Federal
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June 06, 2025
The Tax Angle: IRS Funding, Budget Markup, Insurance Woes
From a look at upcoming Senate hearings on President Donald Trump's funding plans for the IRS to a potential markup of Republicans' $3.8 trillion budget reconciliation bill and the continuing crisis in homeowner insurance, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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June 06, 2025
8th Circ. Rejects Farm Leasing Co.'s Switch To Amortization
The Eighth Circuit denied an Arkansas farm leasing company's action to amortize federal subsidy-eligible land to reduce its tax liability, affirming Friday that the company was not authorized to make such accounting changes without approval from the Internal Revenue Service.
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June 06, 2025
11th Circ. Limits Easement Tax Break Tied To Failed Project
A Georgia partnership that formed after the failure of a resort development and donated a conservation easement in exchange for a tax break cannot take an $8.9 million deduction for the property's fair market value because the land was considered inventory, the Eleventh Circuit said Friday.
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June 06, 2025
Facebook Ruling Casts Uncertainty On Cost-Share Disputes
The U.S. Tax Court recently rejected Facebook's challenge to regulations that determine the buy-in payment for affiliated companies to share the costs of developing intangibles, raising questions about objections to similar rules by pharmaceutical multinationals.
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June 06, 2025
Taxation With Representation: Winston, Stibbe, Weil, Goodwin
In this week's Taxation With Representation, Chart Industries Inc. and Flowserve Corp. merge, Aedifica NV and Cofinimmo NV unite, Sanofi buys Blueprint Medicines Corp., and Kimberly-Clark Corp. sells a majority stake in its international tissue business to Suzano.
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June 06, 2025
Lobbyist Seeks No Prison After Admitting $1.3M Tax Evasion
A Miami lobbyist who admitted to evading $1.3 million in taxes asked a Florida federal court not to sentence him to prison, saying he reported his tax obligations in full, even for the years when he didn't pay, and was overwhelmed by family expenses.
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June 06, 2025
PE Firms Are Top Opportunity Zone Investors, Report Finds
A group tracking private equity activity said each of the 15 largest investors in the federal opportunity zone program are private equity firms, with Salt Lake City, Utah-based Bridge Investment Holdings topping the list with $3.7 billion in opportunity zone funds.
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June 05, 2025
'Sparse' OPM Record On Mass Firings Backs Win, Unions Say
A "sparse and self-serving" record provided by the U.S. Office of Personnel Management still shows the agency unlawfully directed federal agencies to fire probationary employees en masse, so a California federal court can reach a final decision now and "unwind" those terminations, a coalition including unions and advocacy groups said Thursday.
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June 05, 2025
Texas Plastics Co. Challenges IRS Over Microcaptive Rules
A Texas plastics company sued the IRS over regulations flagging microcaptive insurance plans as potentially abusive tax avoidance schemes, telling a Texas federal court that the agency exceeded its authority by imposing broad disclosure requirements that could penalize even legitimate arrangements.
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June 05, 2025
Ex-Atty Says IRS Suit Over Property Sale Tactic Is Retaliatory
A former attorney has asked an Idaho federal court to toss the government's suit accusing him and his company of promoting an abusive tax scheme, arguing that the underlying property sale transactions were above board but the government targeted him as punishment for suing the IRS and to gain backdoor access into confidential business records.
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June 05, 2025
Tax Court Upholds IRS' Proposed Tax Levy Against Neb. Man
The Internal Revenue Service did not abuse its discretion when sustaining a proposed levy against a Nebraska man aimed at collecting unpaid assessments for the 2006 and 2007 tax years, the U.S. Tax Court said Thursday, supporting the agency's determination.
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June 05, 2025
'Longtime Tax Protester' Must Pay On $226K In Income
A Texas man characterized by the U.S. Tax Court as a "longtime tax protester" was incorrect when he claimed his more than $226,000 in wages and retirement distributions aren't taxable, a judge ruled Thursday, also hitting him with a penalty.
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June 05, 2025
Trump Expects China Trade Talks To Resume After Xi Phone Call
President Donald Trump said he and Chinese President Xi Jinping spoke over the phone Thursday about an impasse in ongoing trade talks over U.S. claims China was slow-walking the exports of rare earths, with Trump saying he expects meetings between the countries' negotiating teams to resume.
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June 05, 2025
9th Circ. Backs Denial Of Biz Owner's Bad Debt Deduction
A businessman cannot take a worthless debt deduction for millions of dollars he transferred between his companies and said were loans, the Ninth Circuit said Thursday, affirming a U.S. Tax Court ruling that he owed more than $5 million in taxes.
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June 05, 2025
'Survivor' Winner Ordered To Pay $3.3M Tax Bill
The first winner of reality competition show "Survivor" must pay his $3.3 million tax bill, but the government is not allowed to enforce tax liens by forcing the sale of two properties, a Rhode Island federal court ruled Thursday.
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June 05, 2025
KFC Parent Co. Fights $4B IRS Bill In Tax Court
The parent company of Pizza Hut, KFC and Taco Bell is challenging $2.5 billion in taxes and penalties that the IRS claims it owes for a corporate reorganization to restructure its international operations, according to a U.S. Tax Court petition served Thursday, a figure that has topped $4 billion with interest.
