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Tax
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July 21, 2025
Captive's Premium Payments Are Income, Tax Court Says
A captive insurance company must recognize $782,000 it received in premium payments as income, the U.S. Tax Court said Monday in clarifying that shareholders in a California company cannot deduct their premium payments to the insurer because the arrangement was not really for insurance.
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July 21, 2025
Wis. Homeowners Lack Basis For Tax Burden Suit, Court Told
A Wisconsin county, town and tribal school district pushed a federal court to throw out a suit by homeowners who claim the government entities have conspired to expand the Menominee Indian Tribe's holdings of tax-exempt land and increase taxpayers' burden, saying the homeowners lacked standing.
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July 21, 2025
Rising Star: Davis Polk's Aliza Slansky
Aliza Slansky of Davis Polk & Wardwell LLP is lead counsel in Sycamore Partners' $23 billion acquisition of Walgreens Boots Alliance and advised Missouri tech company Emerson on a series of multibillion-dollar sales, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 21, 2025
UK Co. Faces £1M Penalty For Failing To Report Tax Scheme
HM Revenue & Customs was right to determine that a company had promoted a contractor loan tax scheme, a London tribunal ruled, finding the Manchester-based business liable for up to £1 million ($1.3 million) in penalties.
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July 21, 2025
Paul Hastings Boosts Tax Team In NY With Ex-Kirkland Atty
Paul Hastings LLP announced Monday that a former Kirkland & Ellis LLP attorney is bringing her tax practice to its New York office in a move the firm says will bolster its ability to guide clients through complex deals like mergers, acquisitions and private equity transactions.
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July 18, 2025
Law360 Names 2025's Top Attorneys Under 40
Law360 is pleased to announce the Rising Stars of 2025, our list of more than 150 attorneys under 40 whose legal accomplishments belie their age.
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July 18, 2025
Judge Demands Layoff Plans From Trump Administration
A California federal judge on Friday ordered the Trump administration to hand over reorganization and reduction-in-force plans linked to an executive order directing layoffs at federal agencies, finding that the government's privilege claim was outweighed by the plaintiffs' need for the information to pursue their claims under the Administrative Procedure Act.
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July 18, 2025
​​​​​​​3rd Circ. Pick 'Respected' By Trump, Mysterious To Senators
The senior White House lawyer nominated to represent Delaware on the Third Circuit is a constitutional scholar and presidential immunity defender touted as "highly respected" by President Donald Trump, although some Delaware lawmakers have questioned her ties to the First State.
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July 18, 2025
DC Circ. Affirms Toss Of Tax Pros' PTIN User Fee Challenge
A D.C. federal court properly dismissed a lawsuit by tax return preparers challenging the IRS' process for issuing their special identification numbers, the D.C. Circuit ruled Friday, saying the suit violated rules against filing duplicate claims.
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July 18, 2025
Mass. Advocates Pitch Doubling Real Estate Transfer Fee
Massachusetts would double its real estate transfer fee to raise an estimated $300 million annually for affordable housing and climate mitigation efforts under legislation pitched to a state legislative panel by housing and environmental advocates.
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July 18, 2025
Trump Asks Supreme Court To Decline Early Tariff Challenge
President Donald Trump's administration urged the U.S. Supreme Court to reject a request from Illinois-based toy makers to hear their challenge against the White House's global tariffs, arguing the justices should not "leapfrog" parallel proceedings in circuit courts.
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July 18, 2025
Taxation With Representation: Wachtell, Slaughter And May
In this week's Taxation With Representation, Blackstone pours billions into data centers and related infrastructure, Waters Corp. and Becton Dickinson look to form a new life sciences powerhouse, Reckitt sells 70% of its Essential Home business to private equity firm Advent, and Chevron completes its acquisition of Hess following a favorable arbitral award.
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July 18, 2025
European Tax Policy To Watch In 2nd Half Of 2025
The European Union looks set to collide with President Donald Trump's administration unless a trade deal can be secured soon, while the future of the global minimum tax rules looks far more doubtful than at the start of the year. Here, Law360 looks at current EU tax policy to determine what developments businesses should be watching over the next six months.
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July 18, 2025
Oregon To Issue Report On Property Tax System
The Oregon legislative revenue officer will issue a report on the state's property tax system and options to modernize it under legislation signed into law by the governor.
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July 17, 2025
Uber Asks Ga. Justices To Reverse Sales Tax Ruling
Georgia's highest court should review and reverse an appellate panel's decision that Uber was required to collect and remit millions in sales taxes on behalf of drivers and customers who used its app before the Wayfair decision, the ride-hailing company told the state's justices.
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July 17, 2025
US Negotiating Global Min. Tax Carveout Accord, Official Says
The U.S. hasn't yet secured an agreement with other countries to exempt its companies from the international parts of the 15% global minimum tax despite reaching an "understanding" with the Group of 7 nations, but wider negotiations have begun, a U.S. Treasury Department official said Thursday.
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July 17, 2025
Tax Auditor's Disability Bias Suit Dismissed For Late Filing
A federal judge tossed a tax auditor's suit claiming a North Carolina county yanked her intermittent leave disability accommodation for health flare-ups that made it hard to drive to work, rejecting her bid to toll the statute of limitations due to a lawyer's bad advice.
