Federal
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July 22, 2025
IRS Workforce Has Nosedived 25% Since February
More than 25,000 Internal Revenue Service employees have left since February, a 25% overall reduction in staff driven mostly by workers who took a downsizing deal allowing them to resign while still being paid, the Treasury Inspector General for Tax Administration said Tuesday.
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July 22, 2025
US Expatriations Over 1,000 Again In 2nd Quarter
While about 200 fewer people expatriated from the U.S. in the second quarter of 2025 compared with the first quarter, the number still totaled above 1,000, the Internal Revenue Service said Tuesday.
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July 21, 2025
Tax-Lien Biz Atty Tells Jury He Didn't Seek To Dupe Lender
Counsel for a former compliance lawyer accused of pilfering from a $20 million line of credit extended to his tax-lien investment firm told a Manhattan federal jury Monday that the defendant was "sloppy," but never intended fraud.
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July 21, 2025
9th Circ. Urged To Rethink Denial Of Bad Debt Deduction
A business owner asked the Ninth Circuit to rethink its denial of his $86 million bad debt deduction, saying the court dismissed thousands of pages of exhibits in concluding that his debt arose from loans between his companies and was not actually worthless.
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July 21, 2025
Captive's Premium Payments Are Income, Tax Court Says
A captive insurance company must recognize $782,000 it received in premium payments as income, the U.S. Tax Court said Monday in clarifying that shareholders in a California company cannot deduct their premium payments to the insurer because the arrangement was not really for insurance.
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July 21, 2025
Wis. Homeowners Lack Basis For Tax Burden Suit, Court Told
A Wisconsin county, town and tribal school district pushed a federal court to throw out a suit by homeowners who claim the government entities have conspired to expand the Menominee Indian Tribe's holdings of tax-exempt land and increase taxpayers' burden, saying the homeowners lacked standing.
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July 21, 2025
Charitable Deduction Lacked Dates, Amounts, Tax Court Says
A Washington state man was not entitled to deduct the value of his donations to charity because he did not provide receipts identifying the donated items and their values, the U.S. Tax Court ruled Monday.
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July 21, 2025
House Subcommittee Advances $2.8B IRS Funding Cut
The Internal Revenue Service's funding would be cut by $2.8 billion for the 2026 fiscal year under legislation advanced Monday by a House Appropriations subcommittee.
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July 21, 2025
Rising Star: Davis Polk's Aliza Slansky
Aliza Slansky of Davis Polk & Wardwell LLP is lead counsel in Sycamore Partners' $23 billion acquisition of Walgreens Boots Alliance and advised Missouri tech company Emerson on a series of multibillion-dollar sales, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 21, 2025
Strict Construction Rules Could Gut Solar, Wind Credits
The U.S. Treasury Department could severely weaken the availability of the solar and wind energy tax credits that were scaled back under Republicans' new budget law with upcoming guidance that may upend long-standing construction rules used to determine eligibility.
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July 21, 2025
Paul Hastings Boosts Tax Team In NY With Ex-Kirkland Atty
Paul Hastings LLP announced Monday that a former Kirkland & Ellis LLP attorney is bringing her tax practice to its New York office in a move the firm says will bolster its ability to guide clients through complex deals like mergers, acquisitions and private equity transactions.
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July 18, 2025
Law360 Names 2025's Top Attorneys Under 40
Law360 is pleased to announce the Rising Stars of 2025, our list of more than 150 attorneys under 40 whose legal accomplishments belie their age.
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July 18, 2025
Judge Demands Layoff Plans From Trump Administration
A California federal judge on Friday ordered the Trump administration to hand over reorganization and reduction-in-force plans linked to an executive order directing layoffs at federal agencies, finding that the government's privilege claim was outweighed by the plaintiffs' need for the information to pursue their claims under the Administrative Procedure Act.
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July 18, 2025
Trade Legal Matters To Watch: Midyear Report
Aggressive, sweeping tariff actions have defined the first six months of President Donald Trump's second term, altering the global trade environment in attempts to return manufacturing to the U.S. and reset trading deficits, but legal challenges to certain duties may obstruct Trump's long-term trade strategy in ongoing negotiations later this year.
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July 18, 2025
DC Circ. Affirms Toss Of Tax Pros' PTIN User Fee Challenge
A D.C. federal court properly dismissed a lawsuit by tax return preparers challenging the IRS' process for issuing their special identification numbers, the D.C. Circuit ruled Friday, saying the suit violated rules against filing duplicate claims.
