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Tax
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October 15, 2025
Tax Court Says Easement Fraud Penalties Don't Require Jury
The U.S. Tax Court refused to throw out civil fraud penalties faced by a partnership accused of overvaluing a conservation easement tax deduction, rejecting the partnership's reliance on a U.S. Supreme Court ruling that limited federal agencies' authority to impose certain penalties without a jury trial.
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October 15, 2025
Sabre Says British Airways Must Reimburse For UK Digital Tax
Flight booking giant Sabre sued British Airways over a digital tax bill it says it was required to pay the U.K. on the airline's behalf, claiming the airline was contractually obligated to reimburse Sabre for the expense but has refused.
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October 15, 2025
NYC Hotel Must Hand Over Tax Credits In Bankruptcy
The owners of a boutique hotel in Brooklyn and its management company must return pandemic-era refundable tax credits that they received as the hotel filed for Chapter 11 bankruptcy protection, a New York bankruptcy judge ruled, saying they had unfairly pocketed the money at the bankruptcy estate's expense.
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October 14, 2025
Relief Concerns Grow As Sectoral Tariff Actions Build
Importers' hopes for relief from industrywide tariffs are lagging alongside the trade deals President Donald Trump is trying to broker for some goods, while the administration's accelerated rollout of sectoral levies is also stoking concerns the government may be hamstringing its onshoring goals.
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October 14, 2025
Buy.com Founder's $16M Tax Bill Untimely, 10th Circ. Told
The founder of now-defunct Buy.com is challenging a nearly $16 million tax bill before the Tenth Circuit, arguing that the Internal Revenue Service failed to obtain valid consent to extend the statute of limitations for assessing the levy.Â
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October 14, 2025
Six Pension Plans Settle In $2.1B Danish Tax Fraud Case
Six pension plans have settled claims by Denmark's tax agency accusing them of participating in a $2.1 billion scheme that fraudulently claimed refunds on tax withheld from stock dividends, with a New York federal court dismissing the allegations Tuesday.
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October 14, 2025
Boston Says Celebrity Chef Moved Money To Skirt Tax Bills
The city of Boston is accusing celebrity chef Barbara Lynch of intentionally scheming to avoid paying nearly $1.7 million in property taxes by "siphoning off" corporate assets, asking a judge to pierce the corporate veil and hold her liable for the bill.
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October 14, 2025
'Bitcoin Jesus' Paid $50M In Tax Deal, US Says
The U.S. asked a California federal court Tuesday to dismiss its criminal tax case against a cryptocurrency investor known as Bitcoin Jesus, disclosing that he has paid the $50 million he owed for hiding bitcoin from the IRS after renouncing his U.S. citizenship more than a decade ago.
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October 14, 2025
High Court Says Blackfeet Members Can't Join Tariff Dispute
The U.S. Supreme Court denied a bid by members of the Blackfeet Nation to join its review of suits challenging the legality of President Donald Trump's emergency tariffs, who had argued that their inclusion in the dispute is crucial to protect Indigenous rights under federal law.
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October 14, 2025
Ore. Tax Court Denies Break For Land Claimed As Woodlot
An Oregon landowner could not prove that a portion of a parcel was used as a woodlot that would qualify for a property tax break, the state tax court ruled, noting that the standard for that classification was not clear.
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October 14, 2025
Calif. Allows Extended Property Tax Relief After LA Fires
California property owners affected by several fires in Los Angeles County in January will have extended property tax relief under legislation signed by Democratic Gov. Gavin Newsom.
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October 14, 2025
Miss. Partnership Challenges $89M Nixed Easement Deduction
A Mississippi partnership is entitled to an $89 million tax deduction for donating a conservation easement that protected land that could have been used for mining, despite the IRS' claim that the partnership failed to prove the gift's value, the partnership told the U.S. Tax Court.
