Federal
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October 01, 2025
Tax Court Backs IRS' Rejection Of Excise Tax Debt Settlement
The Internal Revenue Service was justified in rejecting an inspection company's bid to settle $9 million worth of unpaid excise taxes related to the company's failure to meet minimum funding standards for its employee pension plan, the U.S. Tax Court said Wednesday.
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October 01, 2025
Senate Panel Urged To Update Tax Code For Digital Assets
Congress needs to create tax rules for digital assets such as cryptocurrency and nonfungible tokens because the current regime creates uncertainty for taxpayers, digital asset stakeholders told the Senate Finance Committee on Wednesday.
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October 01, 2025
IRS Appeals Launches Post-Review Mediation Pilot Program
The IRS Office of Appeals launched a two-year mediation pilot program that reassigns cases to new teams after going through the administrative review to give taxpayers a faster and more independent process to resolve disputes before they pursue litigation, the agency announced Wednesday.
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October 01, 2025
States, Businesses Push Justices To Extend Tariff Arguments
The dozen states, several small businesses and Illinois toymakers that challenged President Donald Trump's emergency tariffs filed a joint motion Wednesday requesting more time to better represent their different claims for oral arguments at the U.S. Supreme Court in November.
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October 01, 2025
11th Circ. Denies Fla. Biz Owner's $2M Tax Challenge
The owner of a Florida marketing business is on the hook for more than $2 million in taxes and penalties after the Eleventh Circuit found that he filed his notice of appeal too late.
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October 01, 2025
Groups Seek Block On Use Of IRS, SSA Data For Deportations
A coalition of immigrant advocacy groups has asked a Massachusetts federal judge to block the government from the "unfettered" use of Internal Revenue Service and Social Security Administration data to identify and target millions of people for deportation.
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October 01, 2025
Caplin & Drysdale Adds Longtime IRS Pro To DC Office
Caplin & Drysdale has grown its Washington, D.C., office with the addition of a veteran Internal Revenue Service attorney, the firm announced Wednesday.
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October 01, 2025
IRS Sets March Deadline For Research Credit Form Comments
The Internal Revenue Service said Wednesday that the public has until the end of March to submit feedback on the draft form for reporting the research tax credit, saying the feedback deadline extension would give businesses more time to meet the incentive's requirements.
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October 01, 2025
IRS Final Property Capitalization Rule Allows More Deductions
Taxpayers will be able to deduct more interest rather than having to capitalize it when making improvements to property under final regulations released Wednesday by the Internal Revenue Service.
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October 01, 2025
8th Circ. Reverses IRS Win In 3M Transfer Pricing Case
The Eighth Circuit reversed a U.S. Tax Court ruling Wednesday that backed the Internal Revenue Service's decision to reallocate nearly $24 million of 3M Co.'s Brazilian income, holding that the transfer pricing regulations underlying the adjustment are invalid.
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September 30, 2025
IRS To Rework Corporate AMT Proposed Regs
The Internal Revenue Service plans to revise proposed regulations for the corporate alternative minimum tax, the agency announced Tuesday, including rules that would lessen businesses' compliance demands and costs tied to assessing their liability.
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September 30, 2025
ACA Tax Credit Impasse Pushes Gov't Into Shutdown
The federal government shut down Tuesday night after congressional lawmakers failed to reach an agreement with the White House on a short-term government funding bill that would also extend the enhanced tax credits for the Affordable Care Act that expire at the end of December.
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September 30, 2025
Justices Could Enable IEEPA Taxes On Any Trade, Experts Say
If the U.S. Supreme Court decides that a president's power to regulate imports and exports under the International Emergency Economic Powers Act encompasses tariffs, a president could tax services, investments and intellectual property flowing into or out of the country, trade experts said Tuesday.
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September 30, 2025
Tax Court Asked To Revive $27M Break For Historic Building
A Pennsylvania partnership is entitled to a nearly $27 million tax deduction for donating a historic preservation easement over property in Philadelphia, the partnership told the U.S. Tax Court in a challenge to the IRS' denial of the tax break.
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September 30, 2025
IRS Further Delays Deadlines For Victims Of Israel-Hamas War
The Internal Revenue Service further postponed already-delayed tax return and payment deadlines that were set for Tuesday for those impacted by the Israel-Hamas war from 2023 through 2025, the agency said.
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September 30, 2025
IRS Penalty Case Tossed For Now Over Shifting Legal Claims
A woman's shifting legal theories doomed her challenge to IRS penalties related to her delayed disclosure of a foreign inheritance, a California federal judge found, tossing the suit but allowing her to amend her complaint.
