Federal
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November 03, 2025
'No Basis In Reality' In $10M Easement Claim, Tax Court Says
A U.S. Tax Court judge rejected a partnership's claim that its donation of a conservation easement over 200 acres in Georgia was worth a $10 million tax deduction, saying in an opinion Monday that it "has no basis in reality."
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November 03, 2025
2 Doctrines Likely To Direct Justices' Review Of Trump Tariffs
When the U.S. Supreme Court hears oral arguments Wednesday over whether President Donald Trump can impose tariffs under the International Emergency Economic Powers Act, it will likely test two doctrines the justices have recently considered: the major questions and nondelegation doctrines.
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November 03, 2025
Tribes Push Supreme Court To Overturn Okla. Tax Ruling
The Oklahoma Supreme Court incorrectly ruled that a member of the Muscogee Creek Nation owes Oklahoma income tax, groups representing Native American tribes told the U.S. Supreme Court, asking the justices to hear the case and reverse the ruling.
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November 03, 2025
Veteran Tax Controversy Atty Moves Team To Kostelanetz
A longtime New Jersey tax attorney and three of his associates have joined Kostelanetz LLP, the boutique tax firm announced Monday, saying it expected them to bolster its tax controversy practice and add to its commitment to volunteer work and legal education.
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October 31, 2025
Int'l Tax In October: Deal With China, Halt To Canada Talks
A tentative deal to reduce American tariffs on Chinese goods, ruptured trade talks between the U.S. and Canada, court defeats for the Danish and U.S. tax administrations and an end to the European Union's plan for a financial transaction tax topped the list of international tax news in October. Here, Law360 looks at the biggest developments from the past month.
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October 31, 2025
Twin Peaks Lender Says Developer Defaulted On $12M Loan
A Florida franchisee group is suing a developer in state court over a $12 million loan to build two Twin Peaks restaurants in an EB-5 visa program, alleging the developer defaulted on the note and then told the IRS that it converted the loan into equity interest.
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October 31, 2025
Up Next At High Court: Tariffs, Fugitives & Contractor Liability
The U.S. Supreme Court will begin its November oral argument session Monday, during which the justices will consider President Donald Trump's authority to impose tariffs on foreign countries under an emergency statute, whether military contractors can be held liable for alleged breaches of contracts in war zones, and if there are time limits for litigants who want to vacate a void judgment. Here, Law360 breaks down the week's oral arguments.
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October 31, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the continued monthslong slide in applicable federal rates for income tax purposes.
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October 31, 2025
Taxation With Representation: Skadden, Davis Polk
In this week's Taxation With Representation, American Water Works Co. and Essential Utilities announce a merger, semiconductor companies Skyworks and Qorvo combine to create an industry giant, and Terex Corp. and REV Group team up to form a specialty equipment manufacturer.
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October 31, 2025
Ruling Dispute In Limbo As 6th Circ. Rebuffs Shutdown Pause
The Sixth Circuit denied a federal government attorney's request to pause a closely watched case about a U.S. Tax Court filing deadline after he told the court he was barred from working during the shutdown, leaving his plan to request a rehearing in limbo.
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October 30, 2025
Trade Deals At Risk In Trump Tariff Case, Feds Tell Justices
The federal government told the U.S. Supreme Court on Thursday that President Donald Trump's global tariffs have led to significant trade deals addressing the underlying national emergencies he declared, and a ruling determining them unlawful would prove catastrophic.
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October 30, 2025
China Delays Expanded Mineral Export Controls, Trump Says
China has agreed to delay for a year an expansion to export controls for key minerals and is set to start purchasing more U.S. agricultural products including soybeans, while U.S. tariffs on Chinese goods will decrease 10%, President Donald Trump said early Thursday morning.
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October 30, 2025
Kansas Doctor Loses Collection Dispute In Tax Court
The U.S. Tax Court upheld Thursday an Internal Revenue Service action to collect nearly $730,000 from a Kansas-based doctor with years of unpaid taxes, finding that her silence on the agency's judgment request prompted the decision.
