Federal
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November 17, 2025
Feds Back IRS Agent Testimony In Goldstein Tax Case
An Internal Revenue Service agent must be allowed to testify in Tom Goldstein's tax evasion case, the U.S. government said, arguing that the agent's testimony is relevant to proving willfulness in the tax crimes the U.S. Supreme Court attorney and SCOTUSblog publisher was charged with.
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November 17, 2025
Applicable Federal Rates To Continue Monthslong Slide
Applicable federal rates for income tax purposes will decrease in December, the Internal Revenue Service said Monday, sliding for the fifth month in a row after a rebound in July.
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November 17, 2025
Fed. Circ. Finds Baby Formulas For Illnesses Duty-Free
A baby formula maker's products designed as therapies for children with chronic medical conditions qualify for duty-free treatment, the Federal Circuit ruled Monday, overturning the U.S. Court of International Trade's decision in a decade-old dispute.
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November 17, 2025
Minn. Dentist's Wife Can't Feign Ignorance, Tax Court Says
The U.S. Tax Court granted a Minnesota woman only partial relief Monday from shared tax liabilities with her former husband, holding that an Internal Revenue Service agent's visit marked "the dividing line" when she could no longer claim not to know about their unpaid taxes. Â
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November 17, 2025
OMB Reviewing Treasury Regs On OECD Crypto Reporting
The Office of Management and Budget is reviewing regulations proposed by the U.S. Department of the Treasury to implement automatic exchanges of information between tax authorities regarding taxpayers' cryptocurrency holdings under the OECD's crypto-asset reporting framework.
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November 17, 2025
MVP: Sullivan & Cromwell's Isaac Wheeler
Isaac Wheeler of Sullivan & Cromwell LLP's tax practice advised RedBird Capital Partners on the Skydance and Paramount deal, helped xAI and X on a $113 billion transaction related to their merger and guided Tishman Speyer on its $3.5 billion refinancing of Rockefeller Center, earning him a spot as one of the 2025 Law360 Tax MVPs.
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November 17, 2025
Fed. Circ. Backs Commerce To Nix Turkish Steel Duties
The U.S. Department of Commerce's removal of countervailing duties on Turkish steel imports was properly justified by the government, and the lower trade court correctly upheld its determination despite objections by the domestic steel industry, the Federal Circuit affirmed Monday.
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November 17, 2025
Madoff Victims Lose Bid To Claim $8.2M Theft Loss Deduction
A New York couple lost their challenge to claim a $8.2 million theft loss tax deduction on life insurance policies invested in accounts tied to Bernie Madoff's Ponzi scheme after the Second Circuit found that the husband did not own the policies' underlying assets.
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November 14, 2025
IRS Expert Challenges Data Used In Eaton's Projections
An expert witness for the Internal Revenue Service questioned the financial projections prepared by Eaton Corp.'s experts Friday in U.S. Tax Court, saying the data they relied on wasn't available in 2012, when the company took on debt to acquire Ireland-based Cooper Industries, a global electrical products manufacturer, for $13 billion.
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November 14, 2025
The Tax Angle: Letter Ruling Debate, Experts' Role In Policy
From a discussion on whether seeking a private letter ruling risks sparking more IRS oversight to a former Congressional Budget Office director's thoughts on tax experts' role in policymaking, here's a peek into a reporter's notebook on stories from the National Tax Association's annual conference in Boston.
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November 14, 2025
Trump Pulls IRS Chief Counsel Nomination Before Floor Vote
President Donald Trump on Friday withdrew his nomination of a Sullivan & Cromwell attorney to be the Internal Revenue Service's chief counsel just weeks after the Senate Finance Committee voted to advance the nomination to the Senate floor.
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November 14, 2025
MVP: Latham's Pardis Zomorodi
Pardis Zomorodi, partner at Latham & Watkins LLP's transactional tax practice in Los Angeles, has guided companies through the tax aspects of major complex transactions, including 2024's largest IPO and the high-profile merger between Skydance Media and Paramount Global, earning her a spot as one of the 2025 Law360 Tax MVPs.
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November 14, 2025
DC Circ. Urged To Block Trump Org. From IRS Leaker's Appeal
President Donald Trump's private business organization should not be allowed to intervene in a former IRS contractor's challenge to his prison sentence for leaking Trump's and other wealthy people's tax returns, the contractor told the D.C. Circuit, saying the organization's participation would unfairly bias the court.
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November 14, 2025
US To Slash Tariff On Swiss Imports To 15% In Trade Deal
The U.S. will reduce a 39% tariff on Swiss imports to 15% as part of a framework trade agreement reached with Switzerland, according to Friday announcements by the White House and the Swiss government.
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November 14, 2025
Taxation With Representation: Wachtell, Paul Hastings, Sidley
In this week's Taxation With Representation, Pfizer Inc. completes its acquisition of obesity drug developer Metsera Inc., motion and controls technologies company Parker-Hannifin Corp. acquires Filtration Group Corp., and fund administrator JTC PLC backs a cash offer in the billions from British private equity shop Permira.
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November 14, 2025
Biz Contests $1.7M Tax Bill After Insurance Deductions Axed
The Internal Revenue Service incorrectly hit a Colorado corporation with $1.7 million in taxes and penalties after erroneously disallowing deductions the company claimed for insurance premiums, the company told the U.S. Tax Court in a petition published Friday.
