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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Emerging Energy Trends Reflect Shifting Political Landscape
As the Trump administration settles in, some emerging energy industry trends, like expanded support for fossil fuel production, are right off of its wish list — while others, like the popularity of Inflation Reduction Act energy tax credits, and bipartisan support for carbon capture, reflect more complex political realities, say attorneys at Greenberg Traurig.
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Tax-Free Ways To Help Employees After The LA Wildfires
Following the recent wildfires in Los Angeles, there are various tax-free ways to give employees the resources and flexibility they need, including simpler methods like disaster relief payments under Internal Revenue Code Section 139 and leave-sharing programs, and others that require more planning, says Ligeia Donis at Baker McKenzie.
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Judge Should Not Have Been Reprimanded For Alito Essay
Senior U.S. District Judge Michael Ponsor's New York Times essay critiquing Supreme Court Justice Samuel Alito for potential ethical violations absolutely cannot be construed as conduct prejudicial to the administration of the business of the courts, says Ashley London at the Thomas R. Kline School of Law of Duquesne University.
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Lights, Camera, Ethics? TV Lawyers Tend To Set Bad Example
Though fictional movies and television shows portraying lawyers are fun to watch, Hollywood’s inaccurate depictions of legal ethics can desensitize attorneys to ethics violations and lead real-life clients to believe that good lawyers take a scorched-earth approach, says Nancy Rapoport at the University of Nevada, Las Vegas.
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Accountant-Owned Law Firms Could Blur Ethical Lines
KPMG’s recent application to open a legal practice in Arizona represents the first overture by an accounting firm to take advantage of the state’s relaxed law firm ownership rules, but enforcing and supervising the practice of law by nonattorneys could prove particularly challenging, says Seth Laver at Goldberg Segalla.
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AI Will Soon Transform The E-Discovery Industrial Complex
Todd Itami at Covington discusses how generative artificial intelligence will reshape the current e-discovery paradigm, replacing the blunt instrument of data handling with a laser scalpel of fully integrated enterprise solutions — after first making e-discovery processes technically and legally harder.
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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.