Federal
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August 18, 2025
IRS Accepting Applications To 2026 Real-Time Audit Program
The Internal Revenue Service soon will begin accepting applications for its compliance assurance process real-time audit program for 2026, the agency announced Monday.
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August 18, 2025
IRS Floats Changes To Reporting Sale Of Partnership Interest
Partnerships no longer would need to include information in a tax form that would help partners who sold their share of the business with noncapital assets determine the gain or loss from the transaction, the Internal Revenue Service said Monday.
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August 18, 2025
Founder Of 'Modest Needs' Charity Admits Stealing Millions
A New York City man who operated a crowdsourcing charity for the poor copped to fraud and tax evasion charges Monday, telling a Manhattan federal judge that he stole millions and spent the money on a lavish lifestyle.
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August 18, 2025
Siblings Say They Can't Pay $3.4M In Taxes On Dad's Estate
Siblings being sued for $3.4 million in unpaid taxes on their father's estate asked a Texas federal court to deny the U.S. a judgment for the money, saying they can't pay because the estate consists mostly of illiquid interests in partnerships and real estate.
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August 15, 2025
IRS Strips 5% Safe Harbor In Solar, Wind Tax Credit Guidance
Large-scale clean energy projects seeking to claim solar and wind tax credits before they expire under a new accelerated sunset schedule can no longer rely on a safe harbor to incur 5% of the building costs to establish eligible construction start dates under Internal Revenue Service guidance released Friday.
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August 15, 2025
IRS Needs To Improve ID Verification On Telephone Calls
The Internal Revenue Service has failed to properly authenticate callers' identities on its business and practitioner telephone lines, the Treasury Inspector General for Tax Administration said Friday, recommending that the agency strengthen its authentication procedures to combat fraud.
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August 15, 2025
US Eyeing Tariffs, Port Levies Over Shipping Emissions Plan
The U.S. government is considering tariffs, visa restrictions or port levies — and potentially a combination of those measures — in response to an intergovernmental plan to push the global shipping industry toward achieving net-zero greenhouse gas emissions, a U.S. Department of State spokesperson told Law360.
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August 15, 2025
Retired EY Tax Ace Joins Atlanta Boutique
Atlanta-based law boutique Wiggam Law LLC has brought on a retired senior counsel at tax law boutique Asbury Law Firm, adding an attorney who previously led Ernst & Young's tax controversy practice for the central and southeastern U.S. and served as a trial attorney for the IRS, the boutique announced Friday.
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August 15, 2025
Truck Co. Asks Justices To Review Denial Of $268M Tax Break
A Tennessee truck company seeking $268 million in excise tax exemptions for its refurbished tractors has asked the U.S. Supreme Court to review a Sixth Circuit decision finding the company's tractors might not qualify because they may have previously been sold to tax-exempt buyers.
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August 15, 2025
Taxation With Representation: Wachtell, Cooley, Sullivan
In this week's Taxation With Representation, the NBA signs off on the sale of the Boston Celtics, Gildan Activewear acquires HanesBrands, private equity shop Advent International buys insurance software firm Sapiens, and financial software provider MeridianLink goes private via its acquisition by Centerbridge Partners.
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August 15, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included revised proposed rules for the corporate alternative minimum tax that will accommodate different approaches to calculating a partnership's investment income.
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August 14, 2025
Trump's Brazil Tariffs Raise Questions About Legal Limits
Higher tariffs imposed last week on Brazilian imports may prove especially vulnerable to legal challenges, but stakeholders expect the U.S.-Brazil trading relationship to nevertheless remain in limbo for the immediate future.
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August 14, 2025
2nd Circ. Revives Couple's Late Tax Court Petition
The U.S. Tax Court may review a couple's tax deficiency case that was filed past deadline, based on recent U.S. Supreme Court decisions that allow extending the statute of limitations for laws that do not address judicial authority, the Second Circuit ruled Thursday.
