Federal
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March 26, 2025
Engineering Co. Owner Can't Deduct His Time, Tax Court Says
The owner of a Colorado engineering company cannot deduct the value of the time he spent working on software without showing any amounts actually paid, the U.S. Tax Court ruled Wednesday in upholding the majority of $135,000 in tax deficiencies, plus penalties, against the owner.
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March 26, 2025
Ex-UBS North America CEO's $4.9M FBAR Deal Gets OK
The former North American CEO for Swiss bank UBS will pay a $4.9 million judgment under a deal approved by a Connecticut federal court Wednesday that resolves the U.S. government's suit alleging he willfully neglected to file foreign bank account reports with the IRS for a decade.
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March 26, 2025
Goldstein's Devices Must Be Monitored, Judge Affirms
A Maryland federal judge on Tuesday rejected U.S. Supreme Court lawyer and SCOTUSblog publisher Tom Goldstein's request to dismiss a bail condition that requires his electronic devices to be monitored out of concerns that he's been hiding millions in cryptocurrency from the government and could flee while facing tax evasion charges.
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March 25, 2025
Md. Bank Disputes IRS Denial Of Captive Tax Perk
A Maryland community bank is contesting in the U.S. Tax Court the Internal Revenue Service's decision to scrap two years' worth of tax deductions tied to a reinsurance captive, disputing the agency's findings that the arrangement had no economic purpose other than tax avoidance.
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March 25, 2025
Californian Must Allocate Half Of Income To Husband
A woman who filed returns separately from her husband must allocate half her income to him under California community property law, the U.S. Tax Court ruled Tuesday, determining the husband did indeed live in the state.
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March 25, 2025
AICPA Suggests Changes To IRS Retirement Enrollment Rules
Final Internal Revenue Service and U.S. Department of the Treasury rules establishing automatic enrollment requirements for certain retirement plans should clarify that investment requirements are not applicable to certain plans, the American Institute of CPAs said in a letter released Tuesday.
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March 25, 2025
Tax Court Affirms Captive Insurance Premiums Nondeductible
Shareholders in a California company cannot deduct their premium payments for insurance coverage from a captive insurer, the U.S. Tax Court ruled Tuesday, saying the arrangement did not constitute insurance for federal tax purposes.
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March 25, 2025
IRS Must Hand Back $169M In ID Fees To Tax Pros
The IRS must pay nearly $169 million in refunds to tax return preparers for charging them excessive fees for special identification numbers, a D.C. federal judge ruled, a judgment the preparers requested after a decade of litigation but said includes flawed agency calculations.
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March 25, 2025
EU Wants Timeline For Blacklisted US Territories' Data Swaps
The European Union asked the U.S. to provide a concrete timeline for when it will set up a framework to begin automatic exchanges of information with three territories on the bloc's blacklist for uncooperative tax jurisdictions — the U.S. Virgin Islands, Guam and American Samoa — according to a letter released Tuesday.
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March 25, 2025
Carlton Fields Adds Former Tax Law Professor In Atlanta
Carlton Fields has brought on a former tenured professor at Georgia State University College of Law to its team in Atlanta, strengthening its tax and business transactions practices with an attorney experienced in nonprofit law, tax and business matters, the firm announced Tuesday.
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March 24, 2025
IRS Abused Its Power In Levy Suit, Justices Told
A New Jersey woman should be allowed to continue challenging her tax debt in a property seizure hearing after the IRS withheld her tax refunds and dropped its levy pursuit, business and tax groups told the U.S. Supreme Court on Monday, saying the agency had abused its power.
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March 24, 2025
IRS Underreported Direct File Costs By $8.8M, TIGTA Says
The Internal Revenue Service's reported $24.6 million costs for the Direct File pilot program didn't include an estimated $8.8 million incurred by the Office of Management and Budget and the agency's credential service provider, according to the Treasury Inspector General for Tax Administration.
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March 24, 2025
McDermott Hires Skadden Partner To Lead London Tax Office
McDermott Will & Emery LLP announced Monday that it has chosen a former Skadden Arps Slate Meagher & Flom LLP partner to serve as the new leader of the firm's U.K. tax office in London.
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March 24, 2025
Burden Of Proof Is IRS' For $2.3M Bill, Kyocera Tells Tax Court
The Internal Revenue Service should bear the burden of proof in making adjustments to an amended return filed by electronics-maker Kyocera, the company argued as it urged the U.S. Tax Court to review an IRS notice saying the company owes $2.3 million for 2018.
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March 24, 2025
Trump Asks High Court To Halt Fed. Workers' Reinstatement
The Trump administration asked the U.S. Supreme Court on Monday to pause a California federal court order reinstating tens of thousands of probationary federal workers who were fired from six agencies, arguing the band of nonprofit groups that obtained the order have no standing to challenge the firings.
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March 24, 2025
FinCEN Exempts US Businesses From Disclosure Rules
The U.S. Department of the Treasury's financial crimes unit issued interim final rules that exempt domestic businesses from contested reporting regulations, which the department had previously signaled it would narrow to include only foreign companies registered stateside.
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March 24, 2025
Justices Won't Hear Peanut Truck Co.'s Excise Tax Case
The U.S. Supreme Court said Monday it will not hear a Georgia company's case arguing the IRS wrongly denied it an excise tax exemption for the special trucks it makes for peanut farming, letting stand an Eleventh Circuit ruling.
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March 22, 2025
Up Next At High Court: Non-Delegation & Clean Air Fights
The U.S. Supreme Court will return to the bench Monday to hear arguments in a dispute that could revive a long-dormant separation of powers principle and trigger a regulatory power shift.
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March 21, 2025
Fla. Tax Preparer Sentenced To Prison For $20M Fraud
A Miami-area tax preparer was sentenced to nearly five years in prison Friday after admitting to filing thousands of individual tax returns wrongly claiming energy credits, resulting in a $20 million loss for the Internal Revenue Service, according to the U.S. Attorney's Office for the Southern District of Florida.
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March 21, 2025
'Not Mistake-Proof': College Can Try To Recoup Tax Penalties
A community college can proceed with its suit seeking a refund of tax penalties for failing to file wage statements for nearly all its employees, a Michigan federal judge ruled Friday, saying the school didn't have to meet a "mistake-proof" standard to argue it should be excused from the fines.
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March 21, 2025
Groups Can Probe Treasury's Cooperation With DOGE
A Washington, D.C., federal judge let two unions and a retirees group look into any steps the U.S. Secretary of the Treasury took to give the Department of Government Efficiency access to Treasury's computer systems, saying she needs the information to evaluate the action's lawfulness.
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March 21, 2025
Boutique Firm Accuses IRS Of Illegally Enforcing Payroll Tax
A consumer-protection boutique law firm accused the IRS of illegally enforcing payroll taxes while delaying the processing of pandemic-era employee retention tax credits, which the firm claimed would have helped with compliance, according to a complaint in Connecticut federal court.
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March 21, 2025
Ex-UBS North America CEO Agrees To $4.9M FBAR Judgment
The former North American CEO for Swiss bank UBS on Friday agreed to a $4.9 million judgment to end claims that he failed to file timely or accurate foreign bank account reports with the Internal Revenue Service between 2003 and 2013.
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March 21, 2025
Taxation With Representation: Cravath, Paul Weiss, Cooley
In this week's Taxation With Representation, Google acquires Wiz, QXO Inc. acquires Beacon Roofing Supply, and the Boston Celtics are bought by a group led by private equity firm co-founder William Chisholm.
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March 21, 2025
Fed. Circ. Backs Actavis' $12M Patent Suit Cost Deduction
Drugmaker Actavis can take a $12 million tax deduction for money it spent fending off lawsuits while securing approval to sell generic birth control and other drugs, the Federal Circuit ruled Friday, affirming the U.S. Court of Federal Claims' decision that the costs were deductible as ordinary business expenses.