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October 10, 2025
Colorado Business Owner Gets Prison For $1.5M Tax Fraud
The owner of a Colorado healthcare company who pled guilty to keeping over $1.5 million of her employees' withheld taxes received a one-year prison sentence on Friday.
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October 10, 2025
Tax Court Told IRS Miscalculated $21M Bill In Trust Dispute
The Internal Revenue Service made erroneous calculations regarding an Arizona partnership's capital gains and assets related to partnership interests transferred to trusts, the partnership told the U.S. Tax Court as it challenged a $21 million tax bill.
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October 10, 2025
No Taxes On $137M Failed Merger Payment, UK Court Rules
A British microchip company doesn't owe taxes on $137 million it received from a U.S. company after a failed merger, a U.K. court ruled, rejecting HM Revenue & Customs's contention that the payment constituted a taxable disposal of assets.
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October 10, 2025
Taxation With Representation: Sullivan, MoFo, Freshfields
In this week's Taxation With Representation, Fifth Third Bancorp acquires Comerica in an all-stock deal, Qualtrics buys experience analytics firm Press Ganey Forsta, and SoftBank buys ABB's robotics division.
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October 10, 2025
Baker Botts Adds 2 Tax Pros From Venable In San Francisco
Baker Botts LLP is expanding its West Coast transactional team, bringing in a pair of Venable LLP tax attorneys as partners in its San Francisco office.
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October 09, 2025
Hospice Co. Can't Get $450K In Deductions, Tax Court Affirms
A California-based hospice company was correctly denied $450,000 in tax deductions, the U.S. Tax Court decided Thursday, saying most of the tax breaks were not substantiated as required.
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October 09, 2025
GOP Sen. Joins Dems On Bill To Nix Trump's Global Tariffs
Several Senate Democrats and one Republican introduced legislation Thursday to eliminate the national emergency associated with President Donald Trump's so-called reciprocal tariff regime.
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October 09, 2025
Bulgarian Says US Delay On Sanctions Decision Harming Him
A Bulgarian businessman whose U.S. assets were frozen after the federal government accused him of bribery and tax evasion asked a D.C. federal court to force the U.S. to rule on his administrative challenge to the allegations, saying a delay has hurt his reputation and livelihood.
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October 09, 2025
Dutch Gov't Summons Fund Suspected Of €200M Tax Evasion
Dutch prosecutors have summoned a foreign pension fund that they suspect evaded €200 million ($231 million) in taxes on dividends through fraudulent refund claims, the government said Thursday.
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October 08, 2025
Trump Tariffs Unconstitutional, Watchdog Tells Justices
Either President Donald Trump doesn't have authority to impose tariffs under the International Emergency Economic Powers Act, or the law is unconstitutional, the nonprofit group Consumer Watchdog told the U.S. Supreme Court Wednesday, urging the justices to affirm lower court rulings deeming those measures unlawful.
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October 08, 2025
Trade Court Tosses Wis. Man's Trump Tariff Suit
The U.S. Court of International Trade recently dismissed with prejudice a challenge to President Donald Trump's emergency tariffs after the Wisconsin man who filed suit failed to sufficiently amend his complaint.
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October 08, 2025
3rd Time's The Charm? The Tax Court's Odyssey In Medtronic
A U.S. Tax Court judge has been sent back to the drawing board once again in the long-running transfer pricing litigation brought by Medtronic, raising questions about how much weight the court must give to IRS transfer pricing regulations and how much authority it has to go its own way.
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October 08, 2025
Group Claims Mich. 24% Pot Tax Enacted Unlawfully
Michigan's impending wholesale marijuana tax was approved by lawmakers unlawfully, an industry group alleged, saying the legislation signed by Gov. Gretchen Whitmer authorizing the tax did not have the votes of three-fourths of the majorities required in each legislative chamber.
Expert Analysis
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Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs
In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.