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June 05, 2025
Justices Fault Wis. For Denying Tax Break To Charities
Wisconsin discriminated against a group of Catholic charities when it denied them an unemployment tax exemption, the U.S. Supreme Court said Thursday, rejecting the state's argument that the charities were not operated primarily for religious purposes.
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June 04, 2025
Cheesesteak Icon Asks 3rd Circ. If Loper Bright Slices Sentence
Counsel for a Philadelphia cheesesteak shop owner seeking a lighter sentence for paying employees off the books told the court Wednesday that he has asked the Third Circuit to consider how the U.S. Supreme Court's landmark decision striking longstanding agency deference framework might affect his case.
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June 04, 2025
NJ Man Cops To Dodging $2M Tax Bill On Real Estate
A New Jersey man linked to an intricate pension plan scheme involving refunds from the Dutch government pled guilty to evading more than $2.4 million in U.S. taxes by concealing ownership of more than $5.5 million in real estate, the U.S. Department of Justice said Wednesday.
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June 04, 2025
Trump Ordered To Explain Why Layoffs Don't Flout Injunction
A California federal judge ordered the Trump administration Wednesday to explain why preparations for layoffs at the State Department and Department of Housing and Urban Development do not violate an injunction she issued last month, saying she needed more details about the agencies' plans to evaluate their compliance.
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June 04, 2025
Biz Groups Urge US To Pressure Canada To Drop Digital Tax
A coalition of business lobbying groups have urged the U.S. government to take "decisive action" against Canada's digital services tax before the June 30 payment deadline, contending that the levy will cost U.S. companies about $2 billion this year.
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June 04, 2025
Senate May Clash With House On SALT Cap, Energy Credits
Senate Republicans are working to finalize the chamber's version of the House's nearly $4 trillion tax bill, and the Senate's bill is likely to conflict with the House's over proposed changes to the state and local tax deduction and green energy credits.
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June 04, 2025
Tax Court Rejects Frivolous Wage Classification Argument
A woman's wages from her job at Fidelity Investments should have been reported as income on her and her husband's joint tax return, the U.S. Tax Court affirmed Wednesday, upholding the IRS' deficiency finding and also hit the couple with a penalty.
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June 04, 2025
Mother-Son Car Co. Owners Owe Penalties, Tax Court Says
A mother and son who owned a used car business owe tax penalties for failing to report corporate dividends, the U.S. Tax Court ruled Wednesday, saying the pair couldn't back up their claim that the state of California had seized the records they needed to defend themselves.
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June 04, 2025
Satellite Co. Execs Released In $250M Fraud, Evasion Case
Two more satellite company executives facing charges of tricking investors out of $250 million are being released after their leader, who was additionally accused of tax crimes, was deemed a flight risk, according to D.C. federal court documents.
Expert Analysis
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How BigLaw Executive Orders May Affect Smaller Firms
Because of the types of cases they take on, solo practitioners, small law firms and public interest attorneys may find themselves more dramatically affected by the collective impact of recent government action involving the legal industry than even the BigLaw firms named in the executive orders, says Reuben Guttman at Guttman Buschner.
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Lawsuits Shouldn't Be Shadow Assets For Foreign Capital
Third-party litigation financing amplifies inefficiencies from litigation and facilitates national exposure to foreign influence in the U.S. justice system, so full disclosure of financing arrangements should be required as a matter of institutional integrity, says Roland Eisenhuth at the American Property Casualty Insurance Association.
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How To Accelerate Your Post-Attorney Career Transition
Professionals seeking to transition to nonattorney careers may encounter skepticism as nontraditional candidates, but there are opportunities for thought leadership and to leverage speaking and writing to accelerate a post-attorney career transition, say Janet Falk at Falk Communications and Evgeny Efremkin at Toronto Metropolitan University.
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Tariffs And FCA Create Perfect Storm For Importers
The Trump administration's aggressive tariff policies pose a high risk to certain importation practices that are particularly likely to trigger False Claims Act enforcement, say attorneys at Jeffer Mangels.
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US Reassessment Of OECD Tax Deal Is Right Move
The wholesale U.S. reevaluation of the Organization for Economic Cooperation and Development's global tax deal ordered by President Donald Trump is a positive step that could ultimately create a more durable international tax system, says Anne Gordon at the National Foreign Trade Council.
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Measuring And Mitigating Harm From Discriminatory Taxes
In response to new tariffs and other recent "America First Trade Policy" pronouncements, corporations should assess and take steps to minimize their potential exposure to discriminatory and reciprocal tax measures that are likely to come, say economists at Charles River Associates.
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Adapting To Private Practice: From DOJ Leadership To BigLaw
The move from government service to private practice can feel like changing one’s identity, but as someone who has left the U.S. Department of Justice twice, I’ve learned that a successful transition requires patience, effort and the realization that the rewards of practicing law don’t come from one particular position, says Richard Donoghue at Pillsbury.
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How The CRE Industry Is Adapting To Tariff Uncertainty
Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.
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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.