Federal
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August 08, 2025
Taxation With Representation: Latham, Alston & Bird, Orrick
In this week's Taxation With Representation, fiber optic connector systems maker Amphenol Corp. buys CommScope's connectivity and cable solutions business, Blackstone acquires Enverus from private equity firms, investors buy a majority stake in medical device company HistoSonics Inc., and ESPN swaps an equity stake for the National Football League's NFL Network and other intellectual property.
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August 08, 2025
Pennsylvania Litigation Highlights Of The 1st Half Of 2025
In the first half of 2025, Pennsylvania judges have created a federal and state court split in a $175 million verdict against Monsanto in Philadelphia's Roundup mass tort, reduced the tax fraud sentence of a member of the family behind an iconic Philadelphia cheesesteak shop and permanently barred a college apparel company from copying Penn State trademarks.
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August 07, 2025
2nd Circ. Says Trial Atty With Brain Disease Not 'Ineffective'
The Second Circuit on Thursday affirmed the convictions of a former New York City law enforcement union president along with its ex-financial adviser for defrauding members out of $500,000, rejecting among contentions that one defense lawyer's abilities were impaired at trial by a fast-moving neurodegenerative disease.
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August 08, 2025
Midyear Review: A Look At The Tax Trends Shaping 2025
Tax professionals had a lot to keep up with in the first half of 2025, from congressional action to extend the 2017 GOP tax overhaul to a tumultuous international trade scene. And the back half of the year is poised to be just as busy, with litigation over how the IRS handles employee retention tax credits, an Amazon suit in South Carolina over sales tax, and an uncertain future for global minimum tax rules. Here, dive into our slate of analysis pieces to help guide you through evolving tax litigation and policy.
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August 07, 2025
IRS Can Collect From Incarcerated Man, Tax Court Says
The IRS properly denied a request by an incarcerated man to stop collecting his nearly $160,000 tax debt, the U.S. Tax Court ruled Thursday, saying the man admitted to having hundreds of thousands of dollars in assets.
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August 07, 2025
Toyota Forecasts $9.5B Annual Hit From US Tariffs
U.S. tariffs would cost Toyota Motor Corp. 1.4 trillion yen ($9.5 billion) during its fiscal year ending March 2026, including 450 billion yen in its first quarter, the automaker said Thursday.
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August 07, 2025
Siemens Contests Nix Of $315M Foreign-Dividend Tax Break
Regulatory missteps caused the IRS to wrongly slash $315 million from a foreign-dividend tax deduction Siemens claimed on shareholder payments it received from an overseas affiliate, the medical giant told the U.S. Tax Court.
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August 07, 2025
Man Pleads Guilty To Tax Evasion, Faces $50M In Restitution
A man accused of numerous financial crimes related to his operation of promoting abusive and illegal tax shelters pled guilty to three charges across two different cases in Colorado federal court on Thursday.
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August 07, 2025
Hodgson Russ Adds Former NY Tax Pros To SALT Group
Hodgson Russ LLP has announced that two former New York state and city tax professionals have joined the firm's state and local tax practice in New York City, advising the team on complex regional tax issues.
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August 07, 2025
No Changes To Tax Forms Yet After Budget Bill, IRS Says
Withholding tables and information returns for the current tax year as related to the federal budget bill will remain unchanged, the Internal Revenue Service announced Thursday, saying it wants to avoid disruptions to tax filing season.
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August 07, 2025
Trump Greenlights Private Equity, Crypto 401(k) Investing
President Donald Trump signed an executive order Thursday that aims to make it easier for retirement plans to invest in a wider range of assets, including cryptocurrency, private equity and real estate.
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August 07, 2025
Vanguard, Investors Agree To Settle After Axed $40M Tax Deal
Vanguard and investors have reached a second deal in a suit over allegations of surprise tax bills from a fund restructuring after a Pennsylvania federal judge scrapped a previous settlement in which the class would have fetched $40 million, the parties said Thursday.
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August 07, 2025
Fed. Circ. Skeptical Of Realty Co.'s IRS Contract Dispute
Federal Circuit judges seemed skeptical Thursday of a realty company's claim that the IRS improperly blocked its bid to continue leasing office space to the agency after IRS employees complained about the building, with one judge challenging whether evidence actually showed the agency acted in bad faith.
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August 07, 2025
German Carmakers Press EU To Secure Tariff Relief Quickly
A German automaker association urged the European Union to finalize its trade deal with the U.S. to relieve the car manufacturing industry of the pressure of tariffs.
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August 06, 2025
Under Pressure, Higher Ed Leans On Real Estate
As institutions of higher education contend with declining enrollment and federal funding cuts, some are finding creative ways to monetize their real estate, which comes with important legal considerations, according to attorneys.
