarterly: Rulings On Relevance Redactions
In recent cases addressing redactions that parties sought to apply based on the relevance of information — as opposed to considerations of privilege — courts have generally limited a party’s ability to withhold nonresponsive or irrelevant material, providing a few lessons for discovery strategy, say attorneys at Sidley.
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Section 1983 Has Promise After End Of Nationwide Injunctions
After the U.S. Supreme Court recently struck down the practice of nationwide injunctions in Trump v. Casa, Section 1983 civil rights suits can provide a better pathway to hold the government accountable — but this will require reforms to qualified immunity, says Marc Levin at the Council on Criminal Justice.
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Playing Soccer Makes Me A Better Lawyer
Soccer has become a key contributor to how I approach my work, and the lessons I’ve learned on the pitch about leadership, adaptability, resilience and communication make me better at what I do every day in my legal career, says Whitney O’Byrne at MoFo.
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Lessons On Parallel Settlements From Vanguard Class Action
A Pennsylvania federal judge’s unexpected denial of a proposed $40 million settlement of an investor class action against Vanguard highlights key factors parties should consider when settlement involves both regulators and civil plaintiffs, say attorneys at Ropes & Gray.
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Adapting To Private Practice: From ATF Director To BigLaw
As a two-time boomerang partner, returning to BigLaw after stints as a U.S. attorney and the director of the Bureau of Alcohol, Tobacco, Firearms and Explosives, people ask me how I know when to move on, but there’s no single answer — just clearly set your priorities, says Steven Dettelbach at BakerHostetler.
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Mulling Worker Reclassification In Light Of No Tax On OT
The One Big Beautiful Bill Act's no-tax-on-overtime provisions provide tax relief for employees who regularly work overtime and are nonexempt from the Fair Labor Standards Act, but reclassifying employees may lead to higher compliance costs and increased wage and hour litigation for employers, says Steve Bronars at Edgeworth Economics.
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Clean Energy Tax Changes Cut Timelines, Add Red Tape
With its dramatic changes to energy tax credits, the One Big Beautiful Bill Act will reshape project financing and investment planning — and wind and solar developers, especially those in the early stages of projects, face stricter timelines and heightened compliance challenges, says Dan Ruth at Balch & Bingham.
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Playing Baseball Makes Me A Better Lawyer
Playing baseball in college, and now Wiffle ball in a local league, has taught me that teamwork, mental endurance and emotional intelligence are not only important to success in the sport, but also to success as a trial attorney, says Kevan Dorsey at Swift Currie.
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Reform Partly Modernizes Small Biz Stock Gains Exclusion
Changes to the Internal Revenue Code in the One Big Beautiful Bill Act update the qualified small business stock gains exclusion to reflect inflation, but the regime would be more in line with current business realities if Congress had also made the exemption available to additional business structures, says Mark Parthemer at Glenmede.
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How Real Estate Funds Can Leverage Del. Statutory Trusts
Over the last two years, traditional real estate fund sponsors have begun to more frequently adopt Delaware Statutory Trust programs, which can help diversify capital-raising strategies and access to new sources of capital, among other benefits, say attorneys at Polsinelli.
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DOJ Crypto Enforcement Is Shifting To Target Willfulness
Three pending criminal prosecutions could be an indication of how the U.S. Department of Justice's recent digital assets memo is shaping enforcement of the area, and show a growing focus on executives who knowingly allow their platforms to be used for criminal conduct involving sanctions offenses, say attorneys at Gibson Dunn.