Federal
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September 05, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included the agency's plan to remove rules that would have forced companies to recognize income from payments that are disregarded for U.S. taxes yet reduce income in a foreign jurisdiction.
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September 05, 2025
Public Hearing On Offshore Profit Regs Set For October
A public hearing is scheduled for next month on proposed rules that would require U.S. multinational companies to create annual shareholder accounts and follow new pooling concepts to account for previously taxed earnings and profits, the U.S. Treasury Department said Friday.
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September 05, 2025
IRS Security Lapses Could Put Tax Data At Risk, TIGTA Says
The Internal Revenue Service has missed deadlines for resolving security vulnerabilities in its computer systems, the U.S. Treasury Inspector General for Tax Administration said Friday, warning that the lapses could expose taxpayer data to increased risk of attack.
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September 04, 2025
Ill. Toymakers Ask Justices To Resolve Tariff Suit Venue Split
A pair of toymakers asked the U.S. Supreme Court Thursday to resolve a jurisdictional dispute concerning challenges to President Donald Trump's emergency tariffs, saying the justices should hear their case at the D.C. Circuit along with the federal government's just-filed appeal of a Federal Circuit decision that invalidated Trump's tariffs.
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September 04, 2025
Tax Court Affirms SC Man's Tax Deficiency, Penalties
A South Carolina man owes the IRS more than $16,000 after underreporting his income for the 2018 tax year, and he is liable for a $10,000 penalty, the U.S. Tax Court said in an opinion Thursday.
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September 04, 2025
Ex-CEO Should Start Sentence For Tax Crimes, Court Told
A former software executive convicted of failing to pay employment taxes should not be allowed again to delay reporting to prison, the government told a North Carolina federal court Thursday, saying the man's new dental issues weren't serious enough to stop him from beginning his sentence.
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September 04, 2025
ABA Tax President-Elect Plans To Build On Section's Success
Lisa Zarlenga, a Steptoe LLP partner, is serving as president-elect of the American Bar Association's Section of Taxation for the 2025–2026 term, officially taking on the role this month with the goal of building the strength of the organization for the next generation of tax attorneys. In an interview with À¶Ý®ÊÓÆµ, Zarlenga discussed what she enjoys about tax practice, how the section has shaped her career and her vision for strengthening the organization to support future generations of tax attorneys.
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September 04, 2025
PBM Rule Included In DOL Benefits Arm's Regulatory Update
The U.S. Department of Labor's employee benefits arm detailed several new regulations in the works Thursday, including a new fee disclosure rule involving pharmacy benefit managers and plans to revisit retirement plan fiduciary investment advice regulations, according to the administration's latest regulatory update.
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September 04, 2025
Gov't Can Foreclose On Physician's Home Over $2M Tax Debt
A physician and his wife owe more than $2 million in unpaid taxes after failing to file returns for nearly a decade, a Texas federal court found, ruling that the U.S. government can sell the couple's home to help pay the debt.
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September 04, 2025
Gov't Urges Justices To Fast-Track Emergency Tariff Suit
The U.S. Supreme Court must consider under a proposed fast-track schedule the Federal Circuit's finding of President Donald Trump's emergency tariffs as unlawful or jeopardize the recent bilateral trade agreements and the improvements to the U.S. economy as a result of those duties, the administration said.
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September 03, 2025
House Appropriations Panel Advances $2.8B IRS Funding Cut
The House Appropriations Committee approved legislation Wednesday that would cut the Internal Revenue Service's funding by $2.8 billion for the 2026 fiscal year, sending the proposal to the full House for consideration.Â
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September 03, 2025
11th Circ. Affirms Prison Sentence For False Tax Returns
A Florida tax return preparer who admitted to helping prepare false returns must finish serving more than two years in prison, the Eleventh Circuit ruled Wednesday, rejecting his claim that his employees were to blame.
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September 03, 2025
Northwestern Mutual Seeks $23M Tax Refund For Free Meals
Northwestern Mutual is seeking a refund of $23 million in taxes for on-campus lunches it provided to employees, telling a Wisconsin federal court that the IRS improperly denied the company an exclusion on taxable income for the meals.
