Federal
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October 22, 2025
US Among Few Places With Amount B Rules, OECD Reports
The U.S. is a significant exception to a swath of countries, including China, Japan and the U.K., that lack domestic rules allowing companies to use a transfer pricing method for baseline marketing and distribution activities known as Amount B, the OECD reported Wednesday.
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October 22, 2025
Innocent Spouse Claim Is Barred, Tax Court Says
The wife of a man who failed to report overseas income is on the hook for the couple's shared tax liabilities, the U.S. Tax Court ruled Wednesday, rejecting her request to be cleared under a provision protecting spouses who are unaware of a partner's dealings.
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October 22, 2025
Tax Court Judge Warns Against Unchecked AI Use In Filings
A U.S. Tax Court judge cautioned attorneys Wednesday against relying on artificial intelligence to write filings without verifying the information it generates, saying recent "unfortunate incidents" have prompted the court to double down on accuracy in using such tools.
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October 22, 2025
IRS Releases FAQs For Employee Retention Credits
The IRS issued answers Wednesday to a set of frequently asked questions related to the limitations for the fraud-riddled employee retention tax credit program that were implemented under the budget reconciliation law.
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October 22, 2025
'The Right Facts' Can Reduce Cos.' Tariff Impacts, Atty Says
Multinational companies with U.S. distributors that typically bear fewer business risks and earn low profit margins may be able to mitigate the effect of U.S. tariffs on their business as a whole by having a foreign principal bear the tariff costs, an attorney said Wednesday.
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October 22, 2025
Belgian Gov't Looks To Overturn US Tax Data Transfer Ruling
Belgium's data privacy watchdog was wrong to rule that the transfer of personal tax information to the U.S. breaks European Union law, the Belgian government told a Brussels court Wednesday, because the practice was established before the EU's data protection law took effect.
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October 22, 2025
Presidential Firing Limits Fight Builds At High Court
The ousted U.S. Merit Systems Protection Board chair has encouraged the U.S. Supreme Court to include a caveat for "legislative courts" if it overturns precedent that empowers Congress to limit the president's authority to fire certain agency officials, but opponents of independent agencies want a clean break from the status quo.
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October 22, 2025
Senate Sends IRS Clerical Error Correction Bill To Trump
A bill that would allow the IRS to adjust tax assessments to correct mathematical or clerical errors is headed to President Donald Trump's desk for his signature after the Senate approved the legislation, a senator who co-sponsored a related bill said Wednesday.
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October 22, 2025
Trade Court OKs $235K Tax Bill On Korean Soju Imports
South Korean alcoholic beverages were improperly classified upon entering the U.S., and U.S. Customs and Border Protection correctly calculated a nearly $235,000 bill in unpaid federal excise taxes plus interest, according to the U.S. Court of International Trade.
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October 22, 2025
Widow Not Liable For Husband's Tax Debt, 4th Circ. Told
An 80-year-old widow whose husband was imprisoned after hiding more than $20 million from the IRS told the Fourth Circuit that he was "abusive and controlling" and that she shouldn't have to pay the millions of dollars they jointly owe, despite contrary claims by the government.
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October 22, 2025
Construction Co. Owner Hid Income, Tax Court Says
A man who said he was a former officer of a California construction company was actually a 50% shareholder and failed to report income for 2016, including money diverted from a client to the purchase of a motor home, the U.S. Tax Court found.
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October 21, 2025
Nonprofits Face Pressure From GOP Tax Changes, Aides Say
Nonprofit organizations, charities and universities face sweeping changes under the Republicans' 2025 tax overhaul, Capitol Hill staffers said Tuesday, pointing to higher taxes on executive pay and endowments alongside revamped limits and incentives for individuals and corporations claiming charitable deductions.