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November 14, 2025
Liquidated Captive Insurer Fights IRS Bill In Tax Court
A captive insurance company that was later dissolved challenged $800,000 in taxes and penalties in the U.S. Tax Court, saying the Internal Revenue Service wrongly claimed the company had $3 million in unreported long-term capital gains.
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November 14, 2025
US Expatriations Rise To 1,600 In 3rd Quarter, IRS Says
The number of people who lost or renounced their U.S. citizenship totaled 1,600 in the third quarter as logged by the U.S. Treasury Department, a 50% increase from the previous quarter, the IRS said Friday.
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November 14, 2025
Ala. Partnerships Say IRS Erred Rejecting Easement Breaks
The Internal Revenue Service unlawfully denied a pair of Alabama partnerships' $40 million charitable tax deduction on a conservation easement they donated in 2020, the partnerships told the U.S. Tax Court, arguing the agency offered no sufficient explanation for its determination.
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November 14, 2025
Weekly Internal Revenue Bulletin
The Internal Revenue Service released its weekly internal revenue bulletin Friday, which included guidance for group health plans and health insurers to calculate out-of-network healthcare coverage for 2026.
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November 13, 2025
Eaton Witnesses Probed About Data Used For Credit Analysis
An accounting expert and a former Eaton Corp. official both advised the U.S. Tax Court on Thursday about the data used to establish the financial position of the U.S. company after its acquisition of Irish-based Cooper Industries in 2012.
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November 13, 2025
Clean Energy Cos. Tap Private Cash To Beat Tax Credit Clock
Clean energy developers are increasingly looking to privately held investors to ensure they can do enough work to keep their projects fully eligible for tax credits that start phasing out next year, energy development attorneys told Law360.
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November 13, 2025
Latin American Trade Deals With US Include Zero Tariff Rates
Latin American countries including El Salvador, Guatemala, Ecuador and Argentina committed to nontariff reductions for U.S. producers in exchange for a zero tariff rate on many imports not readily available in the U.S., under details of framework trade agreements the White House unveiled Thursday.
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November 13, 2025
Tax Court Lets Oil Co. Split Losses In $72M Carryback Dispute
An oil and gas company was allowed to give up the normal carryback period for its net operating losses without waiving the 10-year period for $72 million in specified liability losses, a divided U.S. Tax Court ruled Thursday, with two judges saying the rules aren't so flexible.
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November 13, 2025
Tax Court Upholds Levy Action For $186K Deficiency In Ala.
The U.S. Tax Court affirmed an Internal Revenue Service decision to collect an Alabama couple's $186,000 tax debt, ruling Thursday that despite sympathy for the wife's severe medical condition, the husband had failed to participate in proceedings to make his case.
Expert Analysis
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Trump Tax Law's Most Consequential International Changes
The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.
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Associates Can Earn Credibility By Investing In Relationships
As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.
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Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling
The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.
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What 2 Profs Noticed As Transactional Law Students Used AI
After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.
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BigLaw Settlements Should Not Spur Ethics Deregulation
A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.
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5 Ways Lawyers Can Earn Back The Public's Trust
Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.
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Legal Jeopardy Looms Over Trump's Trade Negotiation Plans
Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.
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Opportunity Zone Overhaul Is Good News For Investors
Recently enacted reforms making the qualified opportunity zone program permanent, restoring the basis step-up for capital gains and adding flexibility to the zone designation process enhance the program’s appeal for long-term investment, says Steven Hadjilogiou at McDermott.
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White House Report Strikes An Optimistic Note On Crypto
Taking seriously President Donald Trump's pledge to adopt a pro-innovation mindset toward digital assets and blockchain technologies, a recent benchmark White House report on crypto provides a comprehensive regulatory framework that takes into account the products' novel characteristics within the high-tech ecosystem, say attorneys at Davis Wright.
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Bipartisan Bill Could Aid ESOP Formation, Valuation Clarity
The proposed Retire through Ownership Act represents a meaningful first step toward clarifying whether transactions qualify under the adequate consideration exemption in the Employee Retirement Income Security Act, potentially eliminating the litigation risk that has chilled employee stock ownership plan formation, say attorneys at Moore & Van Allen.
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Bar Exam Reform Must Expand Beyond A Single Updated Test
Recently released information about the National Conference of Bar Examiners’ new NextGen Uniform Bar Exam highlights why a single test is not ideal for measuring newly licensed lawyers’ competency, demonstrating the need for collaborative development, implementation and reform processes, says Gregory Bordelon at Suffolk University.
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A Simple Way Courts Can Help Attys Avoid AI Hallucinations
As attorneys increasingly rely on generative artificial intelligence for legal research, courts should consider expanding online quality control programs to flag potential hallucinations — permitting counsel to correct mistakes and sparing judges the burden of imposing sanctions, say attorneys at Lankler Siffert & Wohl and Connors.
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Supreme Court's Criminal Law Decisions: The Term In Review
Though the U.S. Supreme Court’s criminal law decisions in its recently concluded term proved underwhelming by many measures, their opinions revealed trends in how the justices approach criminal cases and offered reminders for practitioners, says Kenneth Notter at MoloLamken.