Federal
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September 04, 2025
ABA Tax President-Elect Plans To Build On Section's Success
Lisa Zarlenga, a Steptoe LLP partner, is serving as president-elect of the American Bar Association's Section of Taxation for the 2025–2026 term, officially taking on the role this month with the goal of building the strength of the organization for the next generation of tax attorneys. In an interview with Law360, Zarlenga discussed what she enjoys about tax practice, how the section has shaped her career and her vision for strengthening the organization to support future generations of tax attorneys.
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September 04, 2025
PBM Rule Included In DOL Benefits Arm's Regulatory Update
The U.S. Department of Labor's employee benefits arm detailed several new regulations in the works Thursday, including a new fee disclosure rule involving pharmacy benefit managers and plans to revisit retirement plan fiduciary investment advice regulations, according to the administration's latest regulatory update.
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September 04, 2025
Gov't Can Foreclose On Physician's Home Over $2M Tax Debt
A physician and his wife owe more than $2 million in unpaid taxes after failing to file returns for nearly a decade, a Texas federal court found, ruling that the U.S. government can sell the couple's home to help pay the debt.
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September 04, 2025
Gov't Urges Justices To Fast-Track Emergency Tariff Suit
The U.S. Supreme Court must consider under a proposed fast-track schedule the Federal Circuit's finding of President Donald Trump's emergency tariffs as unlawful or jeopardize the recent bilateral trade agreements and the improvements to the U.S. economy as a result of those duties, the administration said.
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September 03, 2025
House Appropriations Panel Advances $2.8B IRS Funding Cut
The House Appropriations Committee approved legislation Wednesday that would cut the Internal Revenue Service's funding by $2.8 billion for the 2026 fiscal year, sending the proposal to the full House for consideration.
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September 03, 2025
11th Circ. Affirms Prison Sentence For False Tax Returns
A Florida tax return preparer who admitted to helping prepare false returns must finish serving more than two years in prison, the Eleventh Circuit ruled Wednesday, rejecting his claim that his employees were to blame.
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September 03, 2025
Northwestern Mutual Seeks $23M Tax Refund For Free Meals
Northwestern Mutual is seeking a refund of $23 million in taxes for on-campus lunches it provided to employees, telling a Wisconsin federal court that the IRS improperly denied the company an exclusion on taxable income for the meals.
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September 03, 2025
Senate To Hold Treasury, IRS Nomination Hearings Next Week
The Senate Finance Committee said Wednesday that it has scheduled nomination hearings for high-ranking officials at the U.S. Department of the Treasury and the Internal Revenue Service for Sept. 10.
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September 03, 2025
Software Co. Founder Fights $100M Tax Bill At 11th Circ.
A software company founder facing more than $100 million in tax debt from his participation in an illegal tax shelter should have been allowed to settle with the Internal Revenue Service for $1.5 million because he can't pay the whole bill, he told the Eleventh Circuit.
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September 03, 2025
Tax Court Must Reconsider Medtronic Pricing, 8th Circ. Says
The U.S. Tax Court should reconsider its use of a hybrid approach for pricing intangibles that Medtronic licensed to a Puerto Rican affiliate, the Eighth Circuit said Wednesday, vacating the ruling and directing the court to revisit the IRS' pricing method.
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September 02, 2025
11th Circ. Affirms Slashing Ex-Braves' $47M Easement Break
A $47 million conservation easement deduction for a partnership founded by two former Atlanta Braves players was overvalued, the Eleventh Circuit affirmed Tuesday, saying none of the partnership's arguments undermined the U.S. Tax Court's finding that the easement property was worth far less than it claimed.
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September 02, 2025
Jury Misled On Tax Fraud Conspiracy Charge, 10th Circ. Rules
The Tenth Circuit overturned Tuesday a conviction against a man who did not report trust income on his personal tax returns, saying the New Mexico district court erred in presenting instructions on the conspiracy charges to both the jury and defendant's counsel.
