Federal
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February 26, 2025
Coke's $2.7B Tax Bill Due To 'Bait And Switch,' 11th Circ. Told
Coca-Cola urged the Eleventh Circuit to reverse a U.S. Tax Court decision putting the beverage giant on the hook for $2.7 billion in taxes, arguing the ruling excused the IRS' "blatant bait and switch" regarding how it allocates income from foreign affiliates.
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February 26, 2025
Tax Overhaul Designer Named Top Tax Adviser To Treasury
An attorney who worked for Exxon Mobil and helped design the 2017 tax overhaul in President Donald Trump's first term has been appointed to serve as a top tax adviser to Treasury Secretary Scott Bessent, Treasury announced Wednesday.
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February 25, 2025
DC Judge Blocks Trump's Federal Funding Freeze
A D.C. federal judge on Tuesday issued a preliminary injunction blocking the Trump administration from implementing a federal spending freeze while a group of nonprofits challenge the freeze, calling the measure "ill-conceived from the beginning."
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February 25, 2025
House Passes Budget Blueprint Allowing $4.5T In Tax Cuts
The House of Representatives approved a budget blueprint Tuesday that would allow for the passage of up to $4.5 trillion in tax cuts, paving the way to renew the expiring provisions of President Donald Trump's signature 2017 tax overhaul.
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February 25, 2025
IRS Top Operating Officer To Serve As Acting Commissioner
The Internal Revenue Service's chief operating officer will become its acting commissioner, replacing current acting commissioner Douglas O'Donnell, who took on the role just last month, the U.S. Treasury Department announced Tuesday.
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February 25, 2025
Tax Court Reaffirms Suzanne Somers' Estate Owes $2.7M
The U.S. Tax Court on Tuesday reaffirmed roughly $2.7 million in tax liabilities against television producer Alan Hamel and the estate of his wife, actor Suzanne Somers, finding a Treasury regulation it had relied on in its initial decision was sound.
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February 25, 2025
Texas Tax Pros Criticize Proposal To Advise IRS Disclosures
Texas accountants objected to a proposed federal regulation that would require them to advise clients who have broken tax laws to make disclosures to the IRS, saying in a letter to the agency released Tuesday that it would likely create a conflict when clients have criminal exposure.
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February 25, 2025
Manufacturers Ask To Suspend Biden-Era Reporting Rules
Tax regulations governing partnerships and corporations passed by the outgoing Biden administration should be suspended — or outright retracted — because they conflict with the Trump administration's priorities, the National Association of Manufacturers said in a letter to the IRS and U.S. Treasury Department released Tuesday.
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February 25, 2025
10th Circ. Asked To Rethink Denying Atty's Racing Deductions
A Denver personal injury lawyer asked the Tenth Circuit to reconsider its decision barring his $300,000 tax deduction for car-racing costs as professional advertising, saying the court deprived him of due process in dismissing his argument that the IRS wrongly denied him a chance to settle.
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February 24, 2025
DC Judge Wary Of Constitutionality Of Musk's DOGE
A D.C. federal judge on Monday questioned the constitutionality of Elon Musk's Department of Government Efficiency while expressing skepticism that groups challenging the department's access to federal systems housing Americans' sensitive data had established the irreparable harm needed to block access.
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February 24, 2025
Eaton's Foreign Tax Credits Rejected By Tax Court
The U.S. Tax Court rejected foreign tax credits that Eaton Corp. had claimed on its lower-tier overseas entities' income taxes for 2007 and 2008, saying in a Monday opinion that its overseas ownership structure had disqualified the multinational power management company.
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February 24, 2025
Investor Settles In $2.1B Danish Tax Fraud Case
A U.S. investor who was among those accused by Denmark's tax agency of participating in a $2.1 billion tax fraud scheme related to fraudulently claiming refunds on tax withheld from stock dividends has reached a settlement, according to New York federal court documents filed Monday.
