Federal
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July 07, 2025
IRS Didn't Mislead Coke In $2.7B Pricing Case, 11th Circ. Told
The IRS did not lure Coca-Cola to continue using a transfer pricing method only to suddenly declare it unlawful, as the beverage giant claims, the agency told the Eleventh Circuit on Monday in opposing the company's bid to reverse a ruling that added $2.7 billion to its tax bill.
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July 07, 2025
Trump Threatens Extra 10% Tariff On BRICS-Aligned Nations
President Donald Trump threatened an additional 10% tariff on any country aligning with what's known as the BRICS coalition, which includes Brazil, Russia, India and China.
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July 07, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Monday, included an updated list of locations with shuttered coal manufacturing operations, which is used to determine a clean energy development project's eligibility to get a boost in tax credits.
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July 03, 2025
G7 Deal's Details To Dictate How US Cos. Fare Under Pillar 2
Republicans' international tax changes in their major reconciliation bill that passed Thursday raise questions about the U.S. tax system's ability to coexist with the OECD-designed Pillar Two global minimum tax regime.
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July 03, 2025
Top International Tax Cases To Watch In 2nd Half Of 2025
Major multinational corporations such as 3M and Coca-Cola are expected to continue litigating high-stakes international tax cases in the second half of 2025, including disputes that could test the application of the U.S. Supreme Court's ruling that gutted judicial deference to agencies. Here, Law360 looks at seven key cases to follow the rest of the year.
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July 03, 2025
Federal Tax Policy To Watch In The 2nd Half Of 2025
While the extension of the 2017 GOP tax overhaul consumed much of Congress' attention during the first six months of President Donald Trump's second term, lawmakers have other tax issues on their agenda awaiting action. Here, Law360 examines federal tax policy to watch in the second half of the year.
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July 03, 2025
Top Federal Tax Cases To Watch In 2nd Half Of 2025
In the second half of this year, tax professionals will be keeping an eye on suits challenging the IRS' handling of employee retention tax credits and litigation over new microcaptive insurance regulations, as well as disputes over civil fraud penalties. Here, Law360 looks at the top federal tax cases to monitor during the rest of 2025.
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July 03, 2025
Circuit-By-Circuit Recap: Justices Send Message To Outliers
It was a tough term at the U.S. Supreme Court for two very different circuits — one solidly liberal, one solidly conservative — that had their rulings overturned in eye-popping numbers. But it was another impressive year for a relatively moderate circuit that appears increasingly simpatico with the high court.
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July 03, 2025
The Moments That Shaped The Universal Injunction Case
The U.S. Supreme Court voted along ideological lines when it hindered the ability of federal district court judges to issue nationwide pauses on presidential policies, but that outcome didn't seem like a foregone conclusion during oral arguments earlier this year. What do the colloquies suggest about the justices' thinking? Here are some moments that may have swayed them.
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July 03, 2025
Conn. Man Charged In $6.2M Tax Refund Scheme
Federal prosecutors in Connecticut accused a man of using sham trusts to claim $6.2 million in unwarranted tax refunds and bilking the state for unemployment insurance benefits.
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July 03, 2025
Trump Signs Republicans' Massive Tax, Policy Bill Into Law
In a resounding political victory, President Donald Trump signed congressional Republicans' sweeping tax and policy bill the day after the House narrowly passed the Senate's version of the budget legislation.
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July 03, 2025
The Firms That Won Big At The Supreme Court
The number of law firms juggling three or more arguments before the U.S. Supreme Court this past term nearly doubled from the number of firms that could make that claim last term.
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July 03, 2025
Breaking Down The Vote: The High Court Term In Review
The U.S. Supreme Court once again waited until the term's closing weeks — and even hours — to issue some of its most anticipated and divided decisions.
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July 03, 2025
IRS To Nix 83 More Obsolete Guidance Items
Notices on banks' net operating loss and due dates for filing estate tax returns, as well as revenue rulings for collapsible corporations, are among the 83 guidance documents the Internal Revenue Service has identified as unnecessary and up for removal to help simplify tax administration, the agency announced Thursday.
