Federal
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April 04, 2025
The Tax Angle: Dueling Economic Outlooks For TCJA Renewal
From a look at opposite economic projections for renewing the 2017 Tax Cuts and Jobs Act during the Senate debate on the Republicans' fiscal 2026 budget resolution, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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April 04, 2025
China Issues Tariffs, WTO Challenge To Hit Back At Trump
Chinese officials began honing their response to the Trump administration's expansive new tariffs on Friday, setting up retaliatory duties and announcing plans for a challenge at the World Trade Organization.
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April 04, 2025
Taxation With Representation: Ropes & Gray, Paul Hastings
In this week's Taxation With Representation, Siemens AG acquires Dotmatics from Insight Partners, LPL Financial acquires Commonwealth Financial Network, Brookfield Asset Management takes a majority stake in Angel Oak Cos., and TowneBank acquires Old Point Financial Corp.
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April 04, 2025
Mortgage Lender Sues US For $5M In Worker Credit Refunds
The Internal Revenue Service owes a mortgage lender $5 million in refunds for worker tax credits after it had to suspend operations during the pandemic, the lender told a California federal court, saying the agency denied one of its claims for credits without conducting an audit.
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April 04, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the agency's latest update on its advance pricing agreement program's work.
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April 03, 2025
Ex-Judge, Profs Ask Justices To Weigh 9th Circ. Ch. 7 Ruling
A former bankruptcy judge and five law professors have asked the U.S. Supreme Court to review a Ninth Circuit opinion protecting the state of Montana from a real estate mogul and Montana ski resort founder's bid for damages over an involuntary Chapter 7 the state initiated.
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April 03, 2025
$5.5 Trillion Cost To Making TCJA Permanent, JCT Says
A permanent extension of the 2017 tax overhaul, including the law's expired business provisions, would cost $5.5 trillion including interest over the next decade, according to estimates released Thursday by the Joint Committee on Taxation.
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April 03, 2025
Tax Court Denies Couple's Claim To Energy Credits
A couple is not entitled to claim energy credits from an Arizona partnership whose manager pled guilty in a tax fraud scheme involving solar power equipment, the U.S. Tax Court ruled Thursday.
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April 03, 2025
DOGE Cuts Overlook Long-Standing Bids To Improve IRS
As President Donald Trump moves to downsize the federal government, the new administration may be missing an opportunity to evaluate long-standing proposals that aim to make the Internal Revenue Service run more efficiently, such as major technology upgrades and improving the dispute resolution process.
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April 03, 2025
'No Serious Question' Federal Firings Broke Law, Justices Told
Federal employee unions and advocacy groups urged the U.S. Supreme Court on Thursday to reject the Trump administration's bid to pause a California court order reinstating tens of thousands of probationary workers fired from six agencies, arguing the government can't escape self-inflicted harms brought on by its allegedly unlawful actions.
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April 03, 2025
Senate Passes Long-Shot Bill To End Trump's Canada Tariffs
The U.S. Senate on Wednesday evening passed a resolution to eliminate the national emergency President Donald Trump declared to impose 25% tariffs on Canadian imports, but the measure is likely to stall in the House and certain to be vetoed.
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April 03, 2025
South Korea To Support Industries Hit By US Tariffs
Acting South Korean President Han Duck-soo called Thursday for support to industries like automobiles and others affected by the "global tariff war" that he said was kicked off by the U.S. when it placed a 25% tariff on the country, according to local media.
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April 03, 2025
Family Used Home Loan Scheme To Shirk Tax Debt, DOJ Says
A man who owes more than $1 million in taxes helped his daughter fraudulently obtain a home loan so he could effectively own the house while avoiding paying his debt, the U.S. government said in a complaint in Florida federal court.
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April 03, 2025
UK Gov't Preparing List Of US Goods For Tariffs
The U.K. government revealed a list of U.S. goods it might target with tariffs in response to the tariffs on British goods announced by the Trump administration, according to a statement Thursday.
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April 03, 2025
IRS Considering 16 Additions To List Of Taxable Substances
The Internal Revenue Service is seeking comments on proposals from four companies to add 16 chemicals to the Internal Revenue Code's list of taxable substances, the agency said.
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April 02, 2025
Attys Call Ending DOJ Tax Division 'Epic Failure' In Efficiency
The U.S. Department of Justice's plan to dissolve its Tax Division would jeopardize effective tax enforcement nationwide, a slew of tax controversy lawyers told the DOJ Wednesday, saying such a move would defeat President Donald Trump's stated overarching goal to improve government efficiency.
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April 02, 2025
Trump Unveils New Tariffs On Dozens Of Countries
President Donald Trump announced sweeping tariffs on major trading partners Wednesday, including a 10% rate on all goods entering the U.S. to take effect later this week, in a "declaration of economic independence" he says will jump-start domestic industry and production.
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April 02, 2025
Senate GOP Plan Would Extend TCJA, Allow $1.5T In Tax Cuts
Senate Budget Committee Republicans released a budget proposal Wednesday that would permanently extend the Tax Cuts and Jobs Act and allow for up to $1.5 trillion in other tax cuts.
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April 02, 2025
6th Circ. Orders Private Review Of Docs In Eaton Tax Case
The Sixth Circuit granted a request by multinational power company Eaton Corp. to order a lower court to review in chambers sensitive performance evaluations in its transfer pricing case challenging an Internal Revenue Service summons for its European employee records.
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April 02, 2025
Jailed IRS Leaker Says Judge 'Predetermined' Sentence
The IRS contractor imprisoned for leaking thousands of tax returns, including those of President Donald Trump, to national media outlets asked the D.C. Circuit to rescind his sentence, saying a federal judge held off-the-record meetings that revealed her determination to deliver the maximum punishment.
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April 02, 2025
Environmental Cleanup Co. Seeks Refund For Retention Credit
The Internal Revenue Service owes an Alabama company that does environmental cleanup work a $3.1 million tax refund, the company told a federal district court, arguing that one of its employee retention tax credit claims was wrongfully denied.
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April 02, 2025
Control Of Kyocera's $7M Refund Suit Handed To Tax Court
The U.S. Tax Court holds jurisdiction over Kyocera's case for an approximately $7 million refund after it challenged an overlapping IRS assessment in the specialized tribunal, a South Carolina federal court ruled, agreeing with the company and the U.S. Department of Justice.
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April 01, 2025
5th Circ. Judge Questions IRS Denial Of Insurance Deductions
A Fifth Circuit judge pushed back Tuesday on the Internal Revenue Service's rejection of expense deductions for two physician-led micro-captive insurance companies, saying that the businesses seemed to serve a legitimate purpose while acknowledging that doctors are "notoriously inept" businessmen.
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April 01, 2025
Trump Admin Fights Wash.'s Bid To Expand Layoff Injunction
The Trump administration has urged a California federal judge to reject the state of Washington's request to expand an injunction blocking federal agencies from firing probationary employees, saying the bid to broaden the order to other agencies is unnecessary and based on unfounded speculation of harm.
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April 01, 2025
Tax Court Rejects Excluding IRA Distribution From Income
A Michigan man's assertion that a $15,000 distribution from his individual retirement account was a loan to pay for his ex-wife's funeral costs after her unexpected death doesn't excuse him from needing to include that distribution on his tax return as gross income, the U.S. Tax Court said Tuesday.
Expert Analysis
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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.
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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.