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August 14, 2025
IRS Asked To Add Chemicals To Taxable Substances List
The Internal Revenue Service is seeking comments on a pair of proposals by a synthetic rubber company to add chemicals to the agency's list of taxable substances, the agency said Thursday.
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August 14, 2025
Clark Hill Expands Tax Bench With Plunk Smith Atty In Texas
Clark Hill PLC announced Thursday that it has bolstered its tax and estate planning group in North Texas with an attorney who came aboard from Plunk Smith PLLC.
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August 13, 2025
GAO Upholds $37M IRS Deal For IT Support
The U.S. Government Accountability Office shot down a protest from an incumbent contractor for the Internal Revenue Service after it lost out on an information technology deal to a rival business, saying the IRS reasonably weighed the strengths of both businesses.
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August 13, 2025
2nd Circ. Upholds Ban On Certain SALT Cap Workarounds
An Internal Revenue Service rule prohibiting charitable donation workarounds to the federal cap on state and local tax deductions will remain in place, a Second Circuit panel said Wednesday, affirming a district court determination that upheld the agency's ban on the programs.
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August 13, 2025
2nd Circ. Asked To Review Bid To Bar NYC Congestion Pricing
The Second Circuit should review a federal court's decision to grant the Metropolitan Transportation Authority and Triborough Bridge and Tunnel Authority's bid to dismiss a pair of lawsuits alleging Manhattan's congestion pricing tolls are discriminatory and trample on motorists' right to travel, a New York county argued Tuesday.
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August 13, 2025
US Threatens Retaliation For 'Global Carbon Tax' On Shipping
The U.S. government has preemptively threatened to retaliate against countries that adopt a multilateral plan to shift the global shipping industry toward achieving net-zero greenhouse gas emissions, claiming it's "a global carbon tax" that would disfavor liquefied natural gas and biofuels.
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August 12, 2025
Fed. Circ. Won't Revive Real Estate Co.'s IRS Contract Dispute
A real estate company failed to show that the Internal Revenue Service improperly blocked its bid to continue leasing office space to the agency after agency employees complained about the building, the Federal Circuit said Tuesday, affirming a Court of Federal Claims ruling.
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August 12, 2025
Groups Urge IRS To Resist Pressure To Share Taxpayer Info
Advocacy groups urged the Internal Revenue Service on Tuesday to keep resisting presidential pressure to share confidential tax-return information with immigration enforcement authorities, saying the abrupt departure of the agency's new commissioner highlights the need for oversight.
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August 12, 2025
DOL Yanks 2021 Guidance On Private Equity 401(k) Risks
The U.S. Department of Labor's employee benefits arm on Tuesday rescinded guidance from 2021 that warned 401(k) plan managers about the risks of investing in private equity, which comes after an executive order last week that called for expanding access to alternative asset classes in defined-contribution retirement plan investing.
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August 12, 2025
Texas Tax Prep Firm Deserves Ban For Wide Fraud, Court Told
A Texas tax preparation firm engaged in extensive fraud that included guiding clients to — often unwittingly — invent businesses to claim losses, fraudulently claim self-employment tax credits and falsely identify as heads of household, the government told a federal court, seeking to ban the firm from practicing.
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August 12, 2025
Holland & Knight Hires Sen. Cornyn Tax Counsel In DC
The former senior tax counsel for U.S. Sen. John Cornyn, R-Texas, who worked for the lawmaker for almost two decades on appropriations, taxation, banking and other finance-related issues, has joined Holland & Knight LLP's public policy and regulation group.
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August 12, 2025
Trump's Tariffs Add Billions In Revenue, Think Tank Says
President Donald Trump's enacted tariffs are generating billions of dollars more in revenue when compared to duty collections prior to his taking office, and that revenue could be used to reduce the U.S. budget deficit, according to a recent analysis by the Committee for a Responsible Federal Budget.
Expert Analysis
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E-Discovery Quarterly: Rulings On Relevance Redactions
In recent cases addressing redactions that parties sought to apply based on the relevance of information — as opposed to considerations of privilege — courts have generally limited a party’s ability to withhold nonresponsive or irrelevant material, providing a few lessons for discovery strategy, say attorneys at Sidley.
