Federal
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July 30, 2025
US Adds 40% Tariff On Brazil, Sanctions Top Court Justice
President Donald Trump imposed a 40% tariff on Brazil on Wednesday, alleging in an executive order that the country's Supreme Court is "politically persecuting" former President Jair Bolsonaro, while the U.S. Treasury Department sanctioned one of the court's justices.
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July 30, 2025
Senate Panel Advances 2 Bipartisan Bills Boosting ESOPs
A key Senate panel advanced two bills Wednesday that would change federal benefits law related to employee stock ownership plans, or ESOPs, by providing businesses additional legal cover when they make company stock valuations and by adding ESOP representatives to a federal advisory board.
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July 30, 2025
Tax Overhaul Is Mixed Bag For Interest Expense Deductions
Companies that are eager to increase their interest expense deductions under the new federal tax overhaul may end up with a smaller tax break than expected due to how the law factors their foreign income into the deduction calculation.
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July 30, 2025
Groups Warn IRS Policy Shift Could Beget Dark Money Deluge
Leaders of national nonprofit organizations said Wednesday that the IRS' efforts to weaken a 71-year-old tax law banning churches from endorsing political candidates would lead to unlimited amounts of untraceable campaign contributions flowing through the nonprofit sector.
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July 30, 2025
Dechert Adds Tax Pro From PwC In DC
Dechert LLP has continued to grow its financial services platform in Washington, D.C., with the hire of a partner from PwC.
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July 30, 2025
Trump To Hit India With 25% Tariff, 'Penalty' Starting Friday
President Donald Trump said Wednesday that he planned to impose a 25% tariff on India beginning Friday, plus an additional "penalty," citing the country's energy and defense dealings with Russia as top concerns along with trade barriers.
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July 29, 2025
IRS To Permit Corp. AMT Top-Down Election For Partnerships
The IRS said Tuesday that revised proposed rules for the corporate alternative minimum tax will accommodate different approaches to calculating a partnership's investment income, including the top-down approach permitting a corporate partner to use figures that the partner reported in its own financial statement.
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July 29, 2025
Economists Decry Federal Budget's Looser Interest Deduction
It's regrettable that Congress loosened rules allowing companies to deduct interest costs from tax liabilities in its latest budget, which as a whole is poised to worsen the country's fiscal trajectory while prompting higher interest rates, a panel of economists said Tuesday.
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July 29, 2025
Refiners Seek Clarity From Treasury For Clean Fuel Credit
The U.S. Treasury Department should clarify at what points during the refining process an oil and gas mixture qualifies for the clean fuel production tax credit to be consistent with its preceding incentive for biofuels, an oil and gas refining association said in a letter released Tuesday.
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July 29, 2025
Ensure Energy Tax Credit Limit On Foreign Cos., Letter Says
The U.S. Department of the Treasury should publish guidance aimed at preventing foreign corporations from circumventing the new budget law's limits on energy tax credits by starting construction before the restrictions kick in, a solar technology and manufacturing company said in a letter Tuesday.
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July 29, 2025
Ex-IRS Acting Commissioner Joins KPMG's DC Office
A former senior Internal Revenue Service employee who served as the agency's acting commissioner this year has joined KPMG LLP's Washington national tax practice as a senior managing director, the firm announced.
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July 29, 2025
4th Circ. Rejects BofA's Claim Of Tax Offsets After Mergers
Bank of America cannot use its tax overpayments to offset interest on tax underpayments by Merrill Lynch just because the two companies later merged, the Fourth Circuit affirmed Tuesday in a $163 million case that affects more than 20 years' worth of tax adjustments.
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July 29, 2025
IRS Wrong To Fight Flexible Tax Court Deadline, 8th Circ. Told
A couple arguing for flexibility to the 90-day deadline for challenging tax bills in the U.S. Tax Court told the Eighth Circuit that the Internal Revenue Service is wrong in claiming that such leniency would upend tax collection.
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July 28, 2025
New IRS Chief Rejects 'Wizard Of Oz'-Style Leadership
New Internal Revenue Commissioner Billy Long vowed Monday to engage more directly with agency employees to improve taxpayer service, emphasizing that he does not want to be a "Wizard of Oz"-style leader hiding behind a curtain.
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July 28, 2025
SALT Cap Complexity Could Rewrite Tax Planning Strategies
The new $40,000 cap on state and local tax deductibility in the GOP's 2025 tax overhaul will likely prompt a new wave of strategic tax planning activity among wealthy business owners and individuals seeking to maximize their deductions and make use of state-level workarounds before the temporary relief expires.
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July 28, 2025
Fired Worker Owes Tax On $1.5M Settlement, Tax Court Says
A former PNC Investments LLC employee who won a defamation settlement after being fired must pay tax on the $1.5 million award, the U.S. Tax Court said Monday, rejecting the ex-worker's argument that the money didn't count as income.
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July 28, 2025
10th Circ. Says Carbon Group Can't Appeal Tax Assessment
An entity that owns interest in a carbon producer can't appeal a $2 million tax assessment made by a Colorado county on a carbon unit operator that the entity owns interest in because the federal court doesn't have jurisdiction, the Tenth Circuit said Monday.
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July 28, 2025
Trailer Maker's Bid To Escape $4M Excise Taxes Dismissed
A trailer manufacturer can't avoid more than $4 million in excise taxes, interest and penalties, a South Dakota federal court ruled, finding it couldn't rely on an exemption from a technical advice memorandum after Congress altered the definition of off-highway vehicles.
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July 28, 2025
US, Japanese Businessman Settle $11.6M FBAR Dispute
A Japanese businessman and the federal government have settled their $11.6 million tax filing dispute after the man claimed a language barrier was to blame and the U.S. tried to push past a jury's verdict, according to a Hawaii federal court filing.
