Federal
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December 23, 2025
Top Federal Tax Decisions Of 2025
Over the past year, federal courts have issued decisions that extended the deadline for challenging tax bills in the U.S. Tax Court, allowed the IRS to pursue a woman's decades-old tax debt caused by her return preparer and lifted a $1 million reporting penalty because a jury didn't sign off. Here, Law360 reviews some of the most significant federal tax decisions of 2025.
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December 23, 2025
Top International Tax Cases Of 2025
Government tax administrations came up short in some of the biggest international cases decided this year, including Denmark's challenge to a British trader it accused of deceiving the tax authority into paying thousands of improper refunds. Here, Law360 examines seven of the year's top international tax cases.
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December 23, 2025
IRS Issues Updates To Healthcare Premium Tax Credit
The IRS released updates Tuesday to the refundable premium tax credit that allows individuals to purchase health insurance from the federal government's marketplace, including the removal of a repayment cap on excess credits that were established in the Republican 2025 budget law.
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December 23, 2025
IRS Issues FAQs For Interest Expense Deduction Limits
The Internal Revenue Service issued answers Tuesday to a set of frequently asked questions related to interest expense deduction calculations that were changed under the budget reconciliation law.
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December 23, 2025
11th Circ. Rejects Woman's Legal Fees In Tax Case Win
A Florida woman cannot recoup around $6,000 in attorney fees as part of her win in a U.S. Tax Court deficiency action despite paying her husband's legal practice to help with the case, the Eleventh Circuit found, affirming the Tax Court's ruling.
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December 22, 2025
10th Circ. Tosses Plumbing Co.'s Captive Deduction Bid
The Tenth Circuit is not the proper forum for a Utah plumbing company to challenge the Internal Revenue Service's 2016 notice denying a microcaptive insurance deduction, the appeals court found Monday, citing two statutes that bar the company's arguments.
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December 22, 2025
6th Circ. Vacates Pharma Salesman's $6.8M Restitution Order
The Sixth Circuit vacated a nearly $7 million restitution order against a pharmaceutical salesman convicted of healthcare fraud, finding an Ohio federal court erred in calculating that amount and apportioning liability.
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December 22, 2025
Draft House Bill Would Clarify Tax Rules For Digital Assets
A bipartisan draft bill in the U.S. House would modernize the federal tax code for digital assets, its backers said, by establishing a "commonsense tax treatment" for regulated payment stablecoins, clarifying source-of-income rules for trading and extending existing securities-lending rules to digital assets.
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December 22, 2025
IRS To Issue Guidance For Dyed Fuel Tax Refunds
The IRS announced plans Monday to issue guidance for a provision under the federal budget bill regarding a tax refund process for dyed fuel.
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December 22, 2025
Top Federal Tax Policies Of 2025
The first year of President Donald Trump's second term brought the passage of this summer's budget reconciliation bill, which renewed major parts of the 2017 Tax Cuts and Jobs Act, and major staffing changes at the Internal Revenue Service. Here, Law360 looks at the most consequential developments in federal tax policy in 2025.
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December 22, 2025
Britney Spears Disputes $720K IRS Bill In Tax Court
Britney Spears is challenging the IRS over the more than $720,000 it assessed against her in 2021, telling the U.S. Tax Court that the agency improperly increased income she received through her pass-through entity.
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December 22, 2025
Tariff Refunds Would Be 'A Mess,' Economic Official Says
It would be an "administrative problem" to issue tariff refunds in the aftermath of a potential U.S. Supreme Court ruling against the White House's trade measures, a top economic policy official said.
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December 22, 2025
IRS Seeks Input On Updates To Voluntary Disclosure Process
The Internal Revenue Service asked Monday for comments on a proposed change to its voluntary disclosure program that would require payment of all taxes, penalties and interest within three months after being conditionally approved for the program.
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December 22, 2025
Farmers Can Pay Capital Gains Tax In Installments, IRS Says
Farmers who will pay capital gains tax on a farmland property sale to another farmer can opt to make the payments in four equal installments instead of a lump sum under guidance the IRS released Monday, implementing relief created by the 2025 budget law.
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December 19, 2025
Gunderson-Led Tax Firm Andersen Trades Up After Rare IPO
Tax valuation and advisory firm Andersen Group Inc. has closed a $202 million initial public offering, marking a rare IPO that required legal teams to navigate uncommon structural and governance challenges, according to attorneys who steered the offering.
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December 19, 2025
Conn. Investment Adviser Admits To Tax Evasion
A Connecticut man pled guilty to tax evasion after using $5.2 million of his private equity fund's money to pay personal expenses and causing a criminal tax loss of nearly $2.2 million, federal prosecutors said.
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December 19, 2025
IRS Extends Transition For States' Paid Family Leave Changes
States with paid family and medical leave programs have another year to transition to changes to the income and employment tax treatment of contributions paid in certain situations to support those benefits, the IRS said Friday, adopting stakeholders' recommendation for more time to comply.
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December 19, 2025
IRS Relaxes Carbon Capture Credit's Environmental Reporting
The Internal Revenue Service released guidance Friday easing the carbon capture tax credit's environmental reporting requirements, taking effect by the end of the year, for energy systems that permanently secure the emissions in geological locations, such as deep underground rock formations.
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December 19, 2025
Taxation With Representation: Baker Botts, Morgan Lewis
In this week's Taxation With Representation, Trump Media and Technology Group merges with fusion power company TAE Technologies, pharmaceutical company Cencora boosts its stake in cancer care company OneOncology, and Phoenix Financial partners with private equity giant Blackstone to plug billions into various credit strategies.