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July 03, 2025
TIGTA Flags Paper-Trail Problems In IRS Seizures Of Crypto
The Internal Revenue Service's Criminal Investigation division does not always follow proper reporting procedures when it seizes digital assets, including leaving key details out of required seizure memorandums or failing to submit those documents entirely, the Treasury Inspector General for Tax Administration said Thursday.
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July 03, 2025
Wiggin And Dana Adds Estate Planning Pro In Connecticut
Wiggin and Dana LLP has grown its estate planning capabilities in Connecticut with the addition of an attorney from Whitman Breed Abbott & Morgan LLC.
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July 02, 2025
Solar Farm Halt Can't Rest On Federal Tax Credits, Judge Says
A federal judge has dismissed a lawsuit seeking to block a NextEra Energy solar farm in Kansas, saying arguments that the project can't receive federal clean energy tax credits until it undergoes an environmental review aren't supported by law.
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July 02, 2025
Tax Court Rejects IRS' Partnership Income Adjustment Regs
The U.S. Tax Court ruled Wednesday that the IRS was too late to adjust a Texas real estate partnership's income under a relatively new centralized audit regime, holding that regulations providing a longer adjustment period had exceeded the agency's rulemaking authority granted by Congress.
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July 02, 2025
Top Federal Tax Policies Of 2025: Midyear Report
At the start of President Donald Trump's second term, the House and Senate invested most of their energy into advancing a budget reconciliation bill that would renew major parts of the 2017 Tax Cuts and Jobs Act and carry out other of Trump's campaign policies. Here, Law360 looks at the most consequential developments in federal tax policy from the first half of 2025.
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July 02, 2025
Financial Analyst Owes Fraud Penalties, Tax Court Says
A financial analyst who ran an information technology business with her husband owes $85,000 in tax fraud penalties after the U.S. Tax Court found Wednesday that she hid income from IRS auditors and misled her accountants.
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July 02, 2025
Top Federal Tax Cases Of 2025: Midyear Report
In the first half of the year, the U.S. Supreme Court barred a defunct transportation company's bankruptcy trustee from clawing back federal taxes and prevented the U.S. Tax Court from reviewing a collection dispute after the IRS stopped going after the underlying debt. In Arizona, a federal judge refused to block the IRS from issuing batch denials of pandemic-era worker credit claims. Here, Law360 reviews some of the top federal court decisions from the past six months.
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July 02, 2025
Tax Court Backs $5M In Penalties On Co.'s Abated Tax Debt
The IRS can collect more than $5 million in tax penalties from a corporation whose underlying tax debt was abated after the agency sent notice to the wrong address, the U.S. Tax Court ruled Wednesday.
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July 02, 2025
Trump Announces Trade Deal With Vietnam
The U.S. government reached a trade deal with Vietnam days before a pause on worldwide tariffs is set to expire, President Donald Trump announced Wednesday.
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July 02, 2025
The Funniest Moments Of The Supreme Court's Term
After justices and oral advocates spent much of an argument pummeling a lower court's writing talents, one attorney suggested it might be time to move on — only to be told the drubbing had barely begun. Here, Law360 showcases the standout jests and wisecracks from the 2024-25 U.S. Supreme Court term.
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July 02, 2025
IRS Sent Wrong Info For 7.2M Student Aid Forms, TIGTA Finds
A design flaw in an Internal Revenue Service system resulted in the agency transmitting incorrect taxpayer information to the U.S. Department of Education related to 7.2 million student aid application forms, the Treasury Inspector General for Tax Administration said Wednesday.
Expert Analysis
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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.
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4 Ways Women Attorneys Can Build A Legal Legacy
This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.
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A Judge's Pointers For Adding Spice To Dry Legal Writing
U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.
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Why NY May Want To Reconsider Its LLC Transparency Law
Against the backdrop of the myriad challenges to the federal Corporate Transparency Act, it may be prudent for New York to reconsider its adoption of the LLC Transparency Act, since it's unclear whether the Empire State's "baby-CTA" statute is still necessary or was passed prematurely, say attorneys at Pillsbury.