Federal
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July 18, 2025
Western Union Says IRS Used Flawed Rule To Hike Income
The Internal Revenue Service erroneously included more than $8.2 million in foreign income in Western Union Co.'s foreign tax calculation based on an agency rule that was passed without properly notifying the public, the company told the U.S. Tax Court.
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July 18, 2025
Taxation With Representation: Wachtell, Slaughter And May
In this week's Taxation With Representation, Blackstone pours billions into data centers and related infrastructure, Waters Corp. and Becton Dickinson look to form a new life sciences powerhouse, Reckitt sells 70% of its Essential Home business to private equity firm Advent, and Chevron completes its acquisition of Hess following a favorable arbitral award.
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July 18, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the withdrawal of plans to eliminate a safe harbor that allows some businesses an expanded use of net operating losses.
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July 18, 2025
IRS Issues 2026 Table For Premium Tax Credit Calculations
The Internal Revenue Service published the table used to determine the 2026 premium tax credit Friday.
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July 17, 2025
Canada Mulling Changes To Ability To Rewrite Transactions
Canada's Department of Finance is considering changes to legislation that outlines the tax authority's power to recharacterize transactions set forth in contracts between related parties when their behavior doesn't match what the contract says, an official said Thursday.
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July 17, 2025
IRS Leaker Asks DC Circ. To Bar Comments By Ex-Employer
A tech worker appealing a five-year sentence for leaking tax returns while on the job at the IRS through contractor Booz Allen asked the D.C. Circuit on Thursday to block his former employer from weighing in, saying the company's opinion that he should finish his prison term is irrelevant.
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July 17, 2025
5th Circ. Affirms Nix Of Doctor's Captive Insurance Deductions
The owner of a Texas urgent care network is not entitled to $1 million in tax deductions for insurance premiums he paid to inside companies, the Fifth Circuit ruled, affirming the U.S. Tax Court's decision that the payments were not actually for insurance.
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July 17, 2025
US Challenge To Belgian Minimum Tax Rules Heads To ECJ
A Belgian court said Thursday it has asked the European Union's highest court to weigh in on a U.S. industry group's challenge to the country's global minimum tax rules.
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July 17, 2025
GAO Urges IRS To Hone Method For Gauging Better Service
The Internal Revenue Service should establish an evidence-based approach to assessing the results of its efforts to improve taxpayers' experience with the agency, the U.S. Government Accountability Office said Thursday.
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July 16, 2025
Attys Tout 3 Real Estate Investment Wins In Federal Budget
Real estate investors can breathe a collective sigh of relief seeing the final version of the "One, Big, Beautiful Bill Act" that President Donald Trump signed into law this month, as it is largely favorable to the industry and keeps several much-admired tax breaks alive.
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July 16, 2025
House Panel Urged To Modernize Tax Rules For Digital Assets
Congress needs to create tax rules for digital assets such as cryptocurrency and nonfungible tokens because the current regime is burdensome for businesses and pushing development out of the U.S., industry representatives told a House Ways and Means Committee subcommittee Wednesday.
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July 16, 2025
OECD Mulling Tweaks To Arm's-Length Range Guidance
The Organization for Economic Cooperation and Development's guidance on the arm's-length range is an area ripe for simplification because the resources needed to calculate and make adjustments to the range are sometimes out of proportion with the amount in dispute, an official said Wednesday.
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July 16, 2025
No Tax Refund For Uncashed Retirement Checks, IRS Says
The Internal Revenue Service said Wednesday that an employer administering a retirement plan cannot get a tax refund or tax adjustment when it cuts a distribution check to an individual who had not made a withholding election and did not cash the check.
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July 16, 2025
Tax Losses Back Retired Prof's FBAR Penalties, US Says
A retired professor's admission in U.S. Tax Court that his failure to report his foreign bank accounts caused tax losses shows that a California federal court should affirm tax penalties against him of more than $400,000, the U.S. government said.
