Federal
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December 17, 2025
Ex-Biden Tax Counsel To Chair Willkie Tax Resolution Team
Willkie Farr & Gallagher LLP has hired a former senior tax counsel who worked in two Democratic presidential administrations to come on board as chair of the firm's tax resolution practice group, according to a Wednesday announcement.
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December 17, 2025
Ex-Leader Of Veterans Group Charged With Wire, Tax Fraud
A former leader at an Idaho nonprofit veterans organization was indicted on accusations of defrauding the organization and filing false tax returns, federal prosecutors announced.
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December 17, 2025
A Blockbuster Year For Data Centers
Booming demand drove an explosive year for growth in the data center sector in 2025, with deals getting larger, more multifaceted and more complex for legal teams to pull off.
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December 17, 2025
Treasury Issues Final Rule On BEAT For Securities Lending
Taxpayers must determine and account for certain qualified derivative payments linked to securities-lending transactions when calculating payments covered by the base erosion and anti-abuse tax, according to a final rule released Wednesday by the U.S. Department of the Treasury.
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December 16, 2025
Colo. Man Gets 12 Years, Must Pay $48M For Fraud Scheme
A federal judge sentenced a Colorado man Tuesday to 12.5 years imprisonment for his role in an almost decade-long scheme promoting abusive and illegal tax shelters, and ordered nearly $50 million in restitution, plus a $35,000 fine.
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December 16, 2025
Split Tax Court Backs IRS In Dispensary's Collection Dispute
A San Francisco marijuana dispensary's expenses found to be tied to trafficking in controlled substances are not deductible, a Tax Court majority ruled Tuesday, favoring the IRS' move to not account those costs in calculating an amount to settle the business' 2016-2020 tax debt.
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December 16, 2025
Man Gets Extra Prison Time For Failing To Pay Tax Restitution
A Connecticut man who served time for failing to pay $4.8 million in federal income taxes must return to prison for nine months for not paying restitution while spending more than $100,000 on college basketball tickets and other purchases, a federal judge said.
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December 16, 2025
Corporate Transparency Act Is Constitutional, 11th Circ. Says
The Corporate Transparency Act is constitutional because it regulates economic activities with a substantial impact on interstate commerce and doesn't violate protections against unreasonable searches, the Eleventh Circuit said Tuesday, reversing a lower court's decision.
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December 16, 2025
Okla. Can't Tax Tribal Member On Reservation, Justices Told
A long line of U.S. Supreme Court rulings hold that states cannot tax tribal citizens on reservations without congressional authority, a tribal member told the justices, urging them to hear her appeal of an Oklahoma Supreme Court decision.
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December 16, 2025
Fired Top Antitrust Official Warns Of 'Politicization'
The former No. 2 at the U.S. Department of Justice's Antitrust Division until he was terminated this year testified Tuesday about the "politicization" of antitrust enforcement.
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December 17, 2025
CORRECTED: Trade Court Nixes Injunction In Trump Tariff Suit
The U.S. Court of International Trade has denied a preliminary injunction in a suit challenging President Donald Trump's emergency tariffs after auto part retailers failed to convince the court that the relief was necessary to preserve their potential right to refunds.
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December 15, 2025
Chemical Processing Co. Admits To Polluting Cape Fear
Chemical processing company American Distillation Inc. pled guilty to knowingly discharging tert-butyl alcohol and other pollutants into the Cape Fear River in North Carolina, according to a Monday press release from the U.S. Attorney's Office for the Eastern District of North Carolina.
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December 15, 2025
IRS Finalizes Tribal Welfare, Energy Direct Pay Rules
The IRS finalized a pair of long-awaited tribal regulations Monday governing a taxable income exclusion for welfare benefits and classifying certain tribe-owned entities as tax-exempt to allow them to directly monetize tax credits for clean energy projects.
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December 15, 2025
Cash Withdrawn From Online Biz Taxable, Tax Court Finds
A man who received no paycheck from the online electronics business he ran in 2012 and 2013 but used its funds to purchase luxury vehicles and help a friend should have reported those amounts as taxable income, the U.S. Tax Court held Monday.
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December 15, 2025
Tax Court Upholds Ala. Partnership's Easement Penalties
IRS penalties against an Alabama partnership for inaccurately claiming a nearly $45 million conservation easement deduction may stand, the U.S. Tax Court found, saying the dispute over the fines does not need a jury trial.
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December 15, 2025
2026 To Open With Mixed Applicable Federal Rate Bounceback
Some of the applicable federal rates for income tax purposes will finally increase in January, the Internal Revenue Service said Monday, though others will carry a now six-month slide into 2026.
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December 15, 2025
Fed. Court Asked To Block IRS' Microcaptive Reporting Rule
A Texas federal court should vacate an IRS rule aimed at flagging potential tax avoidance by requiring companies to disclose information about their microcaptive insurance transactions because it undermines Congress' authority, according to a Texas plastics company and its microcaptive adviser.
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December 15, 2025
IRS Updates Corp. Bond Monthly Yield Curve For December
The Internal Revenue Service on Monday updated the corporate bond monthly yield curve used in calculations for defined benefit plans for December, as well as corresponding segment rates and the interest rate for 30-year U.S. Treasury Department securities.