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September 30, 2025
IRS Defines Rural Areas For Opportunity Zone Tax Breaks
The Internal Revenue Service published the definitions Tuesday for rural areas that qualify for the federal opportunity zone program's rural zone expansion under the Republican budget bill signed into law this summer.
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September 30, 2025
Altria Loses Out On $38M Refund On Foreign Subsidiaries
Tobacco products maker Altria is not entitled to a $38 million tax refund on foreign subsidiaries, a Virginia federal court found, saying the company was an indirect shareholder through its interest in Anheuser-Busch and therefore owes taxes on its portion of the subsidiaries' income.
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September 30, 2025
IRS Proposed Installment Sales Regs Suit Is Early, Judge Says
A capital assets dealer's challenge to proposed Internal Revenue Service rules on monetized installment sales cannot stand, an Idaho federal judge found in dismissing the suit, saying the court cannot adjudicate on administrative law regulations that are not yet final.
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September 30, 2025
Trump Orders Lumber, Furniture Tariffs To Begin Oct. 14
In an executive order signed Monday evening, President Donald Trump outlined a series of tariff rates on imported lumber and derivative products to be imposed in two weeks.
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September 29, 2025
Diamond Mogul's Daughter Escapes Tax Claims In $41M Deal
The U.S. government agreed to stop pursuing the adult daughter of a diamond mogul to recover millions in tax liabilities from his estate after reaching an agreement in which the government will receive an additional payment of $41 million, according to a New York federal court order Monday.
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September 29, 2025
IRS Finalizes Income Rules For Housing Tax Credit Projects
The U.S. Department of the Treasury and Internal Revenue Service published finalized rules for housing tax credit developers opting to use an average-income test to set rents for affordable housing projects, aiming to reduce the risk of disqualification if a unit falls out of compliance.
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September 29, 2025
IRS Would Continue Operations Under Shutdown Plan
The Internal Revenue Service will use funds it received under former President Joe Biden to continue operations if Congress can't reach an agreement to avoid a federal government shutdown, under a contingency plan released Monday.
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September 29, 2025
Tribal Members Push For Say In Supreme Court Tariff Review
Members of the Blackfeet Nation tribe told the U.S. Supreme Court Monday their inclusion in the justices' review of suits challenging the legality of President Donald Trump's emergency tariffs is crucial to protect Native American rights under federal law.
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September 29, 2025
Solar Plant Justified $45M Easement Break, Tax Court Told
A partnership is entitled to a roughly $45 million tax deduction for donating a conservation easement that protected hundreds of acres in Texas from potentially being used to host a solar power plant, the partnership told the U.S. Tax Court.
Expert Analysis
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How Attys Can Use A Therapy Model To Help Triggered Clients
Attorneys can lean on key principles from a psychotherapeutic paradigm known as the "Internal Family Systems" model to help manage triggered clients and get settlement negotiations back on track, says Jennifer Gibbs at Zelle.
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3 Steps For In-House Counsel To Assess Litigation Claims
Before a potential economic downturn, in-house attorneys should investigate whether their company is sitting on hidden litigation claims that could unlock large recoveries to help the business withstand tough times, says Will Burgess at Hilgers Graben.
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IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement
Tax crimes are historically difficult to prosecute, but the Internal Revenue Services’ recent agreement with U.S. Immigration and Customs Enforcement to share taxpayer records of non-U.S. citizens could be used to enhance payroll tax-related enforcement against their employers, say attorneys at Holland & Knight.
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Adapting To Private Practice: From DOJ Enviro To Mid-Law
Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares their principles, values their experience and will invest in their transition, says John Cruden at Beveridge & Diamond.
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Legal Ethics Considerations For Law Firm Pro Bono Deals
If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.
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10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks
The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.
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Notable Q1 Updates In Insurance Class Actions
The first quarter of 2025 was filled with the refinement of old theories in the property and casualty space, including in vehicle valuation, time to seek appraisal and materials depreciation, says Mathew Drocton at BakerHostetler.
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Power To The Paralegals: The Value Of Unified State Licensing
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.
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10 Soft Skills Every GC Should Master
As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.
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An Unrestrained, Bright-Eyed View Of Legal AI's Future
Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.
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Tracking The Evolution In Litigation Finance
Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.
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E-Discovery Quarterly: The Perils Of Digital Data Protocols
Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.
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Maximizing Exemptions Before TCJA Rides Into The Sunset
Excerpt from Practical Guidance
Individuals with taxable estates can optimize the benefits of estate planning strategies like spousal lifetime access trusts by setting them up before increases in estate and gift tax exemptions under the 2017 Tax Cuts and Jobs Act sunset in January, say attorneys at Katten.