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July 18, 2025
IRS Offers Guidance On Use Of Transfer Pricing Exception
Taxpayers can use an exception in the tax code for payments for services rendered by foreign related parties without applying a related U.S. Treasury Department regulation's provisions for transfer pricing purposes, the IRS Office of Chief Counsel said Friday.
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July 18, 2025
Trump Asks Supreme Court To Decline Early Tariff Challenge
President Donald Trump's administration urged the U.S. Supreme Court to reject a request from Illinois-based toy makers to hear their challenge against the White House's global tariffs, arguing the justices should not "leapfrog" parallel proceedings in circuit courts.
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July 18, 2025
3 Key Budget Bill Issues Tax Pros Want IRS To Clarify Quickly
The GOP's new tax overhaul is driving demand for guidance on long-sought business and worker-friendly provisions among tax professionals and lawmakers, who are watching to see if IRS staff cuts and funding reductions will hinder the agency's ability to take swift regulatory action. Here, Law360 looks at three areas where tax pros say a quick turnaround on guidance or regulations would be most helpful.
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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.
Expert Analysis
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Dissecting House And Senate's Differing No-Tax-On-Tips Bills
Employers should understand how the House and Senate versions of no-tax-on-tips bills differ — including in the scope of related deductions and reporting requirements — to meet any new compliance obligations and communicate with their employees, say attorneys at Greenberg Traurig.
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Section 899 Could Be A Costly Tax Shift For US Borrowers
Intended to deter foreign governments from applying unfair taxes to U.S. companies, the proposal adding new Section 899 to the Internal Revenue Code would more likely increase tax burdens on U.S. borrowers than non-U.S. lenders unless Congress limits its scope, says Michael Bolotin at Debevoise.
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Calif. Bar Exam Fiasco Shows Why Attys Must Disclose AI Use
The recent revelation that a handful of questions from the controversial California bar exam administered in February were drafted using generative artificial intelligence demonstrates the continued importance of disclosure for attorneys who use AI tools, say attorneys at Troutman.
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In 2nd Place, Va. 'Rocket Docket' Remains Old Reliable
The U.S. District Court for the Eastern District of Virginia was again one of the fastest civil trial courts in the nation last year, and an interview with the court’s newest judge provides insights into why it continues to soar, says Robert Tata at Hunton.
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How Attorneys Can Become Change Agents For Racial Equity
As the administration targets diversity, equity and inclusion efforts and law firms consider pulling back from their programs, lawyers who care about racial equity and justice can employ four strategies to create microspaces of justice, which can then be parlayed into drivers of transformational change, says Susan Sturm at Columbia Law School.
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Adapting To Private Practice: From US Attorney To BigLaw
When I transitioned to private practice after government service — most recently as the U.S. attorney for the Eastern District of Virginia — I learned there are more similarities between the two jobs than many realize, with both disciplines requiring resourcefulness, zealous advocacy and foresight, says Zach Terwilliger at V&E.
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Opportunity Zone Revamp Could Improve The Program
If adopted, the budget bill's new iteration of the opportunity zone program could renew, refine and enhance the effectiveness and accountability of the original program by including structural reforms, expanded eligibility rules and incentives for rural investment, say attorneys at Pillsbury.
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The Ins And Outs Of Consensual Judicial References
As parties consider the possibility of judicial reference to resolve complex disputes, it is critical to understand how the process works, why it's gaining traction, and why carefully crafted agreements make all the difference, say attorneys at Pillsbury.
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The BigLaw Settlements Are About Risk, Not Profit
The nine Am Law 100 firms that settled with the Trump administration likely did so because of the personal risk faced by equity partners in today's billion‑dollar national practices, enabled by an ethics rule primed for modernization, says Adam Forest at Scale.
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House Bill Tax Tweaks Would Hinder Renewable Projects
Provisions in the budget reconciliation bill recently passed by the U.S. House of Representatives would rapidly phase out clean energy tax credits, constrain renewable energy financing arrangements and impose sweeping restrictions on projects with foreign ties, which may create compliance and supply chain issues for many developers, say attorneys at Paul Hastings.
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Power To The Paralegals: An Untapped Source For Biz Roles
Law firms looking to recruit legal business talent should consider turning to paralegals, who practice several key skills every day that prepare them to thrive in marketing and client development roles, says Vanessa Torres at Lowenstein Sandler.
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How Trucking Cos. Can Keep Rolling Under Tariff Burdens
Recent Trump administration tariffs present major challenges for the transportation and logistics sector — and, in particular, trucking — but providers who focus on operational efficiency, cost control, customer relationships, creative contract structures and unique offerings will stand out from the competition, say attorneys at Benesch.
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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.