Federal
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November 12, 2025
MVP: Eversheds Sutherland's Maria Todorova
Eversheds Sutherland's Maria Todorova secured a pivotal win for Duke Energy by successfully arguing that South Carolina's investment tax credit statute allowed the company to claim $20 million for qualifying investments, earning her a spot as one of the 2025 Law360 Tax MVPs.
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November 12, 2025
DOJ Fights Claim That IRS Unlawfully Shared Info With ICE
The Trump administration has said the IRS complied with regulations when considering information requests from immigration enforcement officials, urging a D.C. federal judge to deny advocacy groups' request to submit a supplemental filing asserting that documents it turned over show otherwise.
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November 12, 2025
DC Circ. Affirms Toss Of Tax Tipster's Award Challenge
The U.S. Tax Court correctly dismissed a man's claim to a whistleblower award for tips he gave the IRS about businesses he alleged had skipped employment taxes, the D.C. Circuit ruled Wednesday, saying the IRS didn't take any action against the taxpayers.
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November 12, 2025
8th Circ. Denies Medtronic's Bid To Rethink Pricing Ruling
The Eighth Circuit denied healthcare tech company Medtronic's request to reconsider the court's approach for pricing a licensing agreement with a Puerto Rican affiliate, leaving in place Wednesday a ruling that directed the U.S. Tax Court to give the Internal Revenue Service's method another look.
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November 12, 2025
6th Circ. Asked To Rethink Tax Court Filing Deadline Ruling
The Sixth Circuit should rethink its decision that the 90-day deadline to file a U.S. Tax Court petition is flexible and can be extended sometimes, the U.S. argued, saying the ruling widens a circuit split on an issue critical to tax administration.
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November 10, 2025
Law360 MVP Awards Go To Top Attorneys From 76 Firms
The attorneys chosen as Law360's 2025 MVPs have distinguished themselves from their peers by securing significant achievements in high-stakes litigation, complex global matters and record-breaking deals.
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November 10, 2025
IRS Sets Safe Harbor For Trusts Staking Digital Assets
Investment and grantor trusts can stake their digital assets — which can generate passive income — without losing their tax benefits if they meet certain requirements, including obtaining approval from the U.S. Securities and Exchange Commission to authorize such activities, the Internal Revenue Service said in a revenue procedure Monday.
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November 10, 2025
Ex-Russian Gas Exec Seeks Release After Tax Sentence Axed
A former Russian gas company executive convicted of hiding more than $100 million from the IRS asked a Florida federal court to release him from prison now that his sentence has been vacated on appeal, while the U.S. urged the court to deliver the same seven-year term.
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November 10, 2025
Supreme Court Declines Lawyer's Bid For New Tax Fraud Trial
The U.S. Supreme Court won't hear a personal injury lawyer's appeal of his conviction over allegations he concealed more than $2.6 million in income from the Internal Revenue Service.
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November 07, 2025
Eaton Should Have Weighed Borrowing In Europe, Judge Says
When it acquired Ireland-based Cooper Industries in 2012, Eaton Corp. should have considered the costs of borrowing in Europe to finance the transaction, Tax Court Judge Albert Lauber said Friday in questioning a former Eaton official.
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November 07, 2025
Justices Cast Constitutional Clouds Over Trump's Tariffs
Several U.S. Supreme Court justices appeared skeptical of the government's arguments seeking to salvage President Donald Trump's emergency tariffs, signaling that the high court may come down with a ruling that reinforces Congress' constitutional authority to impose tariffs.
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November 07, 2025
State Tax Rules Flagged To DOJ In Interstate Commerce Probe
Tax attorneys and business groups are using a federal effort that aims to reduce interstate commerce burdens to highlight litigation over state taxes and call for codifying U.S. Supreme Court precedent on the commerce clause.
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November 07, 2025
Calif. Cannabis Co. Fights $10M IRS Bill In Tax Court
A California company that manages cannabis operators challenged $10 million in taxes and penalties in the U.S. Tax Court, arguing the Internal Revenue Service stripped it of business deductions by incorrectly determining it trafficked in a controlled substance.