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July 17, 2025
IRS Leaker Asks DC Circ. To Bar Comments By Ex-Employer
A tech worker appealing a five-year sentence for leaking tax returns while on the job at the IRS through contractor Booz Allen asked the D.C. Circuit on Thursday to block his former employer from weighing in, saying the company's opinion that he should finish his prison term is irrelevant.
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July 17, 2025
EU Lawmakers Push For Tax Data Hub To Combat Evasion
Members of the European Parliament approved proposals for tax changes across the European Union, including a tax data hub to streamline compliance across the bloc and help combat tax avoidance and evasion.
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July 17, 2025
5th Circ. Affirms Nix Of Doctor's Captive Insurance Deductions
The owner of a Texas urgent care network is not entitled to $1 million in tax deductions for insurance premiums he paid to inside companies, the Fifth Circuit ruled, affirming the U.S. Tax Court's decision that the payments were not actually for insurance.
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July 16, 2025
Trump Taps Ex-Thomas, Kavanaugh Clerk For 3rd Circ.
President Donald Trump announced on social media Wednesday that he has chosen a Catholic University of America law professor, who is currently serving in the White House Counsel's office and has clerked for U.S. Supreme Court Justices Clarence Thomas and Brett Kavanaugh, to serve on the Third Circuit.
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July 16, 2025
House Panel Urged To Modernize Tax Rules For Digital Assets
Congress needs to create tax rules for digital assets such as cryptocurrency and nonfungible tokens because the current regime is burdensome for businesses and pushing development out of the U.S., industry representatives told a House Ways and Means Committee subcommittee Wednesday.
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July 16, 2025
Mich. Judge Upholds Propane Assessment After Retailer Vote
A judge dismissed a challenge to an assessment levied on sales of propane in Michigan on Wednesday, finding the state's propane retailers authorized it by vote.Â
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July 16, 2025
Speaker's Aide Won't Rule Out 'Secure 3.0' Retirement Bill
An aide to House Speaker Mike Johnson told tax attorneys in Washington, D.C., Wednesday that he's not ruling out Congress passing a retirement policy overhaul that's known informally as Secure 3.0, though exact timing on such an effort remains unclear because of the busy year-end schedule.
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July 16, 2025
USTR To Probe Brazil's Trade Practices For Possible Tariffs
The Office of the U.S. Trade Representative announced Tuesday evening it will launch an investigation into Brazil's trade practices to determine whether tariff actions could be necessary after a request by President Donald Trump and prior tariff threats.
Expert Analysis
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NY Tax Talk: Sourcing, Retroactivity, Information Services
Attorneys at Eversheds Sutherland examine recent decisions by New York’s Tax Appeals Tribunal, Division of Taxation and Court of Appeals on location sourcing of broker-dealer receipts, a case of first impression on the retroactive application of Corporate Franchise Tax regulations and when fees for information services are excluded from taxation.
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Legal Ethics Considerations For Law Firm Pro Bono Deals
If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.
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Series
Playing Football Made Me A Better Lawyer
While my football career ended over 15 years ago, the lessons the sport taught me about grit, accountability and resilience have stayed with me and will continue to help me succeed as an attorney, says Bert McBride at Trenam.
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10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks
The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.
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Series
Power To The Paralegals: The Value Of Unified State Licensing
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.
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10 Soft Skills Every GC Should Master
As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.
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An Unrestrained, Bright-Eyed View Of Legal AI's Future
Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.
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Tracking The Evolution In Litigation Finance
Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.
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Series
Volunteer Firefighting Makes Me A Better Lawyer
While practicing corporate law and firefighting may appear incongruous, the latter benefits my legal career by reminding me of the importance of humility, perspective and education, says Nicholas Passaro at Ford.
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Tax Takeaways From Georgia's 2025 Legislative Session
Attorneys at Eversheds Sutherland discuss tax-related measures passed by the Georgia Legislature during the session that adjourned on April 4, which included a decrease in income tax rates, an extension of the time in which to a protest tax assessment and cleanup provisions related to launching the state’s new tax court next year.
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E-Discovery Quarterly: The Perils Of Digital Data Protocols
Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.
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Maximizing Exemptions Before TCJA Rides Into The Sunset
Excerpt from
Individuals with taxable estates can optimize the benefits of estate planning strategies like spousal lifetime access trusts by setting them up before increases in estate and gift tax exemptions under the 2017 Tax Cuts and Jobs Act sunset in January, say attorneys at Katten.
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Series
Law School's Missed Lessons: Preparing For Corporate Work
Law school often doesn't cover the business strategy, financial fluency and negotiation skills needed for a successful corporate or transactional law practice, but there are practical ways to gain relevant experience and achieve the mindset shifts critical to a thriving career in this space, says Dakota Forsyth at Olshan Frome.
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A Cold War-Era History Lesson On Due Process
The landmark Harry Bridges case from the mid-20th century Red Scare offers important insights on why lawyers must be free of government reprisal, no matter who their client is, says Peter Afrasiabi at One LLP.
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Series
Improv Makes Me A Better Lawyer
Improv keeps me grounded and connected to what matters most, including in my legal career where it has helped me to maintain a balance between being analytical, precise and professional, and creative, authentic and open-minded, says Justine Gottshall at InfoLawGroup.