Federal
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November 17, 2025
Ex-Russian Gas CFO Resentenced To 6 Years For Tax Crimes
A Florida federal judge handed a nearly six-year prison term to a Russian gas company's former chief financial officer, who was convicted for tax evasion after the Eleventh Circuit vacated a prior sentence earlier this year.
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November 17, 2025
Feds Back IRS Agent Testimony In Goldstein Tax Case
An Internal Revenue Service agent must be allowed to testify in Tom Goldstein's tax evasion case, the U.S. government said, arguing that the agent's testimony is relevant to proving willfulness in the tax crimes the U.S. Supreme Court attorney and SCOTUSblog publisher was charged with.
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November 17, 2025
Applicable Federal Rates To Continue Monthslong Slide
Applicable federal rates for income tax purposes will decrease in December, the Internal Revenue Service said Monday, sliding for the fifth month in a row after a rebound in July.
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November 17, 2025
Fed. Circ. Finds Baby Formulas For Illnesses Duty-Free
A baby formula maker's products designed as therapies for children with chronic medical conditions qualify for duty-free treatment, the Federal Circuit ruled Monday, overturning the U.S. Court of International Trade's decision in a decade-old dispute.
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November 17, 2025
Minn. Dentist's Wife Can't Feign Ignorance, Tax Court Says
The U.S. Tax Court granted a Minnesota woman only partial relief Monday from shared tax liabilities with her former husband, holding that an Internal Revenue Service agent's visit marked "the dividing line" when she could no longer claim not to know about their unpaid taxes.
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November 17, 2025
OMB Reviewing Treasury Regs On OECD Crypto Reporting
The Office of Management and Budget is reviewing regulations proposed by the U.S. Department of the Treasury to implement automatic exchanges of information between tax authorities regarding taxpayers' cryptocurrency holdings under the OECD's crypto-asset reporting framework.
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November 17, 2025
MVP: Sullivan & Cromwell's Isaac Wheeler
Isaac Wheeler of Sullivan & Cromwell LLP's tax practice advised RedBird Capital Partners on the Skydance and Paramount deal, helped xAI and X on a $113 billion transaction related to their merger and guided Tishman Speyer on its $3.5 billion refinancing of Rockefeller Center, earning him a spot as one of the 2025 Law360 Tax MVPs.
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November 17, 2025
Fed. Circ. Backs Commerce To Nix Turkish Steel Duties
The U.S. Department of Commerce's removal of countervailing duties on Turkish steel imports was properly justified by the government, and the lower trade court correctly upheld its determination despite objections by the domestic steel industry, the Federal Circuit affirmed Monday.
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November 17, 2025
Madoff Victims Lose Bid To Claim $8.2M Theft Loss Deduction
A New York couple lost their challenge to claim a $8.2 million theft loss tax deduction on life insurance policies invested in accounts tied to Bernie Madoff's Ponzi scheme after the Second Circuit found that the husband did not own the policies' underlying assets.
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November 14, 2025
IRS Expert Challenges Data Used In Eaton's Projections
An expert witness for the Internal Revenue Service questioned the financial projections prepared by Eaton Corp.'s experts Friday in U.S. Tax Court, saying the data they relied on wasn't available in 2012, when the company took on debt to acquire Ireland-based Cooper Industries, a global electrical products manufacturer, for $13 billion.
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November 14, 2025
The Tax Angle: Letter Ruling Debate, Experts' Role In Policy
From a discussion on whether seeking a private letter ruling risks sparking more IRS oversight to a former Congressional Budget Office director's thoughts on tax experts' role in policymaking, here's a peek into a reporter's notebook on stories from the National Tax Association's annual conference in Boston.
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November 14, 2025
Trump Pulls IRS Chief Counsel Nomination Before Floor Vote
President Donald Trump on Friday withdrew his nomination of a Sullivan & Cromwell attorney to be the Internal Revenue Service's chief counsel just weeks after the Senate Finance Committee voted to advance the nomination to the Senate floor.
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November 14, 2025
MVP: Latham's Pardis Zomorodi
Pardis Zomorodi, partner at Latham & Watkins LLP's transactional tax practice in Los Angeles, has guided companies through the tax aspects of major complex transactions, including 2024's largest IPO and the high-profile merger between Skydance Media and Paramount Global, earning her a spot as one of the 2025 Law360 Tax MVPs.
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November 14, 2025
DC Circ. Urged To Block Trump Org. From IRS Leaker's Appeal
President Donald Trump's private business organization should not be allowed to intervene in a former IRS contractor's challenge to his prison sentence for leaking Trump's and other wealthy people's tax returns, the contractor told the D.C. Circuit, saying the organization's participation would unfairly bias the court.
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November 14, 2025
US To Slash Tariff On Swiss Imports To 15% In Trade Deal
The U.S. will reduce a 39% tariff on Swiss imports to 15% as part of a framework trade agreement reached with Switzerland, according to Friday announcements by the White House and the Swiss government.
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November 14, 2025
Taxation With Representation: Wachtell, Paul Hastings, Sidley
In this week's Taxation With Representation, Pfizer Inc. completes its acquisition of obesity drug developer Metsera Inc., motion and controls technologies company Parker-Hannifin Corp. acquires Filtration Group Corp., and fund administrator JTC PLC backs a cash offer in the billions from British private equity shop Permira.
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November 14, 2025
Biz Contests $1.7M Tax Bill After Insurance Deductions Axed
The Internal Revenue Service incorrectly hit a Colorado corporation with $1.7 million in taxes and penalties after erroneously disallowing deductions the company claimed for insurance premiums, the company told the U.S. Tax Court in a petition published Friday.