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November 07, 2025
Donor Wants Tax Court To Reinstate Easement Deductions
An Oklahoma donor asked the U.S. Tax Court to reinstate deductions of $12 million and $13 million he claimed through partnership entities on a pair of charitable conservation easement donations, asserting the Internal Revenue Service disallowed the tax breaks without adequate explanation.
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November 07, 2025
9th Circ. Sides With Calif. In Tribal Cigarette Tax Fight
The Ninth Circuit on Friday backed California in a dispute it brought to enforce cigarette taxes against a tobacco company owned and operated by a federally recognized Native American tribe, holding that the tribal leader defendants can't claim sovereign or qualified immunity exempts them from the federal tax law.
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November 07, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service on Friday released its weekly internal revenue bulletin, which included proposed regulations that would remove rules that allow revenue officials to look through the corporate owners of real estate investment entities to determine whether they are domestically controlled.
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November 07, 2025
DOJ Backs Trump In NY False-Records Conviction Appeal
The U.S. Department of Justice is throwing its support behind President Donald Trump's effort to overturn his New York criminal conviction for falsifying business records, filing a proposed amicus brief on Friday citing the U.S. Supreme Court's landmark 2024 decision "defining the contours of a president's federal constitutional immunity from criminal prosecution."
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November 07, 2025
Wyden, Warren Flag IRS CEO's Fiserv Tenure In Probe
Two Senate Finance Committee members said they are investigating Internal Revenue Service CEO Frank Bisignano's conduct in his previous position as Fiserv Inc.'s CEO, saying the financial setbacks the company has faced this year raise questions about his ability to serve as a key IRS official.
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November 07, 2025
Taxation With Representation: Kirkland, Cravath, Paul Weiss
In this week's Taxation With Representation, consumer products giant Kimberly-Clark acquires Tylenol maker Kenvue, shale producers SM Energy and Civitas Resources announce a merger, and power management company Eaton buys Boyd Corp.'s thermal business.
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November 06, 2025
Goldstein Loses Bid To Trim Tax Charges Before Trial
A Maryland federal judge Thursday handed SCOTUSblog co-founder Tom Goldstein a series of losses on pre-trial motions aimed at trimming the 22 federal tax charges he'll face at trial next year, ruling that many of the motions involved factual disputes fit for trial and keeping the government's case intact.
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November 06, 2025
Tax Court OKs Disallowance Of Unverified Litigation Fees
The IRS correctly determined that a woman who'd been at odds with her various attorneys — having filed breach of contract suits against two separate legal teams — inadequately justified her claimed $28,000 deduction for legal expenses, the U.S. Tax Court said Thursday.
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November 06, 2025
Whistleblower Entitled To Award For $31M Tip, DC Circ. Told
The U.S. Tax Court wrongly denied a whistleblower award to a woman who said she helped the Internal Revenue Service assess more than $31 million in corporate income, her supporter told the D.C. Circuit, saying the court allowed the agency to omit relevant information it was required to provide.
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November 06, 2025
IRS Microcaptive Reporting Rules Suit Can Move Forward
A global tax services provider can move forward with its suit against the IRS to vacate tax reporting rules for microcaptive insurance companies, a Texas federal court said, finding the company had a stake in the challenge and a right to bring the case.
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November 06, 2025
No $22M Break For Real Estate Partnership, 6th Circ. Affirms
An Ohio real estate partnership cannot claim a $22 million charitable tax deduction on a 2016 preservation easement, the Sixth Circuit found, affirming the U.S. Tax Court and Internal Revenue Service's conclusions that the partnership grossly misstated the value of the donated historic building.
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November 06, 2025
Tax Court Says IRS Took Too Long To Ax Easement Deduction
The Internal Revenue Service failed to timely disallow a charitable deduction related to a company's conservation easement donation, the U.S. Tax Court said, throwing out a partnership adjustment by the agency.
Expert Analysis
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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.
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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.