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December 19, 2025
Calif. Ex-Customs Broker Sentenced For Tax, Wire Fraud
A California man was sentenced to 51 months in federal prison after being indicted this year on federal fraud charges and one count of tax evasion, the U.S. Department of Justice said.
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December 19, 2025
Polsinelli Lands Glaser Weil Tax Pro In Los Angeles
Polsinelli PC is expanding its business team, bringing in a tax pro from Glaser Weil as a shareholder in its Los Angeles office.
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December 18, 2025
IRS Guidance Discriminates Against Wind, Solar, Groups Say
Several groups, including the Natural Resources Defense Council and the city of San Francisco, asked a D.C. federal court Thursday to block the Internal Revenue Service from instituting new tax credit rules that they say illegally discriminate against wind and solar projects.
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December 18, 2025
Tax Court Denies Ex-Calif. Software Officer's Loan Deductions
A former executive of a now-defunct California software company cannot get a tax break on loans he said he lent the failing business between 2012 and 2015, a U.S. Tax Court judge ruled Thursday, finding he failed to show the loans could be deductible.
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December 18, 2025
7th Circ. Upholds Ex-Illinois Lawmaker's Tax Sentence
A former Illinois lawmaker cannot change her sentence despite attempts to comply with her tax reporting obligations after she was charged with evading them, the Seventh Circuit ruled Thursday, rejecting her argument that a lower court unconstitutionally barred evidence of her amended return.
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December 18, 2025
IRS Sets Unused Housing Credit Carryovers For 25 States
The IRS published Thursday the amounts of unused housing credit carryovers allocated to qualified states for 2025.
Expert Analysis
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SEC's Dual Share Class Approval Signals New Era For ETFs
The U.S. Securities and Exchange Commission's recent approval of the dual share class structure marks a landmark moment for the U.S. fund industry, opening the door for asset managers to benefit from combining mutual fund and exchange-traded fund share classes under a single portfolio, say Ilan Guedj at Bates White and Brian Henderson at George Washington University.
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E-Discovery Quarterly: Recent Rulings On Dynamic Databases
Several recent federal court decisions illustrate how parties continue to grapple with the discovery of data in dynamic databases, so counsel involved in these disputes must consider how structured data should be produced consistent with the requirements of the Federal Rules of Civil Procedure, say attorneys at Sidley.
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What To Do If A Retirement Plan Participant Is Deported
Given recent immigration policy changes in the U.S., many businesses are experiencing employee deportations, but retirement plan administrators should still pay and report benefits to avoid violating the plan, the Employee Retirement Income Security Act or tax reporting requirements, says Teri King at Smith Gambrell.
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Defeating Estoppel-Based Claims In Legal Malpractice Actions
State supreme court cases from recent years have addressed whether positions taken by attorneys in an underlying lawsuit can be used against them in a subsequent legal malpractice action, providing a foundation to defeat ex-clients’ estoppel claims, says Christopher Blazejewski at Sherin and Lodgen.
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The Biz Court Digest: How It Works In Massachusetts
Since its founding in 2000, the Massachusetts Business Litigation Session's expertise, procedural flexibility and litigant-friendly case management practices have contributed to the development of a robust body of commercial jurisprudence, say James Donnelly at Mirick O’Connell, Felicia Ellsworth at WilmerHale and Lisa Wood at Foley Hoag.
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Why Appellees Should Write Their Answering Brief First
Though counterintuitive, appellees should consider writing their answering briefs before they’ve ever seen their opponent’s opening brief, as this practice confers numerous benefits related to argument structure, time pressures and workflow, says Joshua Sohn at the U.S. Department of Justice.
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Attys Beware: Generative AI Can Also Hallucinate Metadata
In addition to the well-known problem of AI-generated hallucinations in legal documents, AI tools can also hallucinate metadata — threatening the integrity of discovery, the reliability of evidence and the ability to definitively identify the provenance of electronic documents, say attorneys at Law & Forensics.
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When Atty Ethics Violations Give Rise To Causes Of Action
Though the Model Rules of Professional Conduct make clear that a violation of the rules does not automatically create a cause of action, attorneys should beware of a few scenarios in which they could face lawsuits for ethical lapses, says Brian Faughnan at Faughnan Law.
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How Gov't May Use FARA To Target 'Domestic Terrorism'
After the Trump administration’s recent memo directing law enforcement to use the Foreign Agents Registration Act to prosecute domestic terrorism, nonprofit organizations receiving funding from foreign sources must assess their registration obligations under the statute, say attorneys at Pillsbury.
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Law School's Missed Lessons: Educating Your Community
Nearly two decades prosecuting scammers and elder fraud taught me that proactively educating the public about the risks they face and the rights they possess is essential to building trust within our communities, empowering otherwise vulnerable citizens and preventing wrongdoers from gaining a foothold, says Roger Handberg at GrayRobinson.
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5 Crisis Lawyering Skills For An Age Of Uncertainty
As attorneys increasingly face unprecedented and pervasive situations — from prosecutions of law enforcement officials to executive orders targeting law firms — they must develop several essential competencies of effective crisis lawyering, says Ray Brescia at Albany Law School.
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It's Time For The Judiciary To Fix Its Cybersecurity Problem
After recent reports that hackers have once again infiltrated federal courts’ electronic case management systems, the judiciary should strengthen its cybersecurity practices in line with executive branch standards, outlining clear roles and responsibilities for execution, says Ilona Cohen at HackerOne.
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Rules Of Origin Revamp May Be Next Big Trade Development
The rules of origin for determining what tariff applies to any given import appear to be on the cusp of an important rethink, and it seems likely that the administration will try to align the rule with its overall tariff strategy in one of three ways, says Ted Posner at Baker Botts.