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July 16, 2025
Speaker's Aide Won't Rule Out 'Secure 3.0' Retirement Bill
An aide to House Speaker Mike Johnson told tax attorneys in Washington, D.C., Wednesday that he's not ruling out Congress passing a retirement policy overhaul that's known informally as Secure 3.0, though exact timing on such an effort remains unclear because of the busy year-end schedule.
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July 16, 2025
Cheesesteak Maker Gets 2 Mos. Sliced From Prison Sentence
A member of the family behind the popular Tony Luke's cheesesteak shop in South Philadelphia was re-sentenced Wednesday to 18 months in prison, marking a two-month reduction of the original term he'd received for paying employees under the table.
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July 15, 2025
Trump Admin Seeks Win In Harvard $2B Funding Freeze Case
The Trump administration urged a Massachusetts federal judge Monday to grant it summary judgment in Harvard University's lawsuit challenging the government's effort to freeze $2.2 billion in funding, arguing the dispute is a contract fight that belongs in the Federal Claims Court and the allegations fail on the merits.
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July 15, 2025
Trump Says US Has Struck Trade Deal With Indonesia
President Donald Trump announced Tuesday that the U.S. has reached a trade deal with Indonesia that includes a 19% tariff on all goods exported by the Southeast Asian country to the U.S., while American goods exported there will be free of tariffs.
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July 15, 2025
IRS Rates Dip Slightly In August After July Rebound
Applicable federal rates for income tax purposes are set to decline in August, easing slightly after July's increases, the Internal Revenue Service said Tuesday.
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July 15, 2025
Tax Return Preparer Cops To Role In $25M Fraud Scheme
A tax return preparer pled guilty in a California federal court for his role in a fraud scheme that involved submitting fake federal income tax returns to claim $25 million in refunds.
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July 15, 2025
Tax Court Warns Attys In Denying $20M Easement Deduction
The U.S. Tax Court threatened Tuesday to force attorneys for a Georgia partnership to personally pay court costs after they had argued at trial for a $20 million tax deduction for a conservation easement donation, an amount the court said was over 100 times the land's value.
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July 15, 2025
Tax Court Denies Exclusion To Reduce Estate's Value
The estate of one deceased spouse did not file its return in time for the estate of another deceased spouse to use an exclusion to reduce the value of the second estate, the U.S. Tax Court said in a decision Tuesday.
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July 15, 2025
Tax Court Denies Equitable Tolling To Firm In Collection Action
A North Dakota law firm that convinced the U.S. Supreme Court three years ago that federal courts can extend equitable tolling for nonjurisdictional deadlines was not able to sway the U.S. Tax Court to extend the time for the firm to file a collection action case against the IRS, according to a bench opinion.
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July 15, 2025
IRS Updates Corp. Bond Monthly Yield Curve For July
The Internal Revenue Service updated Tuesday the corporate bond monthly yield curve used in calculations for defined benefit plans for July, as well as corresponding segment rates and other related provisions.
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July 15, 2025
IRS To Provide Transition Relief For Tips And OT Tax Breaks
The IRS will provide guidance for new deductions for tips, overtime pay and car loan interest that will include transition relief for taxpayers claiming those deductions and employers subject to associated reporting requirements, according to a fact sheet released by the agency.
Expert Analysis
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Tariff Strategies For The US Renewable Energy Sector
The Trump administration's tariff actions over the last few months are challenging for the renewable energy industry — but there are strategies for contending with the uncertainty, including diversifying supply chains, seeking certification about equipment origins, and adding tariff-related language to supply contracts and offtake agreements, say attorneys at Sheppard Mullin.
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Ch. 7 Marshaling Ruling Rests On Shaky Legal Grounds
In its recent holding in a Chapter 7 bankruptcy case that marshaling may not be applied against the IRS, a Texas federal court misapplied a bankruptcy code section and case law, leaving a draconian decision that could limit the scope of a powerful equitable estate tool, says Brian Shaw at Cozen O'Connor.