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November 14, 2025
Liquidated Captive Insurer Fights IRS Bill In Tax Court
A captive insurance company that was later dissolved challenged $800,000 in taxes and penalties in the U.S. Tax Court, saying the Internal Revenue Service wrongly claimed the company had $3 million in unreported long-term capital gains.
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November 14, 2025
US Expatriations Rise To 1,600 In 3rd Quarter, IRS Says
The number of people who lost or renounced their U.S. citizenship totaled 1,600 in the third quarter as logged by the U.S. Treasury Department, a 50% increase from the previous quarter, the IRS said Friday.
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November 14, 2025
Ala. Partnerships Say IRS Erred Rejecting Easement Breaks
The Internal Revenue Service unlawfully denied a pair of Alabama partnerships' $40 million charitable tax deduction on a conservation easement they donated in 2020, the partnerships told the U.S. Tax Court, arguing the agency offered no sufficient explanation for its determination.
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November 14, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service released its weekly internal revenue bulletin Friday, which included guidance for group health plans and health insurers to calculate out-of-network healthcare coverage for 2026.
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November 13, 2025
Eaton Witnesses Probed About Data Used For Credit Analysis
An accounting expert and a former Eaton Corp. official both advised the U.S. Tax Court on Thursday about the data used to establish the financial position of the U.S. company after its acquisition of Irish-based Cooper Industries in 2012.
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November 13, 2025
Clean Energy Cos. Tap Private Cash To Beat Tax Credit Clock
Clean energy developers are increasingly looking to privately held investors to ensure they can do enough work to keep their projects fully eligible for tax credits that start phasing out next year, energy development attorneys told Law360.
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November 13, 2025
Latin American Trade Deals With US Include Zero Tariff Rates
Latin American countries including El Salvador, Guatemala, Ecuador and Argentina committed to nontariff reductions for U.S. producers in exchange for a zero tariff rate on many imports not readily available in the U.S., under details of framework trade agreements the White House unveiled Thursday.
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November 13, 2025
Tax Court Lets Oil Co. Split Losses In $72M Carryback Dispute
An oil and gas company was allowed to give up the normal carryback period for its net operating losses without waiving the 10-year period for $72 million in specified liability losses, a divided U.S. Tax Court ruled Thursday, with two judges saying the rules aren't so flexible.
Expert Analysis
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A Look At DOJ's Dropped Case Against Early Crypto Operator
The prosecution of an early crypto exchange operator over alleged unlicensed money transmission was recently dropped in Indiana federal court, showcasing that the U.S. Justice Department may be limiting the types of enforcement cases it will bring against digital asset firms, say attorneys at Greenberg Traurig.
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8 Ways Lawyers Can Protect The Rule Of Law In Their Work
Whether they are concerned with judicial independence, regulatory predictability or client confidence, lawyers can take specific meaningful actions on their own when traditional structures are too slow or too compromised to respond, says Angeli Patel at the Berkeley Center of Law and Business.
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Despite Dark Clouds, Outlook For US Solar Has Bright Spots
While tariff, tax policy and bankruptcy news seemingly portends unending challenges for the U.S. solar energy industry, signs of continued growth in solar generating capacity and domestic solar manufacturing suggest that there is a path forward, say attorneys at Beveridge & Diamond.
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Law School's Missed Lessons: Communicating With Clients
Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.
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Bill Leaves Renewable Cos. In Dark On Farmland Reporting
A U.S. Senate bill to update disclosure requirements for foreign control of U.S. farmland does not provide much-needed guidance on how to report renewable energy development on agricultural property, leaving significant compliance risks for project developers, say attorneys at Hodgson Russ.
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Adapting To Private Practice: From US Rep. To Boutique Firm
My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.
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IRS Should Work With Industry On Microcaptive Regs
The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.
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CARES Act Fraud Enforcement Is Unlikely To Slow Down
In the five years since the passage of the Coronavirus Aid, Relief and Economic Security Act, the federal government has devoted massive resources to investigating CARES Act fraud — and all signs suggest the U.S. Department of Justice will continue vigorous enforcement in this area, say attorneys at Kostelanetz.
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Spinoff Transaction Considerations For Biotech M&A
Amid current market challenges, boards and management teams of biotech companies can consider several strategies for maximizing value should a spinoff opportunity arise, but not without significant advance planning and careful implementation, particularly in cases that might qualify as tax-free, say attorneys at Paul Hastings.
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Senate's 41% Litigation Finance Tax Would Hurt Legal System
The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.
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Drawbacks For Taxpayers From Justices' Levy Dispute Ruling
The Supreme Court's June decision in Commissioner v. Zuch, holding the Tax Court lacks jurisdiction to resolve disputes where the IRS has stopped pursuing a levy, may require taxpayers to explore new tactics for mitigating the increased difficulty of appealing their liability via collection due process hearings, says Matthew Roberts at Meadows Collier.
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How Energy Cos. Can Prepare For Potential Tax Credit Cuts
The Senate Finance Committee's version of the One Big Beautiful Bill act would create a steep phaseout of renewable energy tax credits, which should prompt companies to take several actions, including conduct a project review to discern which could begin construction before the end of the year, say attorneys at Husch Blackwell.
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DOJ Has Deep Toolbox For Corporate Immigration Violations
With the U.S. Department of Justice now offering rewards to whistleblowers who report businesses that employ unauthorized workers, companies should understand the immigration enforcement landscape and how they can reduce their risk, say attorneys at McDermott.