Federal
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August 12, 2025
DOL Yanks 2021 Guidance On Private Equity 401(k) Risks
The U.S. Department of Labor's employee benefits arm on Tuesday rescinded guidance from 2021 that warned 401(k) plan managers about the risks of investing in private equity, which comes after an executive order last week that called for expanding access to alternative asset classes in defined-contribution retirement plan investing.
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August 12, 2025
Texas Tax Prep Firm Deserves Ban For Wide Fraud, Court Told
A Texas tax preparation firm engaged in extensive fraud that included guiding clients to — often unwittingly — invent businesses to claim losses, fraudulently claim self-employment tax credits and falsely identify as heads of household, the government told a federal court, seeking to ban the firm from practicing.
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August 12, 2025
Holland & Knight Hires Sen. Cornyn Tax Counsel In DC
The former senior tax counsel for U.S. Sen. John Cornyn, R-Texas, who worked for the lawmaker for almost two decades on appropriations, taxation, banking and other finance-related issues, has joined Holland & Knight LLP's public policy and regulation group.
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August 12, 2025
Trump's Tariffs Add Billions In Revenue, Think Tank Says
President Donald Trump's enacted tariffs are generating billions of dollars more in revenue when compared to duty collections prior to his taking office, and that revenue could be used to reduce the U.S. budget deficit, according to a recent analysis by the Committee for a Responsible Federal Budget.
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August 12, 2025
Pa. Guilty Plea Means Nothing To Malpractice Case, Atty Says
An ex-chief financial officer suing his former attorney for allegedly coercing him into a consent agreement that landed him with an over $12 million judgment has urged a Florida federal court to keep his malpractice case against the attorney on track.
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August 12, 2025
GAO Calls On IRS To Improve Adoption Tax Credit Messaging
The Internal Revenue Service should develop an educational outreach plan for the adoption tax credit, the U.S. Government Accountability Office said after finding many taxpayers may not be aware of the credit or have received unclear information.
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August 11, 2025
Tax Court Backs IRS' Denial Of Whistleblower's Award Bid
A whistleblower was correctly denied an award for information about alleged underpayments by a large multinational corporation, the U.S. Tax Court said Monday, finding the information did not substantially contribute to the IRS' action in the case.
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August 11, 2025
Goodyear Facing Tax Adjustments Over Intercompany IP Sale
Goodyear Tire & Rubber Co. is planning to challenge proposed IRS adjustments that could undermine the company's ability to offset certain taxes related to an intercompany intellectual property sale, according to a U.S. Securities and Exchange Commission filing.
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August 11, 2025
6th Circ. Orders Eaton To Give Employee Records To IRS
The Sixth Circuit affirmed an Ohio federal judge's order requiring Eaton Corp. to share performance evaluations for Ireland-based workers with the IRS, holding that the agency's interest in investigating potential tax liabilities outweighs Ireland's privacy interest, which the court said was "weak" at best.
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August 11, 2025
Kostelanetz Hires Most Recent DOJ Tax Division Leader
The immediate past head of the U.S. Department of Justice's Tax Division will join Kostelanetz LLP as a partner in Washington, D.C., amid a sweeping restructuring that would split the division's criminal and civil tax functions and place them in the department's main branches.
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August 11, 2025
2nd Circ. Affirms Denial Of Partnership's $22.7M Tax Loss
The U.S. Tax Court correctly found the IRS properly denied a Connecticut partnership's $22.7 million loss deduction because the underlying transactions, which involved a Brazilian company, were tantamount to a disguised property sale, the Second Circuit ruled Monday.
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August 11, 2025
40% Of IRS Self-Service Kiosks Not Working, TIGTA Says
Forty of the Internal Revenue Service's 100 self-service kiosks at its taxpayer assistance centers are inoperable, the Treasury Inspector General for Tax Administration said in a report released Monday, blaming the agency's lack of oversight of a contractor that services the kiosks.
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August 08, 2025
DC Circ. Hands Banker's Estate Win In IRS Whistleblower Bid
A split D.C. Circuit sided with the estate of a former banker at Rabobank in ruling Friday that the Internal Revenue Service used the wrong legal standard to deny him an award for contributing to investigations into two companies' tax avoidance scheme.