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February 24, 2025
Justices Won't Hear Challenge To Colo. Tax Ballot Title Law
The U.S. Supreme Court on Monday let stand a ruling by the Tenth Circuit that a Colorado law requiring that financial impacts be included in the titles of some tax-related ballot initiatives does not cause "improperly compelled" speech.
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February 24, 2025
Tax Software Co. Says Rival Is The Real Trade Secrets Thief
Corporate-focused tax preparation software company Avalara, accused by Vertex Inc. of poaching workers to steal trade secrets, has asked to file counterclaims, arguing Vertex has actually done the illegal poaching.
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February 24, 2025
Express Scripts Sees Claims Cut From $43M Tax Refund Suit
A Missouri federal court on Monday tossed some of Express Scripts' claims for a $42.9 million tax refund formerly available for domestic production, saying the pharmacy benefit manager improperly reversed course on whether certain costs should be included in its calculation of the tax break.
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February 24, 2025
4th Circ. Upholds Levy Against Md. Man's Tax Liability
The Fourth Circuit rejected Monday a Maryland man's attempt to vacate a Tax Court opinion that allowed the IRS to go ahead with a levy to collect his tax liability, saying it found no issue with the determination that he lacked any overpayments to offset his liability.
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February 24, 2025
Ex-Goldman Exec Owes For Not Filing FBARs, US Says
A former Goldman Sachs banking executive who lives in Australia owes penalties to the Internal Revenue Service for failing to report foreign bank accounts she held, the U.S. government told a D.C. federal court.
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February 24, 2025
High Court Won't Hear Tax Tipster's $690M Award Claim
The U.S. Supreme Court declined on Monday to review a man's claim for a $690 million whistleblower award for undercover recordings and tips he gave the IRS that he said led to the arrests of Swiss bankers and the success of an offshore tax disclosure program.
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February 21, 2025
Fla. Biz Owner Gets 4 Years In Prison For Worker Fraud Plot
A Florida federal judge sentenced a construction business owner to four years in prison and ordered him to pay millions of dollars in restitution after pleading guilty to fraud-related charges in connection with an elaborate worker scheme and violating safety standards that led to the death of an employee.
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February 21, 2025
GOP Leader Zeros In On Fintech And Enviro Rules For Repeal
An Internal Revenue Service rule targeting digital asset sales and U.S. Commodity Futures Trading Commission guidance on the trading of voluntary carbon credits are among the environmental and financial regulations that Republicans are prioritizing for repeal, according to House Majority Leader Steven Scalise.
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February 21, 2025
Judge Trims $40M Green Energy Co. Investor Suit
A Tennessee federal judge won't toss a proposed class action claiming that a Chicago green energy outfit and its executives used false promises of extravagant returns to lure investors, but ruled two defendants can escape some of the suit's claims.
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February 21, 2025
Trump Says Tariffs Coming For Countries With DSTs
President Donald Trump's administration will impose tariffs on countries with taxes that disproportionately affect American companies, such as digital services taxes, which mainly apply to tech giants, according to a memorandum released late Friday.
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February 21, 2025
Telecom Biz Re-Ups Push To Exempt BEAD Funds From Taxes
The telecom industry is again pressing policymakers to make income from federal broadband deployment grants tax-free.
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February 21, 2025
The Tax Angle: ABA Midyear Tax Meeting
With a lack of government officials attending the American Bar Association's midyear tax meeting, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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February 21, 2025
Lobbyist Admits To Evading $1.3M Tax By Blocking Home Sale
A lobbyist admitted to trying to thwart IRS efforts to collect about $1.3 million in taxes he owed by preventing a real estate agent from widely listing his home and by transferring assets to a family member, according to Florida federal court documents.
