Federal
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March 17, 2025
The Tax Angle: Lawmakers Huddle To Mull TCJA
From a look at the three-day legislative retreat held by House Democrats to Ways and Means Republicans meeting behind closed doors to discuss the 2017 GOP tax overhaul, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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March 17, 2025
$19M In Partner Shares Not Earnings, Co. Tells Tax Court
A New York-based investment partnership accused the Internal Revenue Service of wrongly increasing its income subject to self-employment taxes by about $19 million by misclassifying its limited partners to include their shares, according to a U.S. Tax Court petition.
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March 17, 2025
10th Circ. Grapples With Liberty Global's $248M Tax Credit Bid
A Tenth Circuit panel questioned Monday whether Liberty Global is entitled to $248 million in foreign tax credits for the sale of a Japanese affiliate, or if legislation limits the telecommunications giant from classifying the gains as overseas income.
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March 17, 2025
Kleinberg Kaplan Adds Simpson Thacher Atty As Tax Partner
Kleinberg Kaplan announced Monday that it has added a Simpson Thacher & Bartlett LLP attorney to help provide clients with expertise on tax aspects of private investment fund formation and operation, as well as mergers and acquisitions, joint ventures and financings.
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March 17, 2025
Coloradan Owes FBAR Penalty After Failing To Appear
An elderly Colorado man who failed to respond to the government's claim that he owed $482,000 for failing to report his foreign bank accounts is on the hook for the bill, a federal court ruled.
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March 17, 2025
High Value Dubious In $23M Easement Dispute, 11th Circ. Told
A partnership that claimed a $23 million tax deduction for a conservation easement donation failed to consider the lack of market demand for a potential quarry it used to justify the land's high value, the U.S. government told the Eleventh Circuit.
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March 17, 2025
Applicable Federal Rates To Drop Again In April
Applicable federal rates for income tax purposes are set to decrease in April for the second month in a row, the Internal Revenue Service said Monday.
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March 17, 2025
Six Taxpayer Advocacy Panel Committees To Meet In April
Six Taxpayer Advocacy Panel committees will meet in April to discuss possible improvements to customer services, the Internal Revenue Service said Monday.
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March 14, 2025
$20 Billion IRS Funding Freeze To Continue
The Internal Revenue Service would continue to be blocked from accessing more than $20 billion in Inflation Reduction Act funding under legislation the Senate passed Friday that paves the way for the government to keep running.
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March 14, 2025
Par Funding Conspirator Gets 11 Years For Fraud, Atty Assault
A Pennsylvania federal judge has sentenced Par Funding principal James "Jimmy" LaForte to 11 years and four months in prison for helping his family run a $404 million racketeering conspiracy and violently assaulting Par Funding receivership's court-appointed counsel in a position prosecutors described as the loan company's "loyal attack dog."
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March 14, 2025
Judge Trims Investor's Bid To Rescind Funds From Pot Co.
A Florida federal judge has found that an investor can't rescind a deal or claim fraud through common law in a suit alleging that the officers and agents of a cannabis company hid a $13 million tax liability when he invested.
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March 14, 2025
IRS Correct To Reject Couple's Settlement, Tax Court Says
The Internal Revenue Service didn't do anything wrong when it rejected a California couple's offer to settle more than $235,000 in tax liabilities for less than half that amount, the U.S. Tax Court said Friday, noting the couple had more than $1 million in their home.
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March 14, 2025
3 Firms Rep Franklin BSP Realty Trust's $425M NewPoint Buy
Hogan Lovells, Reed Smith and Paul Weiss guided Franklin BSP Realty Trust's $425 million acquisition of commercial real estate finance company NewPoint Holdings JV LLC, boosting the REIT's multifamily loan offerings.
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March 14, 2025
IRS Delays Tax Deadlines In W.Va. After Feb. Storms
Taxpayers in six West Virginia counties will have until Nov. 3 to file individual and business tax returns and make payments after portions of the state were hit by severe storms in February, the Internal Revenue Service said Friday.
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March 14, 2025
Judge Splits $79M Judgment In Danish Tax Fraud Case
A New York federal judge divided a nearly $79 million judgment against four investors and their pension plans after a jury in February found them liable for participating in a tax fraud scheme against the Danish government.
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March 14, 2025
Senate Finance Panel Clears Treasury Deputy Secretary Pick
Republicans on the Senate Finance Committee voted Friday to approve Michael Faulkender's nomination to be deputy secretary of the U.S. Department of the Treasury, clearing President Donald Trump's pick for a likely Senate confirmation vote in the coming weeks.
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March 14, 2025
Taxation With Representation: Davis Polk, Paul Weiss
In this week's Taxation With Representation, Mallinckrodt PLC and Endo Inc. combine, Rocket Cos. buys Redfin, and Endo divests its international pharmaceuticals business to Knight Therapeutics Inc.
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March 14, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included final regulations for a pair of new tax credits that reward various types of electricity generation from technologies that don't emit greenhouse gases.
