Federal
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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The U.S. Department of Labor's employee benefits arm on Tuesday rescinded guidance from 2021 that warned 401(k) plan managers about the risks of investing in private equity, which comes after an executive order last week that called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.
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August 12, 2025
Pa. Guilty Plea Means Nothing To Malpractice Case, Atty Says
An ex-chief financial officer suing his former attorney for allegedly coercing him into a consent agreement that landed him with an over $12 million judgment has urged a Florida federal court to keep his malpractice case against the attorney on track.
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August 12, 2025
GAO Calls On IRS To Improve Adoption Tax Credit Messaging
The Internal Revenue Service should develop an educational outreach plan for the adoption tax credit, the U.S. Government Accountability Office said after finding many taxpayers may not be aware of the credit or have received unclear information.
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August 11, 2025
Tax Court Backs IRS' Denial Of Whistleblower's Award Bid
A whistleblower was correctly denied an award for information about alleged underpayments by a large multinational corporation, the U.S. Tax Court said Monday, finding the information did not substantially contribute to the IRS' action in the case.
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August 11, 2025
Goodyear Facing Tax Adjustments Over Intercompany IP Sale
Goodyear Tire & Rubber Co. is planning to challenge proposed IRS adjustments that could undermine the company's ability to offset certain taxes related to an intercompany intellectual property sale, according to a U.S. Securities and Exchange Commission filing.
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August 11, 2025
6th Circ. Orders Eaton To Give Employee Records To IRS
The Sixth Circuit affirmed an Ohio federal judge's order requiring Eaton Corp. to share performance evaluations for Ireland-based workers with the IRS, holding that the agency's interest in investigating potential tax liabilities outweighs Ireland's privacy interest, which the court said was "weak" at best.
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August 11, 2025
Kostelanetz Hires Most Recent DOJ Tax Division Leader
The immediate past head of the U.S. Department of Justice's Tax Division will join Kostelanetz LLP as a partner in Washington, D.C., amid a sweeping restructuring that would split the division's criminal and civil tax functions and place them in the department's main branches.
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August 11, 2025
2nd Circ. Affirms Denial Of Partnership's $22.7M Tax Loss
The U.S. Tax Court correctly found the IRS properly denied a Connecticut partnership's $22.7 million loss deduction because the underlying transactions, which involved a Brazilian company, were tantamount to a disguised property sale, the Second Circuit ruled Monday.
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August 11, 2025
40% Of IRS Self-Service Kiosks Not Working, TIGTA Says
Forty of the Internal Revenue Service's 100 self-service kiosks at its taxpayer assistance centers are inoperable, the Treasury Inspector General for Tax Administration said in a report released Monday, blaming the agency's lack of oversight of a contractor that services the kiosks.
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August 08, 2025
DC Circ. Hands Banker's Estate Win In IRS Whistleblower Bid
A split D.C. Circuit sided with the estate of a former banker at Rabobank in ruling Friday that the Internal Revenue Service used the wrong legal standard to deny him an award for contributing to investigations into two companies' tax avoidance scheme.
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August 08, 2025
Trump Ousts IRS Commissioner Weeks After Confirmation
Billy Long has been removed from his role as Internal Revenue Service commissioner after spending just shy of two months as head of the agency, the White House said Friday.
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August 08, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included indexing adjustments for calculating penalties against large employers that don't offer health insurance to their full-time workers or whose full-time workers opt to enroll in government-subsidized health coverage using premium tax credits
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August 08, 2025
Swiss Metals Group Fears US Tariffs' Impact On Gold
The U.S.-imposed 39% tariffs on Switzerland may "negatively impact" gold trading, a Swiss metals association warned Friday.
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August 08, 2025
$47M Fat Brands Tax Case Tossed After DOJ Quits Pursuing It
A California federal judge dismissed an indictment accusing Fat Brands and its founder of hiding $47 million from the IRS through a loan scheme after the U.S. Department of Justice had said the case was no longer a priority.
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August 08, 2025
11th Circ. Vacates Russian Gas Ex-CFO's Tax Crime Sentence
The Eleventh Circuit vacated a Russian former gas executive's seven-year prison term and order to pay $4 million in restitution to the IRS, saying federal prosecutors were wrongly given extra time to bring charges against him for failing to file income tax returns.
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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.
Expert Analysis
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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.
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Firms Still Have Lateral Market Advantage, But Risks Persist
Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
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Making The Opportunity Zones Program Great At Last
As the opportunity zone program approaches its expiration, the Republican-led government could take specific steps to extend and improve the program, address its structural flaws, encourage broader participation and enable it to live up to its promised outcomes, say attorneys at Pillsbury.
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We Must Allow Judges To Use Their Independent Judgment
As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.
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Preparing For Tariffs On Canadian Power In The Northeast
The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.
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Making The Case For Rest In The Legal Profession
For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.
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Mitigating Tariff Risks For Healthcare In US And Canada
Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.