Federal
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October 23, 2025
Eaton To Defend Interest Rates, Fees Paid After 2012 Inversion
Eaton is preparing to defend the interest rates and guarantee fees paid by entities in the U.S. to their newly formed Irish parent after the company's 2012 acquisition and inversion at a U.S. Tax Court trial scheduled to start Nov. 3.
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October 22, 2025
Tax Co.'s Push To Escape Sex Harassment Verdict Falls Short
An Idaho federal judge rejected a tax business's bid Wednesday to escape potential liability for a $111,000 sexual harassment verdict won by a worker who claimed that the tax company acquired her former employer so that her ex-boss could avoid paying out on her lawsuit.
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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.
Expert Analysis
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UK's 1st ICSID Claim Shows Bilateral Investment Treaty Reach
For the first time, the U.K. is facing a claim under the International Centre for Settlement of Investment Disputes Convention, underscoring the broader reality that treaty protections are no longer confined to investors in emerging markets, says Philipp Kurek at Signature Litigation.
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Trump Tax Law's Most Impactful Corp. And Individual Changes
The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.
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From Clerkship To Law Firm: 5 Transition Tips For Associates
Excerpt from Practical Guidance
Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.
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Trump Tax Law's Most Consequential International Changes
The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.
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Associates Can Earn Credibility By Investing In Relationships
As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.
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Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling
The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.
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What 2 Profs Noticed As Transactional Law Students Used AI
After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.
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BigLaw Settlements Should Not Spur Ethics Deregulation
A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.
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5 Ways Lawyers Can Earn Back The Public's Trust
Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.
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Legal Jeopardy Looms Over Trump's Trade Negotiation Plans
Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.
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Opportunity Zone Overhaul Is Good News For Investors
Recently enacted reforms making the qualified opportunity zone program permanent, restoring the basis step-up for capital gains and adding flexibility to the zone designation process enhance the program’s appeal for long-term investment, says Steven Hadjilogiou at McDermott.
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White House Report Strikes An Optimistic Note On Crypto
Taking seriously President Donald Trump's pledge to adopt a pro-innovation mindset toward digital assets and blockchain technologies, a recent benchmark White House report on crypto provides a comprehensive regulatory framework that takes into account the products' novel characteristics within the high-tech ecosystem, say attorneys at Davis Wright.
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Bipartisan Bill Could Aid ESOP Formation, Valuation Clarity
The proposed Retire through Ownership Act represents a meaningful first step toward clarifying whether transactions qualify under the adequate consideration exemption in the Employee Retirement Income Security Act, potentially eliminating the litigation risk that has chilled employee stock ownership plan formation, say attorneys at Moore & Van Allen.