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August 08, 2025
Trump Ousts IRS Commissioner Weeks After Confirmation
Billy Long has been removed from his role as Internal Revenue Service commissioner after spending just shy of two months as head of the agency, the White House said Friday.
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August 08, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included indexing adjustments for calculating penalties against large employers that don't offer health insurance to their full-time workers or whose full-time workers opt to enroll in government-subsidized health coverage using premium tax credits
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August 08, 2025
Swiss Metals Group Fears US Tariffs' Impact On Gold
The U.S.-imposed 39% tariffs on Switzerland may "negatively impact" gold trading, a Swiss metals association warned Friday.
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August 08, 2025
$47M Fat Brands Tax Case Tossed After DOJ Quits Pursuing It
A California federal judge dismissed an indictment accusing Fat Brands and its founder of hiding $47 million from the IRS through a loan scheme after the U.S. Department of Justice had said the case was no longer a priority.
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August 08, 2025
11th Circ. Vacates Russian Gas Ex-CFO's Tax Crime Sentence
The Eleventh Circuit vacated a Russian former gas executive's seven-year prison term and order to pay $4 million in restitution to the IRS, saying federal prosecutors were wrongly given extra time to bring charges against him for failing to file income tax returns.
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August 08, 2025
Taxation With Representation: Latham, Alston & Bird, Orrick
In this week's Taxation With Representation, fiber optic connector systems maker Amphenol Corp. buys CommScope's connectivity and cable solutions business, Blackstone acquires Enverus from private equity firms, investors buy a majority stake in medical device company HistoSonics Inc., and ESPN swaps an equity stake for the National Football League's NFL Network and other intellectual property.
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August 08, 2025
Pennsylvania Litigation Highlights Of The 1st Half Of 2025
In the first half of 2025, Pennsylvania judges have created a federal and state court split in a $175 million verdict against Monsanto in Philadelphia's Roundup mass tort, reduced the tax fraud sentence of a member of the family behind an iconic Philadelphia cheesesteak shop and permanently barred a college apparel company from copying Penn State trademarks.Â
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August 07, 2025
2nd Circ. Says Trial Atty With Brain Disease Not 'Ineffective'
The Second Circuit on Thursday affirmed the convictions of a former New York City law enforcement union president along with its ex-financial adviser for defrauding members out of $500,000, rejecting among contentions that one defense lawyer's abilities were impaired at trial by a fast-moving neurodegenerative disease.
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August 08, 2025
Midyear Review: A Look At The Tax Trends Shaping 2025
Tax professionals had a lot to keep up with in the first half of 2025, from congressional action to extend the 2017 GOP tax overhaul to a tumultuous international trade scene. And the back half of the year is poised to be just as busy, with litigation over how the IRS handles employee retention tax credits, an Amazon suit in South Carolina over sales tax, and an uncertain future for global minimum tax rules. Here, dive into our slate of analysis pieces to help guide you through evolving tax litigation and policy.Â
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August 07, 2025
IRS Can Collect From Incarcerated Man, Tax Court Says
The IRS properly denied a request by an incarcerated man to stop collecting his nearly $160,000 tax debt, the U.S. Tax Court ruled Thursday, saying the man admitted to having hundreds of thousands of dollars in assets.
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August 07, 2025
Toyota Forecasts $9.5B Annual Hit From US Tariffs
U.S. tariffs would cost Toyota Motor Corp. 1.4 trillion yen ($9.5 billion) during its fiscal year ending March 2026, including 450 billion yen in its first quarter, the automaker said Thursday.
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August 07, 2025
Siemens Contests Nix Of $315M Foreign-Dividend Tax Break
Regulatory missteps caused the IRS to wrongly slash $315 million from a foreign-dividend tax deduction Siemens claimed on shareholder payments it received from an overseas affiliate, the medical giant told the U.S. Tax Court.
Expert Analysis
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House Bill Tax Tweaks Would Hinder Renewable Projects
Provisions in the budget reconciliation bill recently passed by the U.S. House of Representatives would rapidly phase out clean energy tax credits, constrain renewable energy financing arrangements and impose sweeping restrictions on projects with foreign ties, which may create compliance and supply chain issues for many developers, say attorneys at Paul Hastings.