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Section 1983 Has Promise After End Of Nationwide Injunctions
After the U.S. Supreme Court recently struck down the practice of nationwide injunctions in Trump v. Casa, Section 1983 civil rights suits can provide a better pathway to hold the government accountable — but this will require reforms to qualified immunity, says Marc Levin at the Council on Criminal Justice.
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Playing Soccer Makes Me A Better Lawyer
Soccer has become a key contributor to how I approach my work, and the lessons I’ve learned on the pitch about leadership, adaptability, resilience and communication make me better at what I do every day in my legal career, says Whitney O’Byrne at MoFo.
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Lessons On Parallel Settlements From Vanguard Class Action
A Pennsylvania federal judge’s unexpected denial of a proposed $40 million settlement of an investor class action against Vanguard highlights key factors parties should consider when settlement involves both regulators and civil plaintiffs, say attorneys at Ropes & Gray.
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Adapting To Private Practice: From ATF Director To BigLaw
As a two-time boomerang partner, returning to BigLaw after stints as a U.S. attorney and the director of the Bureau of Alcohol, Tobacco, Firearms and Explosives, people ask me how I know when to move on, but there’s no single answer — just clearly set your priorities, says Steven Dettelbach at BakerHostetler.
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Mulling Worker Reclassification In Light Of No Tax On OT
The One Big Beautiful Bill Act's no-tax-on-overtime provisions provide tax relief for employees who regularly work overtime and are nonexempt from the Fair Labor Standards Act, but reclassifying employees may lead to higher compliance costs and increased wage and hour litigation for employers, says Steve Bronars at Edgeworth Economics.
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Clean Energy Tax Changes Cut Timelines, Add Red Tape
With its dramatic changes to energy tax credits, the One Big Beautiful Bill Act will reshape project financing and investment planning — and wind and solar developers, especially those in the early stages of projects, face stricter timelines and heightened compliance challenges, says Dan Ruth at Balch & Bingham.
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Playing Baseball Makes Me A Better Lawyer
Playing baseball in college, and now Wiffle ball in a local league, has taught me that teamwork, mental endurance and emotional intelligence are not only important to success in the sport, but also to success as a trial attorney, says Kevan Dorsey at Swift Currie.
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Reform Partly Modernizes Small Biz Stock Gains Exclusion
Changes to the Internal Revenue Code in the One Big Beautiful Bill Act update the qualified small business stock gains exclusion to reflect inflation, but the regime would be more in line with current business realities if Congress had also made the exemption available to additional business structures, says Mark Parthemer at Glenmede.
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How Real Estate Funds Can Leverage Del. Statutory Trusts
Over the last two years, traditional real estate fund sponsors have begun to more frequently adopt Delaware Statutory Trust programs, which can help diversify capital-raising strategies and access to new sources of capital, among other benefits, say attorneys at Polsinelli.
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DOJ Crypto Enforcement Is Shifting To Target Willfulness
Three pending criminal prosecutions could be an indication of how the U.S. Department of Justice's recent digital assets memo is shaping enforcement of the area, and show a growing focus on executives who knowingly allow their platforms to be used for criminal conduct involving sanctions offenses, say attorneys at Gibson Dunn.
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4 Former Justices Would Likely Frown On Litigation Funding
As courts increasingly confront cases involving hidden litigation finance contracts, the jurisprudence of four former U.S. Supreme Court justices establishes a constitutional framework that risks erosion by undisclosed financial interests, says Roland Eisenhuth at the American Property Casualty Insurance Association.
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Practical Implications Of SEC's New Crypto Staking Guidance
The U.S. Securities and Exchange Commission's recent staff guidance that protocol staking does not constitute securities offerings provides a workable compliance blueprint for crypto developers, validators and custodial platforms willing to keep staking strictly limited to protocol-driven rewards, say attorneys at Cahill.