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December 15, 2025
Employee-Related Charges Against Goldstein Are Tossed
A Maryland federal judge has dismissed several charges against SCOTUSblog founder Tom Goldstein related to employees at his law firm, agreeing that prosecutors had failed to establish a clear rule for determining whether employees are legitimate for tax purposes.
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December 15, 2025
IRS Urged To Boost Oversight Of Puerto Rican Tax Breaks
The Internal Revenue Service needs to implement stronger oversight of tax incentives available to Puerto Rico residents who receive federal income tax exemptions if they meet certain requirements, according to a U.S. Government Accountability Office report.
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December 15, 2025
Former Montana Insurer Wants Income Exclusion
A Montana insurance company that dissolved in 2023 is challenging the IRS' determination that transactions it engaged in with an entity on the Turks and Caicos Islands didn't actually involve insurance and therefore aren't deductible for 2021.
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December 15, 2025
Supreme Court Declines Cannabis Ban Review
The U.S. Supreme Court on Monday declined to hear a case challenging the federal marijuana ban, leaving in place a high court precedent that has governed cannabis policy for 20 years.
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December 12, 2025
Judge Says Eaton Moved $14B Subsidiary For Tax Purposes
A U.S. Tax Court judge said Friday that he plans to find Eaton's U.S. group transferred ownership of a $14 billion subsidiary overseas in 2012 solely to justify payment of higher interest rates and guarantee fees to the company's new Irish parent.
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December 12, 2025
DOJ Shake-Up Keeps Criminal Tax Meetings, Ex-Official Says
The U.S. Department of Justice — despite recently eliminating its Tax Division as part of a broad restructuring — continues to meet with practitioners representing clients who may face federal criminal tax charges, the former division chief said Friday.
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December 12, 2025
IRS To Revamp Voluntary Disclosure Program
The Internal Revenue Service will be updating a program early next year that would allow taxpayers to voluntarily report previously undisclosed income as a way to resolve their tax issues to facilitate a simpler reporting process, the agency's criminal enforcement chief said Friday.
Expert Analysis
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Perfecting Security Interests In Renewable Energy Tax Credits
The ability to transfer renewable energy tax credits has created new opportunities for developers, investors and lenders, but it also raises important questions regarding when and how the security interests in these credits are perfected — questions that must be answered definitively to protect credit claims and transactions, says Harry Teichman at Stinson.
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Firms Still Have Lateral Market Advantage, But Risks Persist
Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
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Making The Opportunity Zones Program Great At Last
As the opportunity zone program approaches its expiration, the Republican-led government could take specific steps to extend and improve the program, address its structural flaws, encourage broader participation and enable it to live up to its promised outcomes, say attorneys at Pillsbury.
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We Must Allow Judges To Use Their Independent Judgment
As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.
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Preparing For Tariffs On Canadian Power In The Northeast
The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.
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Making The Case For Rest In The Legal Profession
For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.
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Mitigating Tariff Risks For Healthcare In US And Canada
Healthcare stakeholders should take steps to evaluate the impact of cross-border tariffs, as the historically strong ties between Canada and the U.S. demonstrate the potential for real disruption and harm to the healthcare industry in both countries, say attorneys at Norton Rose.
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4 Ways Women Attorneys Can Build A Legal Legacy
This Women’s History Month, women attorneys should consider what small, day-to-day actions they can take to help leave a lasting impact for future generations, even if it means mentoring one person or taking 10 minutes to make a plan, says Jackie Prester, a former shareholder at Baker Donelson.
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A Judge's Pointers For Adding Spice To Dry Legal Writing
U.S. District Judge Fred Biery shares a few key lessons about how to go against the grain of the legal writing tradition by adding color to bland judicial opinions, such as by telling a human story and injecting literary devices where possible.
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Why NY May Want To Reconsider Its LLC Transparency Law
Against the backdrop of the myriad challenges to the federal Corporate Transparency Act, it may be prudent for New York to reconsider its adoption of the LLC Transparency Act, since it's unclear whether the Empire State's "baby-CTA" statute is still necessary or was passed prematurely, say attorneys at Pillsbury.
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IRS Scrutiny May Underlie Move Away From NIL Collectives
The University of Colorado's January announcement that it was severing its partnership with a name, image and likeness collective is part of universities' recent push to move NIL activities in-house, seemingly motivated by tax implications and increased scrutiny by the Internal Revenue Service, say attorneys at Buchanan Ingersoll.
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7 Tips For Associates To Thrive In Hybrid Work Environments
Excerpt from Practical Guidance
As the vast majority of law firms have embraced some type of hybrid work policy, associates should consider a few strategies to get the most out of both their in-person and remote workdays, says James Argionis at Cozen O’Connor.
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IRS Should Revise Overbroad Microcaptive Regs
Rather than seeking to curtail use of congressionally sanctioned microcaptive insurance programs by imposing burdensome disclosure obligations, the Internal Revenue Service should revisit its recently finalized regulations and implement rules tailored to address areas of specific abuse, say attorneys at Zerbe Miller.