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October 30, 2025
Senate Votes To Ax Global Tariffs, But House Path Blocked
The Senate passed legislation Thursday to end the declared national emergency propping up President Donald Trump's global tariff regime shortly after passing similar bills regarding tariffs on Canada and Brazil, though the House previously moved its deadline for action on the matter to next year.
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October 30, 2025
IRS Discloses Record In ICE Data Sharing Case
The IRS, following a judge's order, has released its administrative record in a lawsuit over its agreement to share taxpayer information with federal immigration authorities, including emails in which officials discuss U.S. Immigration and Customs Enforcement's request for information on nearly 1.3 million taxpayers.
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October 30, 2025
Pa. Couple Ordered To Pay $1.77M IRS Debt
A Pennsylvania couple who purchased a Maserati and a Porsche and took trips to international destinations while owing the Internal Revenue Service $1.77 million must pay those tax debts, a Pennsylvania federal judge ruled Thursday, adopting a magistrate judge's report.
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October 30, 2025
Sidley's 'Incomplete' Story Hid Fraud Scheme, Family Says
A family alleging it was roped into an illegal tax sheltering scheme on the advice of a former Sidley Austin LLP attorney has urged a Georgia federal judge to keep its suit against the firm alive, arguing a jury should decide when the family knew enough about the fraud to move forward with its claims.
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October 30, 2025
3rd Circ. Affirms Tax On Interest In $191M Pharma Family Feud
A pharmaceutical company's $191 million payment settling a family feud was for the sale of a family trust's ownership shares and included interest taxed as ordinary income, the Third Circuit said Thursday, rejecting the trust's claim that the money should be taxed at the lower, capital gains rate.
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October 29, 2025
Tax Atty Group Backs Fund Manager's $1.9M Refund Bid
A tax attorneys professional association told the Eleventh Circuit that a Florida district court improperly blocked a fund manager and his wife's appeal to receive a $1.9 million tax refund under a rule that bars taxpayers from making new claims in federal court.
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October 29, 2025
Senate Backs Axing Brazil Tariffs, But House Vote Blocked
The Senate voted to end a declared national emergency underpinning U.S. tariffs placed on Brazil for the prosecution of its former president over an attempted coup, but the House has delayed a statutory requirement to expedite accompanying legislation.
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October 29, 2025
Partnership Challenges Nix of $4.5M Easement Deduction
The Internal Revenue Service relied on an audit report that failed to meet the requirements of the Administrative Procedure Act when it rejected a partnership's $4.5 million tax deduction for donating a conservation easement across more than 50 acres in Tennessee, the partnership told the U.S. Tax Court as it challenged the rejection.
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October 29, 2025
Fla. Challenges 'Special' Calif. Tax Rule At Supreme Court
Florida on Tuesday took steps to sue California in the U.S. Supreme Court, seeking to strike down a California taxation rule as unconstitutional for allegedly discouraging companies from relocating or operating outside the Golden State.
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October 29, 2025
7th Circ. Skeptical Of Bid To Toss Ex-Atty's Bribery Conviction
Judges on a Seventh Circuit panel appeared doubtful Wednesday of a former attorney's contention that he never bribed ex-Chicago Alderman Ed Burke and was merely seeking to hire him for a legal matter.
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October 29, 2025
IRS Wrongly Nixed Insurance Transactions, Tax Court Told
A Tennessee company that claims to provide in-house insurance to businesses supporting the U.S. Department of Defense and NATO has challenged more than $500,000 in tax liabilities and the IRS' denial of its status as an insurer, according to a U.S. Tax Court petition.
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October 29, 2025
Publix Heiress Asks To Quash IRS Summons For Bank Info
An heiress to the Publix grocery store chain asked a Florida federal court to quash an IRS summons seeking her bank information on behalf of Italian tax officials, arguing that the agency's request flouts the Italy-U.S. tax treaty.
