Federal
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December 12, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included final regulations for the excise tax on corporations' stock buybacks and similar transactions without what is known as the funding rule.
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December 11, 2025
IRS Plans Outreach Campaign For NIL Income Earners
The Internal Revenue Service plans to launch an outreach campaign to educate student-athletes, entertainers, artists and social media influencers about the tax implications of income earned through personal brand marketing, endorsements and similar activities, an agency official said Thursday.
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December 11, 2025
Judge Slams Eaton Expert For Offering Legal Analysis
A report submitted by one of Eaton's expert witnesses in its acquisition financing trial overstepped the limits of an expert's role, offering legal rather than economic analysis and seeming to advocate for the company, a U.S. Tax Court judge said Thursday.
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December 11, 2025
Failed ACA Credit Extension Votes Leave Costs In Limbo
The Senate failed Thursday to pass procedural votes on two healthcare proposals to address the upcoming lapse in the Affordable Care Act's enhanced premium tax credits, including a proposal by Democrats to extend the subsidies for three years.
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December 11, 2025
Fed Terminates 3 Actions Against Credit Suisse, JPMorgan
The Federal Reserve said Thursday that it has terminated a trio of enforcement actions against Credit Suisse Group AG and JPMorgan Chase & Co., lifting consent orders that were tied to alleged illicit finance practices and trade surveillance failures.
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December 11, 2025
Group Seeks Cannabis Reclassification Regarding Tax Status
Cannabis shouldn't be categorized as a Schedule 1 or 2 drug, so tax law regarding the sale of illegal drugs shouldn't be applied to cannabis sales, a coalition of cannabis industry groups told the U.S. Tax Court in an amicus brief Thursday.
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December 11, 2025
Tax Court Rejects Nevada Couple's Law Firm Deductions
A married couple who are both attorneys are subject to a federal tax lien because they are not entitled to deductions and reduced gross receipts related to their law firm, and they aren't entitled to claimed losses from real estate, the U.S. Tax Court said Thursday.
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December 10, 2025
House Advances Bill To Suspend Tax Refund Claim Limits
The House Ways and Means Committee approved several tax bills Wednesday, including legislation that suspends the limitation period to file a refund claim until an IRS collection due process hearing concludes and all appeals rights have lapsed in levy cases.
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December 10, 2025
Judge Probes IRS Expert On Method For Eaton's Credit Rating
A U.S. Tax Court judge asked an IRS expert Wednesday about his calculation of a standalone credit rating for Eaton's U.S. group in 2012, when it acquired an Irish entity and inverted, noting that the expert, unlike ratings agency Standard & Poor's, factored in Eaton's debt to the Irish parent.
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December 10, 2025
6th Circ. Chides US For Lacking Merits In Distilling Ban Case
A Sixth Circuit judge criticized the U.S. Department of Justice on Wednesday for refusing to address the merits of a suit challenging the constitutionality of the U.S. tax code's ban on home distilling, saying the government cannot decide what the appellate court reviews.
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December 10, 2025
DOJ Seeks Fairness Review From High Court In Tax Dispute
A property owner is appropriately compensated if given surplus proceeds from a government sale of their property for more than the owner owed, provided the sale was conducted fairly, the federal government told the U.S. Supreme Court.
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December 10, 2025
7th Circ. Upholds Tax Conviction Of DHS Special Agent
A jury relied on enough evidence to convict a former U.S. Department of Homeland Security agent of tax crimes related to his secret dealings with drug dealers, the Seventh Circuit said Wednesday, rejecting his claim that proof of his corruption was insufficient.
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December 10, 2025
Magistrate Backs FinCEN Rules In All-Cash Real Estate Deals
A magistrate judge in Florida federal court rejected arguments from a title insurance company in upholding a U.S. Department of Treasury rule establishing new reporting requirements for all-cash residential real estate transactions as a means of combating financial crime.
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December 09, 2025
Judge Wants Cost-Benefit Analysis Of Eaton Guarantees
A U.S. Tax Court judge asked one of Eaton's experts Tuesday how much the company could have saved by issuing debt from its new Irish parent in 2012 instead of having the parent guarantee bonds the U.S. company issued to third parties.