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October 21, 2025
Partnership Deadline To Dispute IRS Is Fixed, Tax Court Says
A deadline to petition the U.S. Tax Court to challenge IRS adjustments to partnership returns is effectively fixed and cannot be extended, the court said Tuesday in a reviewed decision that denied an Alabama LLC's late bid to restore a $46 million deduction for donating to charity.
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October 21, 2025
Discovery Against Gem Company Halted In Malawi's Tax Probe
Malawi's government can no longer proceed with discovery against a gemstone company that partnered with a mining outfit the country claims evaded billions of dollars in taxes and royalties on exported rubies and sapphires, a Washington federal judge ruled, vacating his own order.
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October 21, 2025
CPA Group Calls For Transition Relief For Tips, OT Deductions
Internal Revenue Service guidance related to reporting requirements for the new deductions for tips and overtime should include a safe harbor for businesses for the 2025 tax year, the American Institute of Certified Public Accountants said in a letter released Tuesday.
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October 21, 2025
IRS Publishes Guidance For Car Loan Interest Reporting
The Internal Revenue Service released transitional guidance Tuesday for businesses' reporting requirements under the budget reconciliation law's new deduction for car loan interest.
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October 21, 2025
'Revenge Tax' May Reappear If Pillar 2 Talks Stall, Pros Say
Republican lawmakers are likely to revive what is commonly known as the revenge tax if countries are unable to flesh out a tentative agreement to effectively exempt U.S. companies from the 15% global corporate minimum tax regime known as Pillar Two, practitioners said Tuesday.
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October 21, 2025
IRS Moves Tips Deduction Hearing To Phone-Only
The Internal Revenue Service will hold its scheduled hearing on the nearly 70 occupations proposed to be subject to President Donald Trump's policy of no tax on tips via phone instead of in person, the agency announced Tuesday.
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October 21, 2025
Jones Walker Expands To Chicago With Tax Partner Hire
Jones Walker LLP has hired a Chicago-based attorney for its transactional tax team from Chapman and Cutler LLP, marking its first move into Illinois.
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October 21, 2025
Hawaii Domino's Franchisee Sues IRS Over Penalty Dispute
The IRS owes a Domino's Pizza franchisee $1.6 million in tax refunds for penalties related to failures to report its employee health coverage plan, the franchisee told a Hawaii federal court, saying the company's payroll provider was first to blame and the IRS mishandled the fallout.
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October 21, 2025
CPA Admits $1.7M Tax Fraud, Pandemic Loan Charges
A Massachusetts certified public accountant has agreed to plead guilty to failing to disclose to the IRS nearly $1.7 million in off-the-books compensation to an employee and making false certifications to obtain pandemic relief loans.
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October 21, 2025
Medtronic Says 8th Circ. Wrongly Tossed Tax Court's Method
The Eighth Circuit's rejection of the U.S. Tax Court's latest ruling on the pricing of Medtronic intangibles placed unnecessary restrictions on the court's unspecified method addressing such assets transferred to Puerto Rico, the company argued as it asked the circuit court to rethink its decision.
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October 20, 2025
Tax Pros Seek Clarity In Energy Supplier Certification Rules
The U.S. Treasury Department should clarify how developers can demonstrate new supplier certification compliance for some clean energy tax credits retooled by the Republican budget law, practitioners said Monday, noting uncertainty over what information could suffice under new restrictions on certain foreign suppliers.
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October 20, 2025
G7 Deal Exempting US From Min. Tax Hurts Brazil, Prof Says
Latin American countries, especially Brazil, are concerned that the deal announced by the Group of Seven countries in June exempting U.S. multinationals from a globally agreed 15% minimum tax gives the U.S. an unfair advantage over them, a professor at University of Antwerp said Monday.
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October 20, 2025
Tax Startup CEO Swindled $13M From Investors, SEC Says
The CEO of a defunct tax-compliance startup lied to investors as she raised $13 million for her company, overstating its revenues by almost 900 times and falsely claiming she was a certified public accountant, the U.S. Securities and Exchange Commission said Monday in California federal court.
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.