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September 03, 2025
Senate To Hold Treasury, IRS Nomination Hearings Next Week
The Senate Finance Committee said Wednesday that it has scheduled nomination hearings for high-ranking officials at the U.S. Department of the Treasury and the Internal Revenue Service for Sept. 10.
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September 03, 2025
Software Co. Founder Fights $100M Tax Bill At 11th Circ.
A software company founder facing more than $100 million in tax debt from his participation in an illegal tax shelter should have been allowed to settle with the Internal Revenue Service for $1.5 million because he can't pay the whole bill, he told the Eleventh Circuit.
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September 03, 2025
Tax Court Must Reconsider Medtronic Pricing, 8th Circ. Says
The U.S. Tax Court should reconsider its use of a hybrid approach for pricing intangibles that Medtronic licensed to a Puerto Rican affiliate, the Eighth Circuit said Wednesday, vacating the ruling and directing the court to revisit the IRS' pricing method.
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September 02, 2025
11th Circ. Affirms Slashing Ex-Braves' $47M Easement Break
A $47 million conservation easement deduction for a partnership founded by two former Atlanta Braves players was overvalued, the Eleventh Circuit affirmed Tuesday, saying none of the partnership's arguments undermined the U.S. Tax Court's finding that the easement property was worth far less than it claimed.
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September 02, 2025
Jury Misled On Tax Fraud Conspiracy Charge, 10th Circ. Rules
The Tenth Circuit overturned Tuesday a conviction against a man who did not report trust income on his personal tax returns, saying the New Mexico district court erred in presenting instructions on the conspiracy charges to both the jury and defendant's counsel.
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September 02, 2025
Firm Urges 2nd Circ. To Review $142M Earnings Boost
A New York investment company has asked the Second Circuit to review a U.S. Tax Court ruling that sustained a $142 million increase to its net earnings and found its principals did not qualify as limited partners for an exception from self-employment income tax.
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September 02, 2025
Most Employers Paid Taxes After COVID Delay, Report Says
Most employers who put off paying Social Security taxes during the pandemic have paid their bills, the Treasury Inspector General for Tax Administration said Tuesday, although some employers who didn't pay were incorrectly charged penalties by the IRS.
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September 02, 2025
IRS Withdraws Rule On Tax Data Use In Passport Revocations
The IRS will scrap a 2018 proposed rule that would have allowed the U.S. State Department to share taxpayer return information with contractors that assist in the revocation or denial of passports of individuals with serious tax debts, the agency announced Monday, calling the rule unnecessary.
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September 02, 2025
Colgate-Palmolive To Shell Out $332M In Pension Payout Fight
Colgate-Palmolive retirees asked a New York federal judge to greenlight a $332 million class action deal in their suit claiming the household products company shorted them on lump-sum retirement payouts, signaling the end of a nearly decade-old case that reached the Second Circuit in 2023.Â
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August 29, 2025
Split Fed. Circ. Backs Limits On Presidential Tariff Powers
The Federal Circuit held that President Donald Trump's emergency tariffs were improperly imposed under the International Emergency Economic Powers Act, which it said makes no mention of "tariff," "duties" or "tax."
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August 29, 2025
Bookie Who Took Bets From Ohtani Interpreter Gets 1 Year
A resident of Orange County, California, was sentenced to a year and a day in prison on Friday after pleading guilty to operating as an unlicensed bookmaker who placed bets for current and former professional athletes as well as a Japanese language interpreter who is serving time for stealing from baseball megastar Shohei Ohtani.
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August 29, 2025
House Dems Reintroduce Marijuana Legalization Bill Again
Democrats in the U.S. House of Representatives once again reintroduced a federal marijuana legalization bill that previously passed the chamber twice when it was under Democratic control, but has never gained traction in the U.S. Senate or under a majority-Republican House.