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December 09, 2025
7th Circ. Denies Tax Evader's New Trial Over Disciplined Atty
A man convicted of tax fraud will not get a new trial based on his lawyer's removal from the Seventh Circuit Bar two months after his conviction in an unrelated case, the appellate court ruled Tuesday, saying the discipline must relate to his own defense.
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December 09, 2025
US Asks 5th Circ. To Revive ACA Employer Tax Penalties
The IRS properly penalized a janitorial services company for failing to provide employees with healthcare coverage under the Affordable Care Act, the U.S. government said, urging the Fifth Circuit to reverse a Texas federal court ruling that voided regulations promulgating the penalties.
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December 09, 2025
IRS Provides Guidance On Health Savings Account Expansion
The IRS provided guidance Tuesday on new tax benefits for Health Savings Account participants, including a provision making bronze and catastrophic plans available through the Affordable Care Act marketplace HSA-compatible, even if they don't meet the definition of a high-deductible health plan.
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December 09, 2025
Holland & Knight Adds Shipman & Goodwin Wealth Atty
A member of the 17-attorney team that left Tarlow Breed Hart & Rodgers PC to launch Shipman & Goodwin LLP's first office in Boston last month has made another move to join Holland & Knight LLP as a partner in its private wealth services group, the firm announced Monday.
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December 09, 2025
Sabre Tax Dispute Belongs In UK Court, British Airways Says
Flight booking giant Sabre's lawsuit over a U.K. digital tax bill should be dismissed or left for a British court to rule on, British Airways told a Texas federal court, arguing that the digital services tax is a matter for U.K. law.
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December 09, 2025
Sens. Propose NIL Accounts To Help Students Grow Earnings
Two U.S. senators introduced legislation Monday to allow the growing number of college student-athletes inking name, image and likeness deals with companies to create tax-advantaged investment accounts to save some of their earnings.
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December 08, 2025
Conservative Justices Probe 'Husk' Of FTC Firing Protections
The U.S. Supreme Court's conservative majority pushed back Monday against the 90-year-old precedent permitting the removal only for cause of Federal Trade Commission members, and perhaps those serving other independent agencies, calling those safeguards a "dried husk" and wondering where to draw the line for protected agencies.
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December 08, 2025
Tax Court Rejects Telecom Co.'s $3M Bankruptcy Deductions
A telecommunications company cannot deduct over $3 million as a loss tied to a subsidiary's bankruptcy proceedings, the U.S. Tax Court ruled Monday, holding that the amount must be reported as capitalized expenditures because both businesses share the same owners.
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December 08, 2025
Tax Services Provider Andersen Launches $165M IPO Plans
Tax and legal services provider Andersen Group launched plans for an estimated $165 million initial public offering, according to a filing with the U.S. Securities and Exchange Commission on Monday.
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December 08, 2025
Meta Fights $16B Tax Bill Over Facebook's Cost-Sharing Deal
Facebook parent Meta Inc. is challenging a nearly $16 billion tax bill stemming from an agreement with an Irish affiliate to share the costs of developing intangibles, telling the U.S. Tax Court that the IRS can't relitigate issues the court already addressed.
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December 08, 2025
11th Circ. Affirms Tax Court Wrong Venue For FBAR Challenge
The U.S. Tax Court isn't the right venue for a couple to challenge the Internal Revenue Service's denial of a hearing over the agency withholding their Social Security benefits to cover penalties stemming from their failure to report foreign bank accounts, the Eleventh Circuit affirmed Monday.
Expert Analysis
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Firms Must Embrace Alternative Billing Models Or Fall Behind
As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.
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How Attorneys Can Master The Art Of On-Camera Presence
As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.
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Adapting To Private Practice: From Fed. Prosecutor To BigLaw
Making the jump from government to private practice is no small feat, but, based on my experience transitioning to a business-driven environment after 15 years as an assistant U.S. attorney, it can be incredibly rewarding and help you become a more versatile lawyer, says Michael Beckwith at Dickinson Wright.
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Justices' False Statement Ruling Curbs Half-Truth Liability
The U.S. Supreme Court’s recent Thompson v. U.S. decision clarified that a federal statute used to prosecute false statements made to bank regulators only criminalizes outright falsehoods, narrowing prosecutors’ reach and providing defense counsel a stronger basis to challenge indictments of merely misleading statements, says Tamara de Silva at De Silva Law Offices.
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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.