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August 06, 2025
Ex-Homeowners Seek OK On Tax Foreclosure Suit Deal
A proposed class of former property owners asked a Michigan federal judge Tuesday to give initial support to a settlement with several counties that would allow the ex-homeowners to receive the surplus profits they allege the county treasurers made selling their tax-delinquent properties.
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August 06, 2025
No IRS Error In Lien Against Lawyer, Tax Court Says
The IRS' appeals office did nothing wrong in sustaining a tax lien against an attorney who asked for other ways of paying what the agency said was her $43,000 tax debt, the U.S. Tax Court ruled Wednesday, saying the lawyer was offered lower payment options.
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August 06, 2025
Troutman Adds Former Fannie Mae Associate GC In DC
The former associate general counsel at the Federal National Mortgage Association, who spent the past decade as a tax partner with Morris Manning & Martin LLP, has joined Troutman Pepper Locke LLP in the nation's capital, the firm announced Wednesday.
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August 06, 2025
G7's Tax Carveout For US Cos. Raises EU State Aid Questions
The Group of Seven nations' deal to exclude U.S. companies from Pillar Two minimum tax rules would give those companies a competitive advantage, experts say, prompting questions about the carveout's compatibility with EU state aid rules and whether a viable path exists to challenge the deal.
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August 06, 2025
3 Key Foreign Entity Issues In Claiming Clean Energy Credits
Stricter foreign supply chain and business ownership rules were tacked onto clean energy tax credits that weren't eliminated under the new budget reconciliation law, raising major compliance hurdles that have practitioners eagerly awaiting implementation rules from the U.S. Treasury Department. Here, Law360 outlines key issues the agencies need to address in coming guidance on restrictions targeting projects linked to foreign entities of concern.
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August 06, 2025
DOJ Says $47M Fat Brands Tax Case Not A Priority
The U.S. Department of Justice quit prosecuting Fat Brands and its founder on charges of helping hide $47 million from the IRS because of guidance from DOJ leaders that emphasized other priorities, including enforcement against cartels, the department told a California federal court.
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August 05, 2025
GAO Denies Co.'s Protest Of $49M IRS Task Order
The U.S. Government Accountability Office denied a Virginia company's protest of a $49 million task order issued by the U.S. Department of the Treasury for information technology services support, saying it was not competitively prejudiced during the procurement process.
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August 05, 2025
AICPA Pushes For Guidance On Renewed R&D Tax Break
The U.S. Department of the Treasury needs to issue guidance immediately allowing taxpayers to deduct research and development costs incurred in 2024 on their originally filed federal income tax returns for that year, the American Institute of CPAs said in a letter released Tuesday.
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August 05, 2025
McGuireWoods Adds Loeb & Loeb Tax Pro In Los Angeles
McGuireWoods LLP is enhancing its corporate team, announcing Tuesday it is bringing in a Loeb & Loeb LLP tax expert as a partner in its Los Angeles office in Century City.
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August 05, 2025
Simpson Thacher Adds Tax, Funds Pro From Dechert
Simpson Thacher & Bartlett LLP announced Monday that it has continued its growth in the tax and registered funds spaces, welcoming a partner from Dechert LLP to its New York office.
Expert Analysis
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Firms Must Embrace Alternative Billing Models Or Fall Behind
As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.
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How Attorneys Can Master The Art Of On-Camera Presence
As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.
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Adapting To Private Practice: From Fed. Prosecutor To BigLaw
Making the jump from government to private practice is no small feat, but, based on my experience transitioning to a business-driven environment after 15 years as an assistant U.S. attorney, it can be incredibly rewarding and help you become a more versatile lawyer, says Michael Beckwith at Dickinson Wright.
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Justices' False Statement Ruling Curbs Half-Truth Liability
The U.S. Supreme Court’s recent Thompson v. U.S. decision clarified that a federal statute used to prosecute false statements made to bank regulators only criminalizes outright falsehoods, narrowing prosecutors’ reach and providing defense counsel a stronger basis to challenge indictments of merely misleading statements, says Tamara de Silva at De Silva Law Offices.
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Perfecting Security Interests In Renewable Energy Tax Credits
The ability to transfer renewable energy tax credits has created new opportunities for developers, investors and lenders, but it also raises important questions regarding when and how the security interests in these credits are perfected — questions that must be answered definitively to protect credit claims and transactions, says Harry Teichman at Stinson.
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Firms Still Have Lateral Market Advantage, But Risks Persist
Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
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Making The Opportunity Zones Program Great At Last
As the opportunity zone program approaches its expiration, the Republican-led government could take specific steps to extend and improve the program, address its structural flaws, encourage broader participation and enable it to live up to its promised outcomes, say attorneys at Pillsbury.
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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.