Federal
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July 15, 2025
Tax Court Warns Attys In Denying $20M Easement Deduction
The U.S. Tax Court threatened Tuesday to force attorneys for a Georgia partnership to personally pay court costs after they had argued at trial for a $20 million tax deduction for a conservation easement donation, an amount the court said was over 100 times the land's value.
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July 15, 2025
Tax Court Denies Exclusion To Reduce Estate's Value
The estate of one deceased spouse did not file its return in time for the estate of another deceased spouse to use an exclusion to reduce the value of the second estate, the U.S. Tax Court said in a decision Tuesday.
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July 15, 2025
Tax Court Denies Equitable Tolling To Firm In Collection Action
A North Dakota law firm that convinced the U.S. Supreme Court three years ago that federal courts can extend equitable tolling for nonjurisdictional deadlines was not able to sway the U.S. Tax Court to extend the time for the firm to file a collection action case against the IRS, according to a bench opinion.
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July 15, 2025
IRS Updates Corp. Bond Monthly Yield Curve For July
The Internal Revenue Service updated Tuesday the corporate bond monthly yield curve used in calculations for defined benefit plans for July, as well as corresponding segment rates and other related provisions.
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July 15, 2025
IRS To Provide Transition Relief For Tips And OT Tax Breaks
The IRS will provide guidance for new deductions for tips, overtime pay and car loan interest that will include transition relief for taxpayers claiming those deductions and employers subject to associated reporting requirements, according to a fact sheet released by the agency.
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July 15, 2025
These Firms Worked On The Top First-Half Real Estate Deals
A&O Shearman and Stibbe are among the more than 20 law firms that scored work on the 10 largest global real estate mergers and acquisitions of the first half, a period that saw three transactions above $4 billion.
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July 15, 2025
IRS Issues 2026 Static Mortality Tables For Defined Plans
The Internal Revenue Service released on Tuesday the updated static mortality tables to be used to calculate the funding target and other items for defined benefit pension plans during the 2026 calendar year.
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July 15, 2025
Booz Allen Urges DC Circ. To Affirm IRS Leak Sentence
Government contractor Booz Allen Hamilton urged the D.C. Circuit to uphold the five-year prison sentence of its former employee for leaking tax returns while on a job at the IRS, saying the crime has hurt the company's reputation and subjected it to "baseless lawsuits."
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July 15, 2025
11th Circ. Told Tax Court Erred Nixing Easement's Values
A Georgia partnership told the Eleventh Circuit that the U.S. Tax Court broke legal precedent by relying on a flawed valuation method that did not consider commercial mining potential when it denied a deduction tied to the conservation easement donation of a property.
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July 15, 2025
LA Deputies Admit Using Positions To Aid Crypto 'Godfather'
Two Los Angeles County sheriff's deputies admitted using their official positions to harass enemies of a cryptocurrency founder who called himself "The Godfather" and failed to report $36 million in income from selling hacked Meta business accounts, the U.S. Department of Justice said.
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July 14, 2025
EU Law Doesn't Shield Eaton Records, US Tells 6th Circ.
The European Union's privacy law does not protect Eaton Corp. from having to disclose employee evaluation records in a transfer pricing dispute with the Internal Revenue Service, the U.S. government told the Sixth Circuit on Monday.
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July 14, 2025
Tax Court Tosses $62M In Bogus Land Deductions
The U.S. Tax Court slashed about $62 million in tax deductions claimed by four partnerships for donations of conservation easements in Georgia on Monday, saying the partnerships did not provide the required appraisals and grossly overstated the value of their donations.
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July 14, 2025
GOP Lawmakers Back USTR Probe Into Foreign Drug Pricing
Republican members of Congress expressed support Monday for the Office of the U.S. Trade Representative's efforts against what the lawmakers referred to as anti-innovation policies abroad that, they said, require U.S. companies to take on the brunt of pharmaceutical research and development.
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July 14, 2025
Trump Threatens Tariffs On Russia Over Ukraine War
President Donald Trump said Monday that Russia must end its war with Ukraine within the next 50 days or else the U.S. will levy "severe tariffs" on Russian goods entering the U.S.
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July 14, 2025
IRS Met Penalty Rules In Easement Cases, Tax Court Says
The IRS met all requirements for supervisory approval of penalties it issued to two companies related to disallowed charitable contribution deductions for donated conservation easements, the U.S. Tax Court said Monday.