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Del. Dispatch: General Partner Discretion In Valuing Incentives
In Walker v. FRP Investors, the Delaware Court of Chancery recently held that the general partner of a limited partnership breached its obligations when determining the threshold value of newly issued incentive units, highlighting the court's willingness to reconstruct what a reasonable determination of value by a general partner should have been, say attorneys at Fried Frank.
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Move Beyond Surface-Level Edits To Master Legal Writing
Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.
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9th Circ. Has Muddied Waters Of Article III Pleading Standard
District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.
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Series
Competing In Modern Pentathlon Makes Me A Better Lawyer
Opening myself up to new experiences through competing in modern Olympic pentathlon has shrunk the appearance of my daily work annoyances and helps me improve my patience, manage crises better and remember that acquiring new skills requires working through your early mistakes, says attorney Mary Zoldak.
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Series
Law School's Missed Lessons: Teaching Yourself Legal Tech
New graduates often enter practice unfamiliar with even basic professional software, but budding lawyers can use on-the-job opportunities to both catch up on technological skills and explore the advanced legal and artificial intelligence tools that will open doors, says Alyssa Sones at Sheppard Mullin.
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Steps For Universities To Pass Tax-Exempt Test Amid Scrutiny
After decades of a quiet governmental acceptance of tax-exempt status, universities are facing unprecedented and public pressure to defend themselves, and must consider how to protect this valuable status, say attorneys at Eversheds Sutherland.
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Tax Court Ruling Sets High Bar For Limited Partner Exception
The U.S. Tax Court’s recent decision in Soroban Capital Partners v. Commissioner endorsed the IRS’ use of functional analysis to determine whether the limited partner exception applied for taxation under the Self-Employed Contributions Act, highlighting the intense factual analysis that will occur during audits, says Erin Hines at Akerman.
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How AI May Reshape The Future Of Adjudication
As discussed at a recent panel at Texas A&M, artificial intelligence will not erase the human element of adjudication in the next 10 to 20 years, but it will drive efficiencies that spur private arbiters to experiment, lead public courts to evolve and force attorneys to adapt, says Christopher Seck at Squire Patton.
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When Legal Advocacy Crosses The Line Into Incivility
As judges issue sanctions for courtroom incivility, and state bars advance formal discipline rules, trial lawyers must understand that the difference between zealous advocacy and unprofessionalism is not just a matter of tone; it's a marker of skill, credibility and potentially disciplinary exposure, says Nate Sabri at Perkins Coie.
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Series
Volunteering At Schools Makes Me A Better Lawyer
Speaking to elementary school students about the importance of college and other opportunities after high school — especially students who may not see those paths reflected in their daily lives — not only taught me the importance of giving back, but also helped to sharpen several skills essential to a successful legal practice, says Guillermo Escobedo at Constangy.
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Attacks On Judicial Independence Tend To Manifest In 3 Ways
Attacks on judicial independence now run the gamut from gross (bald-faced interference) to systemic (structural changes) to insidious (efforts to undermine public trust), so lawyers, judges and the public must recognize the fateful moment in which we live and defend the rule of law every day, says Jim Moliterno at Washington and Lee University.
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Increased Tariffs Create Opportunity To Protect IP Rights
Heightened tariffs on certain foreign imports have created operational and fiscal challenges for companies, but the corresponding increase in customs inspections could offer a silver lining of more consistent enforcement against counterfeit and infringing goods, says Andraya Pulaski Brunau at Day Pitney.
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Dissecting House And Senate's Differing No-Tax-On-Tips Bills
Employers should understand how the House and Senate versions of no-tax-on-tips bills differ — including in the scope of related deductions and reporting requirements — to meet any new compliance obligations and communicate with their employees, say attorneys at Greenberg Traurig.
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Series
Law School's Missed Lessons: Appreciating Civil Procedure
If you’re like me, law school’s often complex and theoretical approach to teaching civil procedure may have contributed to an early struggle with the topic, but when seen from a practical perspective, new lawyers may find they enjoy mastering these rules, says Chloe Villagomez at Foster Garvey.