Expert Analysis
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What's Next For Accounting Enforcement After SEC's Big 2024
The U.S. Securities and Exchange Commission under the Trump administration will likely continue to focus enforcement efforts on many of the same accounting and auditing issues that it pursued over the past year — but other areas, such as ESG, internal controls and cryptocurrency cases, may fall out of focus, say attorneys at Debevoise.
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Mentorship Resolutions For The New Year
Attorneys tend to focus on personal achievements or career milestones when they set yearly goals, but one important area often gets overlooked in this process — mentoring relationships, which are some of the most effective tools for professional growth, say Kelly Galligan at Rutan & Tucker and Andra Greene at Phillips ADR.
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Coaching Little League Makes Me A Better Lawyer
While coaching poorly played Little League Baseball early in the morning doesn't sound like a good time, I love it — and the experience has taught me valuable lessons about imperfection, compassion and acceptance that have helped me grow as a person and as a lawyer, says Alex Barnett at DiCello Levitt.
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5 Litigation Funding Trends To Note In 2025
Lawyers and their clients must be prepared to navigate an evolving litigation funding market in 2025, made more complicated by a new administration and the increasing overall cost of litigation, says Jeffery Lula at GLS Capital.
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Rethinking Litigation Risk And What It Really Means To Win
Attorneys have a tendency to overestimate litigation risk before summary judgment and underestimate risk after it, but an eight-stage litigation framework can clarify risk at different points and help litigators reassess what true success looks like in any particular case, says Joshua Libling at Arcadia Finance.
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Small Biz Caught In Corporate Transparency Act Crossfire
Despite compliance being put on hold due to a nationwide preliminary injunction, small businesses have been caught in the middle of the legal battle over the Corporate Transparency Act — and confusion over the law's requirements could result in major penalties, say attorneys at Snell & Wilmer.
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No, Litigation Funders Are Not 'Fleeing' The District Of Del.
A recent study claimed that litigation funders have “fled” Delaware federal court due to a standing order requiring disclosure of third-party financing, but responsible funders have no problem litigating in this jurisdiction, and many other factors could explain the decline in filings, say Will Freeman and Sarah Tsou at Omni Bridgeway.
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Hydrogen Regs Will Provide More Certainty — If They Survive
Newly finalized regulations implementing the Section 45V clean hydrogen tax credit allow producers more flexibility, and should therefore help put the industry on more solid footing — but the incoming Trump administration and Republican Congress will have multiple options for overturning or altering the regulations, say attorneys at Steptoe.
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5 E-Discovery Predictions For 2025 And Beyond
In the year to come, e-discovery will be shaped by new and emerging trends, from the adoption of artificial intelligence provisions in protective orders, to the proliferation of emojis as a source of evidence in contemporary litigation, say attorneys at Littler.
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What's Ahead As Transparency Act Comes To A Crossroads
Synthesizing the contrasting federal district and appellate court rulings on the Corporate Transparency Act’s validity reveals several main areas of debate that will likely remain at issue as challenges to the law continue winding through the courts, say attorneys at Farella Braun.
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Final Hydrogen Tax Credit Regs Add Flexibility For Producers
The recently released final regulations implementing the Inflation Reduction Act's clean hydrogen production tax credit offer taxpayers greater flexibility, reducing risk and creating more certainty for investments in the industry, thus diminishing — but not eliminating — the risk of legal challenges to the regulations, say attorneys at Steptoe.
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5 Evolving Concerns For Family Offices In 2025
Complex regulatory changes and emerging operational risks will force family offices to stay on their toes in 2025, with timely action particularly necessary to address several tax and reporting developments that may affect their investments and business operations, say attorneys at Morgan Lewis.
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7 Ways 2nd Trump Administration May Affect Partner Hiring
President-elect Donald Trump's return to the White House will likely have a number of downstream effects on partner hiring in the legal industry, from accelerated hiring timelines to increased vetting of prospective employees, say recruiters at Macrae.