Expert Analysis
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Budget Act's Deduction Limit Penalizes Losing Gamblers
A provision in the One Big Beautiful Bill Act that reduces the deduction for gambling losses is unfair to professional and recreational players, risks driving online activity to offshore sites, and will set back efforts to legalize and regulate the industry, says Walter Bourdaghs at Kang Haggerty.
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The Legal Education Status Quo Is No Longer Tenable
As underscored by the fallout from California’s February bar exam, legal education and licensure are tethered to outdated systems, and the industry must implement several key reforms to remain relevant and responsive to 21st century legal needs, says Matthew Nehmer at The Colleges of Law.
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6 Questions We Should Ask About The Trump Trade Deals
Whenever the text becomes available, certain questions will help determine whether the Trump administration’s trade deals with U.S. trading partners have been crafted to form durable economic relationships, or ephemeral ties likely to break upon interpretive disagreement or a change in political will, says Ted Posner at Baker Botts.
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E-Discovery Quarterly: Rulings On Relevance Redactions
In recent cases addressing redactions that parties sought to apply based on the relevance of information — as opposed to considerations of privilege — courts have generally limited a party’s ability to withhold nonresponsive or irrelevant material, providing a few lessons for discovery strategy, say attorneys at Sidley.
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Section 1983 Has Promise After End Of Nationwide Injunctions
After the U.S. Supreme Court recently struck down the practice of nationwide injunctions in Trump v. Casa, Section 1983 civil rights suits can provide a better pathway to hold the government accountable — but this will require reforms to qualified immunity, says Marc Levin at the Council on Criminal Justice.
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Playing Soccer Makes Me A Better Lawyer
Soccer has become a key contributor to how I approach my work, and the lessons I’ve learned on the pitch about leadership, adaptability, resilience and communication make me better at what I do every day in my legal career, says Whitney O’Byrne at MoFo.
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Lessons On Parallel Settlements From Vanguard Class Action
A Pennsylvania federal judge’s unexpected denial of a proposed $40 million settlement of an investor class action against Vanguard highlights key factors parties should consider when settlement involves both regulators and civil plaintiffs, say attorneys at Ropes & Gray.
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Adapting To Private Practice: From ATF Director To BigLaw
As a two-time boomerang partner, returning to BigLaw after stints as a U.S. attorney and the director of the Bureau of Alcohol, Tobacco, Firearms and Explosives, people ask me how I know when to move on, but there’s no single answer — just clearly set your priorities, says Steven Dettelbach at BakerHostetler.
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Mulling Worker Reclassification In Light Of No Tax On OT
The One Big Beautiful Bill Act's no-tax-on-overtime provisions provide tax relief for employees who regularly work overtime and are nonexempt from the Fair Labor Standards Act, but reclassifying employees may lead to higher compliance costs and increased wage and hour litigation for employers, says Steve Bronars at Edgeworth Economics.
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Clean Energy Tax Changes Cut Timelines, Add Red Tape
With its dramatic changes to energy tax credits, the One Big Beautiful Bill Act will reshape project financing and investment planning — and wind and solar developers, especially those in the early stages of projects, face stricter timelines and heightened compliance challenges, says Dan Ruth at Balch & Bingham.
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Playing Baseball Makes Me A Better Lawyer
Playing baseball in college, and now Wiffle ball in a local league, has taught me that teamwork, mental endurance and emotional intelligence are not only important to success in the sport, but also to success as a trial attorney, says Kevan Dorsey at Swift Currie.
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Reform Partly Modernizes Small Biz Stock Gains Exclusion
Changes to the Internal Revenue Code in the One Big Beautiful Bill Act update the qualified small business stock gains exclusion to reflect inflation, but the regime would be more in line with current business realities if Congress had also made the exemption available to additional business structures, says Mark Parthemer at Glenmede.
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How Real Estate Funds Can Leverage Del. Statutory Trusts
Over the last two years, traditional real estate fund sponsors have begun to more frequently adopt Delaware Statutory Trust programs, which can help diversify capital-raising strategies and access to new sources of capital, among other benefits, say attorneys at Polsinelli.