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Stephen Josey and Quentin Manuel examine how the IRS enforces civil tax fraud penalties within the federal tax system, offering practitioners key insights into the legal standards, evidentiary burdens, and practical consequences involved. They explain how civil fraud differs from negligence and criminal tax fraud, highlight the IRS’s reliance on circumstantial evidence and badges of fraud, and outline the significant financial and legal risks taxpayers face when fraud is found. They also address defenses available to taxpayers and emphasize the importance of distinguishing between intentional misconduct and good-faith mistakes in today’s enforcement environment.
Published by Taxes The Tax Magazine®
On July 29, 2025, Attorney General Pam Bondi issued a memorandum offering specific examples of what the U.S. Department of Justice (“DOJ”) considers to be unlawful discriminatory policies and practices under federal civil rights laws, as well as recommendations on best practices for employers to avoid engaging in unlawful discrimination.
V&E Governance & Sustainability Update
As the Trump administration continues to roll out its sweeping tariff policy, the North American energy industry is working to address the effects of the President’s tariff strategy. The Trump administration intends to “unleash American energy,”1 in part by imposing tariffs designed to remedy what the administration views as unfair trade practices and increase U.S. domestic energy production. The currently imposed and threatened tariffs will inevitably impact the energy industry and its consumers. The particularly relevant tariffs can be defined in two broad categories: (1) sectoral tariffs, in this case, imposed under Section 232 of the Trade Expansion Act of 1962, and (2) the country-specific and “reciprocal tariffs” that the Trump administration has imposed under the International Emergency Economic Powers Act.
Published by RiEnergia, July 2025
On July 8th, 2025, President Trump issued an order (the “Order”) forcing divestment of U.S.-based Jupiter Systems (“Jupiter”) by its China-based parent company, Suirui Group Co., Ltd. (“Suirui”), more than five years after Suirui acquired Jupiter.
V&E CFIUS Update
Joyce Adetutu, Jason Fleischer, and Stephen Josey emphasize that the unresolved legal status of the IEEPA tariffs creates significant uncertainty for importers. With the tariffs still being collected during appeal, businesses risk overpaying and should consider filing protests to safeguard potential refunds. To navigate this shifting landscape, importers must stay alert to liquidation deadlines and build tariff-related contingencies into their contracts.
Published by Energy Intelligence
On July 4, 2025, President Donald J. Trump signed the One Big Beautiful Bill Act (the “OBBBA”) into law. Congress passed the OBBBA through budget reconciliation, a special legislative process that allows Congress to advance certain tax, spending, and debt limit legislation with a simple majority vote in the Senate so long as the legislation does not increase the federal budget deficit outside a 10-year budget window.
V&E Tax Update
On July 1, 2025, a little over two weeks after the Senate Finance Committee released its draft tax title (the “Initial Senate Draft”), the U.S. Senate secured sufficient votes to advance its version of the “One Big Beautiful Bill Act” (the “OBBBA”) — a comprehensive budget reconciliation bill — back to the House of Representatives, which voted in favor of the bill on July 3, 2025.
On July 4, 2025, President Trump signed the “One Big Beautiful Bill Act” (H.R. 1 119th Congress) (“OBBBA”) into law.
V&E Renewable Energy Update
The federal government is continuing to implement President Donald Trump’s Unleashing American Energy mandate to promote domestic energy and infrastructure projects.
V&E Environmental Update
On June 16, 2025, the Senate Finance Committee released its draft tax title for inclusion in the Senate’s version of the budget reconciliation bill, known as the “One Big Beautiful Bill Act” (the “OBBBA”).