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July 25, 2025
Trump Trade Deals Do Little To Ease Importers' Concerns
President Donald Trump's recently announced framework trade deals offer new insight into tariff rates for several countries come Aug. 1, but experts say unanswered questions about those agreements and others still at large continue to stifle longer-term planning, leaving importers in uncertain territory.
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July 25, 2025
Ex-Credit Suisse Client Gets 2½ Years For Hiding Assets
A Florida federal judge on Friday sentenced a Colombian-American businesswoman and former Credit Suisse client to two and a half years in prison for conspiring with family members to hide more than $90 million in assets from the IRS through a series of foreign bank accounts.
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July 25, 2025
Mayo Clinic's $11.5M Tax Refund Affirmed By 8th Circ.
The Mayo Clinic qualifies as an "educational organization" under federal tax law, making it eligible for a tax exemption for such organizations and meriting a nearly $11.5 million refund, the Eighth Circuit said Friday, affirming a federal district court.
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July 25, 2025
Vegas Workers Laud Tax Breaks On Tips, OT At Hearing
The new federal tax deductions for tips and overtime pay will be extremely beneficial to working-class residents of Las Vegas, the House Ways and Means Committee heard from workers and others at a field hearing Friday, while Democrats criticized the temporary nature of the tax breaks.
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July 25, 2025
Rising Star: Gibson Dunn's Michael Q. Cannon
Michael Q. Cannon of Gibson Dunn & Crutcher LLP has been the lead attorney on several high-profile cases, including playing a key role in advising on the tax aspects of the world's largest merger and acquisition deal in 2023, earning him a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 25, 2025
IRS Provides Guidance Meant To Speed Up Corporate Audits
The Internal Revenue Service released guidance Friday that aims to make audits more efficient for corporate taxpayers, including by phasing out a document request process taxpayers had criticized as time-consuming and of little value.
Expert Analysis
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When Innovation Overwhelms The Rule Of Law
In an era where technology is rapidly evolving and artificial intelligence is seemingly everywhere, it’s worth asking if the law — both substantive precedent and procedural rules — can keep up with the light speed of innovation, says Reuben Guttman at Guttman Buschner.
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What Compensation Committees Must Keep In Mind In 2025
New disclosure obligations, an evolving discussion on the analysis of executive perks and updated proxy adviser policies — on top of a new presidential administration — are all important things compensation committees must pay close attention to in 2025, say attorneys at Simpson Thacher.
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Anticipating Direction Of Cosmetics Regulation Under Trump
It is unclear how cosmetics regulation reform from the last few years will fare under President Donald Trump, but the new administration's emphasis on deregulation and Robert F. Kennedy Jr.'s views on product safety provide some insight, say attorneys at Crowell & Moring.
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IRS Basis-Shifting Rule Poses Notable Reporting Obligations
While the IRS’ recently finalized rule requiring partnerships to report certain related-party basis adjustment transactions is narrower than originally proposed, taxpayers and their advisers will still need to comb through myriad transactions to comply, say attorneys at Debevoise.
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Imagine The Possibilities Of Openly Autistic Lawyering
Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.
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Litigation Funding Disclosure Debate: Strategy Considerations
In the ongoing debate over whether courts should require disclosure of litigation funding, funders and plaintiffs tend to argue against such mandates, but voluntarily disclosing limited details about a funding arrangement can actually confer certain benefits to plaintiffs in some scenarios, say Andrew Stulce and Marc Cavan at Longford Capital.
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Top Considerations For Insurance Companies In 2025
As insurance industry participants look to plan for the year, regulatory changes, climate-related challenges, the ongoing effects of social inflation and the potential for significant mergers and acquisitions will be among the key items for insurer boards and management to have on their radar, say attorneys at Debevoise.
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Scope And Nature Of Judicial Relief Will Affect Loper's Impact
The practical result of post-Loper Bright rulings against regulatory actions will depend on the relief courts grant — and there has been controversy in these types of cases over whether the ruling is applied just to the parties or nationwide, and whether the action can be left in place while it's corrected, says Steven Gordon at Holland & Knight.
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5 Ways To Create Effective Mock Assignments For Associates
In order to effectively develop associates’ critical thinking skills, firms should design mock assignments that contain a few key ingredients, from messy fact patterns to actionable feedback, says Abdi Shayesteh at AltaClaro.
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Congress Should Pass Sex Abuse Settlement Tax Exemptions
The proposed Survivor Justice Tax Prevention Act would expand tax exemptions more clearly for sexual abuse cases, and finally remove the stigma around compensation for emotional and psychological damage, says Rocco Strangio at Milestone & Co.
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What's Next For Accounting Enforcement After SEC's Big 2024
The U.S. Securities and Exchange Commission under the Trump administration will likely continue to focus enforcement efforts on many of the same accounting and auditing issues that it pursued over the past year — but other areas, such as ESG, internal controls and cryptocurrency cases, may fall out of focus, say attorneys at Debevoise.
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Mentorship Resolutions For The New Year
Attorneys tend to focus on personal achievements or career milestones when they set yearly goals, but one important area often gets overlooked in this process — mentoring relationships, which are some of the most effective tools for professional growth, say Kelly Galligan at Rutan & Tucker and Andra Greene at Phillips ADR.
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Coaching Little League Makes Me A Better Lawyer
While coaching poorly played Little League Baseball early in the morning doesn't sound like a good time, I love it — and the experience has taught me valuable lessons about imperfection, compassion and acceptance that have helped me grow as a person and as a lawyer, says Alex Barnett at DiCello Levitt.