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July 14, 2025
Tax Court Finds Couple Not Divorced In Filing Status Dispute
A Minnesota accountant and his wife who divorced through a religious ceremony were not divorced in the eyes of the law and thus can't claim the head-of-household tax filing status reserved for certain unmarried people, the U.S. Tax Court ruled.
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July 14, 2025
US Defends Seeking Man's Info From Apple In Swiss Tax Probe
The U.S. government urged a California federal court to enforce an IRS summons on Apple Inc. to produce records linked to the account of a dual Swiss-Italian citizen, arguing the summons is valid under the U.S.-Switzerland tax treaty.
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July 14, 2025
Evidence Tainted In $20.7M Easement Loss, 11th Circ. Told
The U.S. Tax Court improperly allowed hundreds of trial exhibits in striking a Georgia partnership's $20.7 million tax deduction for donating a conservation easement, the partnership told the Eleventh Circuit, saying the government failed to address its claims that the court broke evidence rules.
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July 14, 2025
Jury Says Commercial Real Estate Owner Hid $4.8M
A jury in Washington federal court has found a commercial real estate company owner guilty on charges of concealing nearly $5 million in income from the Internal Revenue Service using a series of limited liability companies.
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July 14, 2025
30% US Tariffs Would Prohibit Trade, EU Commissioner Says
President Donald Trump's weekend threat to impose a 30% tariff on goods imported from the European Union would "practically prohibit" trade, the EU's trade commissioner warned Monday.
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July 14, 2025
IRS Staff Cuts Imperil Gains In Wealthy Audits, TIGTA Says
The Internal Revenue Service's small- and large-business divisions increased audits on high-income taxpayers in 2024, but that progress will likely be jeopardized by recent staffing cuts, the Treasury Inspector General for Tax Administration said in a report released Monday.
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July 11, 2025
Courts Face Early Push To Expand Justices' Injunction Ruling
In the two weeks since the U.S. Supreme Court curtailed federal judges' ability to issue universal injunctions, Trump administration attorneys have begun pushing to expand the decision's limits to other forms of relief used in regulatory challenges and class actions. So far, judges don't appear receptive to those efforts.
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July 11, 2025
Gov't Wants Fla. Man's Assets Repatriated To Pay Tax Debt
A Floridian who owes the federal government nearly $28 million, plus penalties and interest, must repatriate funds held in two Bahamian trusts kept in his name and that of his children, the government told a Florida federal court.
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July 11, 2025
The Tax Angle: Church Politics, Budget Talk, Disaster Relief
From a look at the IRS' statement relaxing a 71-year-old ban on political endorsements by churches to talk of a second budget reconciliation bill this year and the passage of disaster tax relief legislation, here's a peek into a reporter's notebook on a few developing tax stories.
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July 11, 2025
US Seeks To Toss DOGE Taxpayer Data-Sharing Suit
Unions and advocacy organizations trying to block the White House's Department of Government Efficiency from sharing taxpayer data across agencies have not shown they've suffered the sort of injuries that would allow them to sue the federal government, the U.S. government told a D.C. federal court.
Expert Analysis
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How To Accelerate Your Post-Attorney Career Transition
Professionals seeking to transition to nonattorney careers may encounter skepticism as nontraditional candidates, but there are opportunities for thought leadership and to leverage speaking and writing to accelerate a post-attorney career transition, say Janet Falk at Falk Communications and Evgeny Efremkin at Toronto Metropolitan University.
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Tariffs And FCA Create Perfect Storm For Importers
The Trump administration's aggressive tariff policies pose a high risk to certain importation practices that are particularly likely to trigger False Claims Act enforcement, say attorneys at Jeffer Mangels.
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US Reassessment Of OECD Tax Deal Is Right Move
The wholesale U.S. reevaluation of the Organization for Economic Cooperation and Development's global tax deal ordered by President Donald Trump is a positive step that could ultimately create a more durable international tax system, says Anne Gordon at the National Foreign Trade Council.
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Measuring And Mitigating Harm From Discriminatory Taxes
In response to new tariffs and other recent "America First Trade Policy" pronouncements, corporations should assess and take steps to minimize their potential exposure to discriminatory and reciprocal tax measures that are likely to come, say economists at Charles River Associates.
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Adapting To Private Practice: From DOJ Leadership To BigLaw
The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.
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How The CRE Industry Is Adapting To Tariff Uncertainty
Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.
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Law Firm Executive Orders Create A Legal Ethics Minefield
Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.
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Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike
The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.
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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.