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Power To The Paralegals: An Untapped Source For Biz Roles
Law firms looking to recruit legal business talent should consider turning to paralegals, who practice several key skills every day that prepare them to thrive in marketing and client development roles, says Vanessa Torres at Lowenstein Sandler.
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How Trucking Cos. Can Keep Rolling Under Tariff Burdens
Recent Trump administration tariffs present major challenges for the transportation and logistics sector — and, in particular, trucking — but providers who focus on operational efficiency, cost control, customer relationships, creative contract structures and unique offerings will stand out from the competition, say attorneys at Benesch.
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Tariff Strategies For The US Renewable Energy Sector
The Trump administration's tariff actions over the last few months are challenging for the renewable energy industry — but there are strategies for contending with the uncertainty, including diversifying supply chains, seeking certification about equipment origins, and adding tariff-related language to supply contracts and offtake agreements, say attorneys at Sheppard Mullin.
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Ch. 7 Marshaling Ruling Rests On Shaky Legal Grounds
In its recent holding in a Chapter 7 bankruptcy case that marshaling may not be applied against the IRS, a Texas federal court misapplied a bankruptcy code section and case law, leaving a draconian decision that could limit the scope of a powerful equitable estate tool, says Brian Shaw at Cozen O'Connor.
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3 Tax Issues Manufacturers Should Watch In 2025 Budget Bill
As Congress works toward a budget reconciliation bill, manufacturing companies should keep a keen eye on proposals to change bonus depreciation, the qualified business income deduction and energy tax credits, which could have a significant impact on capital-intensive industries, say attorneys at Frost Brown Todd.
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$38M Law Firm Settlement Highlights 'Unworthy Client' Perils
A recent settlement of claims against law firm Eckert Seamans for allegedly abetting a Ponzi scheme underscores the continuing threat of clients who seek to exploit their lawyers in perpetrating fraud, and the critical importance of preemptive measures to avoid these clients, say attorneys at Lockton Companies.
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Jurisdictional Issues At Play In 9th Circ.'s FCA Trade Case
A decision by the Ninth Circuit in Island Industries v. Sigma Corp. could result in the U.S. Court of International Trade’s exclusive jurisdiction over trade-related FCA cases, a big shift in the enforcement landscape just as tariffs take center stage in trade policy, say attorneys at Haynes Boone.
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Evolving Federal Rules Pose Further Obstacles To NY LLC Act
Following the Financial Crimes Enforcement Network's recent changes to beneficial ownership information reporting under the federal Corporate Transparency Act — dramatically reducing the number of companies required to make disclosures — the utility of New York's LLC Transparency Act becomes less apparent, say attorneys at Pillsbury.
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Alternative Business Structures Raise Ethics Questions
The new KPMG law firm, launched in Arizona following that state's repeal of the prohibition on fee sharing with nonlawyers, raises a number of important practice questions, both for the firm and those law firms seeking to partner with it, says Deborah Winokur at Cozen O’Connor.
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The IRS Shouldn't Go To War Over Harvard's Tax Exemption
If the Internal Revenue Service revokes Harvard's tax-exempt status for violating established public policy — a position unsupported by currently available information — the precedent set by surviving the inevitable court challenge could undercut the autonomy and distinctiveness of the charitable sector, says Johnny Rex Buckles at Houston Law Center.
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Mitigating Import Risks Around Southeast Asian Solar Cells
The U.S. Department of Commerce's recent final determinations in its antidumping and countervailing duty investigations into solar cells produced in certain Southeast Asian countries make it important for U.S. purchasers to consider risk mitigation strategies, including modifying supply chains and contractually assigning import responsibilities, say attorneys at Morgan Lewis.
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Reassessing Corporate Separateness After Explosion Of LLCs
Following the dramatic increase of limited liability companies in the U.S., the Corporate Transparency Act's enactment and the Trump administration's subsequent narrowing of that law, it's worth revisiting the underlying legal principles that govern shell companies in order to remedy the problems that initially motivated the CTA, says Jeff Newton at Omni Bridgeway.