Expert Analysis
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Accountant-Owned Law Firms Could Blur Ethical Lines
KPMG’s recent application to open a legal practice in Arizona represents the first overture by an accounting firm to take advantage of the state’s relaxed law firm ownership rules, but enforcing and supervising the practice of law by nonattorneys could prove particularly challenging, says Seth Laver at Goldberg Segalla.
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AI Will Soon Transform The E-Discovery Industrial Complex
Todd Itami at Covington discusses how generative artificial intelligence will reshape the current e-discovery paradigm, replacing the blunt instrument of data handling with a laser scalpel of fully integrated enterprise solutions — after first making e-discovery processes technically and legally harder.
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When Innovation Overwhelms The Rule Of Law
In an era where technology is rapidly evolving and artificial intelligence is seemingly everywhere, it’s worth asking if the law — both substantive precedent and procedural rules — can keep up with the light speed of innovation, says Reuben Guttman at Guttman Buschner.
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What Compensation Committees Must Keep In Mind In 2025
New disclosure obligations, an evolving discussion on the analysis of executive perks and updated proxy adviser policies — on top of a new presidential administration — are all important things compensation committees must pay close attention to in 2025, say attorneys at Simpson Thacher.
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Anticipating Direction Of Cosmetics Regulation Under Trump
It is unclear how cosmetics regulation reform from the last few years will fare under President Donald Trump, but the new administration's emphasis on deregulation and Robert F. Kennedy Jr.'s views on product safety provide some insight, say attorneys at Crowell & Moring.
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IRS Basis-Shifting Rule Poses Notable Reporting Obligations
While the IRS’ recently finalized rule requiring partnerships to report certain related-party basis adjustment transactions is narrower than originally proposed, taxpayers and their advisers will still need to comb through myriad transactions to comply, say attorneys at Debevoise.
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Imagine The Possibilities Of Openly Autistic Lawyering
Andi Mazingo at Lumen Law, who was diagnosed with autism about midway through her career, discusses how the legal profession can create inclusive workplaces that empower openly autistic lawyers and enhance innovation, and how neurodivergent attorneys can navigate the challenges and opportunities that come with disclosing one’s diagnosis.
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Litigation Funding Disclosure Debate: Strategy Considerations
In the ongoing debate over whether courts should require disclosure of litigation funding, funders and plaintiffs tend to argue against such mandates, but voluntarily disclosing limited details about a funding arrangement can actually confer certain benefits to plaintiffs in some scenarios, say Andrew Stulce and Marc Cavan at Longford Capital.
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Top Considerations For Insurance Companies In 2025
As insurance industry participants look to plan for the year, regulatory changes, climate-related challenges, the ongoing effects of social inflation and the potential for significant mergers and acquisitions will be among the key items for insurer boards and management to have on their radar, say attorneys at Debevoise.
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Scope And Nature Of Judicial Relief Will Affect Loper's Impact
The practical result of post-Loper Bright rulings against regulatory actions will depend on the relief courts grant — and there has been controversy in these types of cases over whether the ruling is applied just to the parties or nationwide, and whether the action can be left in place while it's corrected, says Steven Gordon at Holland & Knight.
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5 Ways To Create Effective Mock Assignments For Associates
In order to effectively develop associates’ critical thinking skills, firms should design mock assignments that contain a few key ingredients, from messy fact patterns to actionable feedback, says Abdi Shayesteh at AltaClaro.
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Congress Should Pass Sex Abuse Settlement Tax Exemptions
The proposed Survivor Justice Tax Prevention Act would expand tax exemptions more clearly for sexual abuse cases, and finally remove the stigma around compensation for emotional and psychological damage, says Rocco Strangio at Milestone & Co.
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What's Next For Accounting Enforcement After SEC's Big 2024
The U.S. Securities and Exchange Commission under the Trump administration will likely continue to focus enforcement efforts on many of the same accounting and auditing issues that it pursued over the past year — but other areas, such as ESG, internal controls and cryptocurrency cases, may fall out of focus, say attorneys at Debevoise.