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3 Tax Issues Manufacturers Should Watch In 2025 Budget Bill
As Congress works toward a budget reconciliation bill, manufacturing companies should keep a keen eye on proposals to change bonus depreciation, the qualified business income deduction and energy tax credits, which could have a significant impact on capital-intensive industries, say attorneys at Frost Brown Todd.
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$38M Law Firm Settlement Highlights 'Unworthy Client' Perils
A recent settlement of claims against law firm Eckert Seamans for allegedly abetting a Ponzi scheme underscores the continuing threat of clients who seek to exploit their lawyers in perpetrating fraud, and the critical importance of preemptive measures to avoid these clients, say attorneys at Lockton Companies.
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Jurisdictional Issues At Play In 9th Circ.'s FCA Trade Case
A decision by the Ninth Circuit in Island Industries v. Sigma Corp. could result in the U.S. Court of International Trade’s exclusive jurisdiction over trade-related FCA cases, a big shift in the enforcement landscape just as tariffs take center stage in trade policy, say attorneys at Haynes Boone.
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Evolving Federal Rules Pose Further Obstacles To NY LLC Act
Following the Financial Crimes Enforcement Network's recent changes to beneficial ownership information reporting under the federal Corporate Transparency Act — dramatically reducing the number of companies required to make disclosures — the utility of New York's LLC Transparency Act becomes less apparent, say attorneys at Pillsbury.
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Alternative Business Structures Raise Ethics Questions
The new KPMG law firm, launched in Arizona following that state's repeal of the prohibition on fee sharing with nonlawyers, raises a number of important practice questions, both for the firm and those law firms seeking to partner with it, says Deborah Winokur at Cozen O’Connor.
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The IRS Shouldn't Go To War Over Harvard's Tax Exemption
If the Internal Revenue Service revokes Harvard's tax-exempt status for violating established public policy — a position unsupported by currently available information — the precedent set by surviving the inevitable court challenge could undercut the autonomy and distinctiveness of the charitable sector, says Johnny Rex Buckles at Houston Law Center.
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Mitigating Import Risks Around Southeast Asian Solar Cells
The U.S. Department of Commerce's recent final determinations in its antidumping and countervailing duty investigations into solar cells produced in certain Southeast Asian countries make it important for U.S. purchasers to consider risk mitigation strategies, including modifying supply chains and contractually assigning import responsibilities, say attorneys at Morgan Lewis.
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Reassessing Corporate Separateness After Explosion Of LLCs
Following the dramatic increase of limited liability companies in the U.S., the Corporate Transparency Act's enactment and the Trump administration's subsequent narrowing of that law, it's worth revisiting the underlying legal principles that govern shell companies in order to remedy the problems that initially motivated the CTA, says Jeff Newton at Omni Bridgeway.
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Crisis Management Lessons From The Parenting Playbook
The parenting skills we use to help our kids through challenges — like rehearsing for stressful situations, modeling confidence and taking time to reset our emotions — can also teach us the fundamentals of leading clients through a corporate crisis, say Deborah Solmor at the Wisconsin Alumni Research Foundation and Cara Peterman at Alston & Bird.
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Immunity Waiver Ruling A Setback For Ch. 7 Trustees
While governmental units should welcome the U.S. Supreme Court's recent decision in U.S. v. Miller restricting the reach of the Bankruptcy Code's sovereign immunity waiver, Chapter 7 trustees now have a limited ability to maximize bankruptcy estates, says Dan Prieto at Jones Day.
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Adapting To Private Practice: From NY Fed To BigLaw
While the move to private practice brings a learning curve, it also brings chances to learn new skills and grow your network, requiring a clear understanding of how your skills can complement and contribute to a firm's existing practice, and where you can add new value, says Meghann Donahue at Covington.