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March 14, 2025
Feds Say North Carolina Cardiologist Owes $7.9M In Taxes
A North Carolina cardiologist owes the federal government $7.9 million in taxes, fees and interest, according to a new civil complaint brought against him by the tax division of the U.S. Department of Justice seeking to hold him liable for the purportedly unpaid sum.
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March 13, 2025
Texan Calls $1.7M In FBAR Penalties Unconstitutional
Constitutional law bars the United States from imposing $1.7 million in penalties for failure to report foreign bank accounts, a Texan said in urging a federal court to dismiss such an assessment against her.
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March 13, 2025
Eaton Shouldn't Be Allowed To Shortcut Appeal, 6th Circ. Told
The Sixth Circuit shouldn't grant Eaton Corp.'s request to curtail arguments in its appeal of a court order enforcing an Internal Revenue Service summons for its European employee records, the federal government argued Thursday, saying it wants the chance to explain why foreign law doesn't apply.
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March 13, 2025
IRS Layoffs Could Slash Revenue By $2.4 Trillion, Report Says
If the Internal Revenue Service's workforce is cut by half, as President Donald Trump is reportedly considering, it could cost over $2.4 trillion in lost revenue over the next decade and increase the tax gap by about 25%, according to a report released Thursday by Yale's Budget Lab.
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March 13, 2025
Former IRS Counsel Joins Hinshaw In Chicago
Hinshaw & Culbertson LLP announced that a longtime government attorney who most recently served as deputy managing counsel of the Internal Revenue Service Office of Chief Counsel in Chicago, has joined the firm's government practice as a partner.
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March 13, 2025
Akin's Energy Transition Group Grows With V&E Tax Atty
Akin Gump Strauss Hauer & Feld LLP has hired a Vinson & Elkins LLP tax counsel who has spent the past decade counseling clients on the federal income tax aspects of energy transition transactions, the firm announced Thursday.
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March 13, 2025
Vanguard's $40M Deal In Tax Suit Gets Delay In Final Approval
A Pennsylvania federal judge delayed a proposed $40 million settlement between Vanguard and investors who claimed the firm unfairly stuck them with big tax bills, saying both sides must respond to objections about the effects of a recent SEC settlement on the deal.
Expert Analysis
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Rank-And-File DOJ Attorneys Will Keep Calm And Carry On
Career prosecutors at the U.S. Department of Justice often pride themselves on their ability to remain apolitical in order to ensure consistency and keep the department’s mission afloat, and the incoming Trump administration is unlikely to upend this tradition, says Michael Landman at Bird Marella.
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What Higher Education Can Expect From A 2nd Trump Admin
The election of Donald Trump for a second presidential term has far-reaching ramifications for colleges and universities — come January, institutions can expect a crackdown on DEI, increased scrutiny of campus protests, a rollback of the Biden administration's Title IX rules and more, say attorneys at Jenner & Block.
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3 Ways To Train Junior Lawyers In 30 Minutes Or Less
Today’s junior lawyers are experiencing a skills gap due to pandemic-era disruptions, but firms can help bring them up to speed by offering high-impact skill building content in bite-sized, interactive training sessions, say Stacey Schwartz at Katten, Diane Costigan at Winston & Strawn and Lauren Tierney at Freshfields.
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Expect Surging Oil And Gas Industry Under New Trump Admin
Throughout his recent campaign, President-elect Donald Trump promised increased oil and natural gas production and reduced reliance on renewables — and his administration will likely bring more oil and gas dealmaking, faster federal permitting and attempts to roll back incentives for green energy, say attorneys at Sidley.
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The Bar Needs More Clarity On The Discovery Objection Rule
Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.
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Cos. Should Inventory Issues To Prep For New Congress
As the legislative and oversight agendas of the 119th Congress come into sharper focus, corporate counsel should assess and plan for areas of potential oversight risk — from tax policy changes to supply chain integrity — even as much uncertainty remains, say attorneys at WilmerHale.
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Conservation Easement Cases Weave Web Of Uncertainty
Much of the IRS and Justice Department’s recent success in prosecuting syndicated conservation easement cases can be attributed to the government’s focus on the so-called PropCo ratio, which could indicate treacherous waters ahead for participants and their advisers, even under the incoming Trump administration, say attorneys at Polsinelli.
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So You Want To Move Your Law Practice To Canada, Eh?
Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.
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Legislation Most Likely To Pass In Lame Duck Session
As Congress begins its five-week post-election lame duck session, attorneys at Greenberg Traurig break down the legislative priorities and which proposals can be expected to pass.
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What Trump's 2nd Presidency Could Mean For Crypto Sector
Trump's second term will bring a fundamental shift from the Biden administration's approach to crypto-asset regulation and banking supervision, with the most significant changes likely taking effect in the first two quarters of 2025 and broader policy shifts emerging over the next year, say attorneys at Cahill.
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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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Takeaways From The IRS' Crypto Doc Summons Win
A recent First Circuit decision holding that taxpayers do not have a Fourth Amendment reasonable expectation of privacy in cryptocurrency transaction records should prompt both taxpayers and exchanges to take stock of past transactions and future plans, say attorneys at BakerHostetler.