Justices Rule Ch. 7 Trustee Can't Recover Tax Payments
The U.S. Supreme Court on Wednesday reversed a Tenth Circuit decision allowing the bankruptcy trustee of a defunct Utah company to claw back $145,000 in federal taxes, saying the sections of the Bankruptcy Code relied upon by the trustee provide only a limited waiver of sovereign immunity.

IRS Cuts May Delay Taxpayer Help Beyond 2025 Filing Season
IRS staff cuts and early retirements, driven by the White House's push to shrink government, will likely lead to longer phone hold times and reduced service and make it harder for taxpayers to get assistance for the remainder of the 2025 tax return filing season and beyond.

These 3 GOP Budget Questions Will Shape TCJA Talks
As Congress barrels toward negotiations over renewing expiring provisions of the Tax Cuts and Jobs Act, Republican lawmakers are faced with several major budgetary decisions that will govern which proposals can be included in the bill they send to President Donald Trump's desk.
Featured Stories
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IRS Cuts May Delay Taxpayer Help Beyond 2025 Filing Season
IRS staff cuts and early retirements, driven by the White House's push to shrink government, will likely lead to longer phone hold times and reduced service and make it harder for taxpayers to get assistance for the remainder of the 2025 tax return filing season and beyond.
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These 3 GOP Budget Questions Will Shape TCJA Talks
As Congress barrels toward negotiations over renewing expiring provisions of the Tax Cuts and Jobs Act, Republican lawmakers are faced with several major budgetary decisions that will govern which proposals can be included in the bill they send to President Donald Trump's desk.
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Technical, Policy Questions Still Swirl Around Amount B
U.S. multinational corporations have welcomed the option of a simplified transfer pricing approach under an international tax framework known as Amount B, but uncertainties linger about how the rules will ultimately shake out on a technical level both domestically and globally.
Expert Analysis
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Adapting To Private Practice: From Fed. Prosecutor To BigLaw
Making the jump from government to private practice is no small feat, but, based on my experience transitioning to a business-driven environment after 15 years as an assistant U.S. attorney, it can be incredibly rewarding and help you become a more versatile lawyer, says Michael Beckwith at Dickinson Wright.
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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.