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September 02, 2025
Firm Urges 2nd Circ. To Review $142M Earnings Boost
A New York investment company has asked the Second Circuit to review a U.S. Tax Court ruling that sustained a $142 million increase to its net earnings and found its principals did not qualify as limited partners for an exception from self-employment income tax.
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September 02, 2025
Most Employers Paid Taxes After COVID Delay, Report Says
Most employers who put off paying Social Security taxes during the pandemic have paid their bills, the Treasury Inspector General for Tax Administration said Tuesday, although some employers who didn't pay were incorrectly charged penalties by the IRS.
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September 02, 2025
IRS Withdraws Rule On Tax Data Use In Passport Revocations
The IRS will scrap a 2018 proposed rule that would have allowed the U.S. State Department to share taxpayer return information with contractors that assist in the revocation or denial of passports of individuals with serious tax debts, the agency announced Monday, calling the rule unnecessary.
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September 02, 2025
Colgate-Palmolive To Shell Out $332M In Pension Payout Fight
Colgate-Palmolive retirees asked a New York federal judge to greenlight a $332 million class action deal in their suit claiming the household products company shorted them on lump-sum retirement payouts, signaling the end of a nearly decade-old case that reached the Second Circuit in 2023.
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August 29, 2025
Split Fed. Circ. Backs Limits On Presidential Tariff Powers
The Federal Circuit held that President Donald Trump's emergency tariffs were improperly imposed under the International Emergency Economic Powers Act, which it said makes no mention of "tariff," "duties" or "tax."
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August 29, 2025
Bookie Who Took Bets From Ohtani Interpreter Gets 1 Year
A resident of Orange County, California, was sentenced to a year and a day in prison on Friday after pleading guilty to operating as an unlicensed bookmaker who placed bets for current and former professional athletes as well as a Japanese language interpreter who is serving time for stealing from baseball megastar Shohei Ohtani.
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August 29, 2025
House Dems Reintroduce Marijuana Legalization Bill Again
Democrats in the U.S. House of Representatives once again reintroduced a federal marijuana legalization bill that previously passed the chamber twice when it was under Democratic control, but has never gained traction in the U.S. Senate or under a majority-Republican House.
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August 29, 2025
Federal Tax Policy To Watch In The Rest Of 2025
As Congress returns to Washington, D.C., after the August recess, the bulk of federal tax policy is expected to focus on funding the IRS past Sept. 30 and getting out guidance for retroactive deductions included in this summer's budget reconciliation bill. Here's a look at federal tax policy to watch during the rest of the year.
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August 29, 2025
Apple Must Hand Swiss User's Records To IRS, Judge Rules
Apple must provide the Internal Revenue Service with a Swiss user's internet and phone records as part of a criminal investigation by Switzerland's taxing authority, a California federal judge ruled, despite the man's protests that the records are unrelated to taxes.
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August 29, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the removal of a method for large-scale clean energy projects to establish eligible construction start dates in order to claim solar and wind tax credits.
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August 29, 2025
Taxation With Representation: White & Case, Paul Weiss
In this week's Taxation With Representation, private equity firm Sycamore Partners completes its $24 billion acquisition of Walgreens Boots Alliance Inc., telecommunications company EchoStar sells wireless spectrum licenses to AT&T and Keurig Dr Pepper acquires JDE Peet's in a deal that aims to create a "global coffee champion."
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August 28, 2025
Coke Says IRS Taking 'Extreme' Position In $2.7B Dispute
The IRS is taking an "extreme" position in its defense of a $2.7 billion tax ruling against Coca-Cola by asserting that the standard prohibiting arbitrary and capricious actions by an agency doesn't apply to it, the company told the Eleventh Circuit.
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August 28, 2025
6th Circ. Affirms Dismissal Of Meritless Tax Challenge
The Sixth Circuit affirmed the dismissal of a Tennessee man's suit against the Internal Revenue Service, ruling Wednesday that his challenge to the agency's tax collections was meritless and provided no basis for federal jurisdiction.
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.