Federal

  • September 08, 2026

    IRS Sets Emission Guidance For Biofuel Tax Credit Eligibility

    The IRS released Tuesday the emissions rates use to calculate the tax credit amount for the domestic production of less carbon intensive transportation fuel, including those made primarily of organic materials and other compounds derived from livestock manure. 

  • September 08, 2026

    With New Tax Partner, Simpson Thacher Boosts Sports Focus

    Jonathan Westreich joined Simpson Thacher & Bartlett LLP as a tax partner in its Los Angeles office, the firm announced Tuesday, deepening the firm's sports, media and entertainment bench.

  • September 08, 2026

    IRS Accepting Applications To 2027 Real-Time Audit Program

    The Internal Revenue Service is accepting applications for its compliance assurance process real-time audit program for 2027, the agency announced Tuesday.

  • September 08, 2026

    Canada Defends Retaliatory Tariffs Against US As Necessary

    Canadian Prime Minister Mark Carney defended Canada's retaliatory tariffs against the U.S. as they went into effect Tuesday, saying they are needed to protect Canadian workers and industries from President Donald Trump's latest trade war action.

  • September 08, 2026

    DC Circ. Affirms Injunction Against IRS-ICE Data Sharing

    The D.C. Circuit affirmed a lower court's preliminary injunction Tuesday barring the IRS from sharing taxpayer data with immigration authorities, finding that the coalition challenging the deal has standing and that the arrangement likely violates the law.

  • September 04, 2026

    DOJ Ordered To Turn Over 'Weaponization' Fund Discovery

    A Virginia federal magistrate judge ordered the Trump administration Friday to move quickly in turning over documents connected to its proposed "Anti-Weaponization Fund," including the names of those who structured it before the idea was shot down in several federal courts and withdrawn by the U.S. Department of Justice.

  • September 04, 2026

    4 Books Transfer Pricing Economists Think You Should Read

    What do transfer pricing experts — economists, specifically — do in the summer? In July, many of them attend the National Association for Business Economics' annual transfer pricing symposium and discuss their favorite books with Law360 during the coffee breaks. Others were kind enough to do it during their regular work hours. Here, Law360 looks at four of their picks.

  • September 04, 2026

    IRS Finalizes 50% Personal-Use Test For Car Loan Tax Break

    A vehicle's amount of personal use would be based on the buyer's expected use over the period of ownership for purposes of determining eligibility for the tax break on car loan interest enacted in last summer's budget law, according to final regulations released Friday.

  • September 04, 2026

    ERISA Recap: 5 Appellate Rulings To Know From August

    The Seventh Circuit kept an Arkansas pharmacy benefit manager rule in place as not preempted by federal benefits law, the Fourth Circuit revived an Altria ex-worker's dispute over benefit plan documents, and the Eleventh Circuit reversed a pretrial win for Royal Caribbean in cruise workers' suit challenging 401(k) funds. Here, Law360 looks at those and two other major appellate decisions from August involving ERISA that benefits attorneys may want to know.

  • September 04, 2026

    Chrisleys Fight Balch & Bingham's Bid To Ax Malpractice Suit

    Reality television stars Todd and Julie Chrisley asked a Georgia federal judge on Friday to reject an attempt by their former attorneys to dismiss a legal malpractice lawsuit that claims a critical pretrial mistake allowed evidence obtained through an unlawful search to be used against them at their criminal trial.

  • September 04, 2026

    4th Circ. Affirms $2.9M IRS Fine For Unreported Accounts

    The Fourth Circuit affirmed a $2.9 million fine Friday against a Hong Kong-based U.S. businessman, holding that he should have known there was a "grave risk" of inaccurate tax filings when he failed to disclose offshore accounts to the IRS.

  • September 04, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, included proposed rules addressing the 2025 federal budget bill's changes to how U.S. corporations account for the earnings of their offshore affiliates when calculating their taxable income.

  • September 04, 2026

    IRS Updates Rules For Changing R&D Accounting Methods

    The Internal Revenue Service on Friday updated its guidelines for those looking to get automatic consent to change their method of accounting for research and development expenditures to comply with changes made in President Donald Trump's two major tax bills.

  • September 04, 2026

    IRS Spent 64% Of $26B Current Funding, Watchdog Says

    The Internal Revenue Service has already spent 64% of the $26 billion that Congress appropriated earlier this year for the agency through 2031, directing most of the money toward enforcement and taxpayer services, according to the tax administration watchdog's report. 

  • September 03, 2026

    Developer Seeks To Restore $78M In Conservation Tax Perks

    The Internal Revenue Service was wrong to disallow two conservation easement deductions worth a combined $78 million based on potential mining activity without adequately explaining why, an Alabama real estate developer told the U.S. Tax Court.

  • September 03, 2026

    Tax Court Keeps Innocent Spouse Case Over IRS Mail Flaw

    The Internal Revenue Service failed to establish that it properly mailed a final determination notice to a Nevada woman, the U.S. Tax Court said Thursday, denying the agency's motion to dismiss for untimely filing.

  • September 03, 2026

    Social Security Number Needed For COVID Rebate, Court Says

    The U.S. Tax Court rejected a man's bid to claim a COVID-19-era tax rebate credit Thursday because he didn't provide a Social Security number on his return, instead using an individual taxpayer identification number.

  • September 03, 2026

    IRS Needs To Improve Representation Training, TIGTA Says

    The Internal Revenue Service needs to overhaul training related to taxpayers' rights to representation and direct contact restrictions after a review found some employees lacked required knowledge, the Treasury Inspector General for Tax Administration said.

  • September 03, 2026

    IRS Could Improve Follow-Up On Rich Nonfilers, TIGTA Says

    The IRS could secure a tax return or make an assessment in over 10,000 cases involving wealthy nonfilers by taking further action on those cases after issuing an initial notice, the Treasury Inspector General for Tax Administration estimated in a report released Thursday.

  • September 03, 2026

    IRS Moves To Strip Schools' Tax Exemptions Over DEI Policies

    As many as 18,000 private schools that enact racially based diversity and inclusion policies could lose their federal tax exemptions under a proposed rule released by the Internal Revenue Service on Thursday.

  • September 02, 2026

    Technology Biz Can't Deduct $59M, Tax Court Says

    A California man's technology business can't deduct the $59 million in losses it claimed for 2016 and 2017, the U.S. Tax Court held Wednesday in a case in which it also rejected the IRS' determinations of his individual income.

  • September 02, 2026

    Airbnb Can't Nix IRS Expert In $1.3B Bill Fight, Tax Court Says

    The U.S. Tax Court denied Airbnb's bid to strike IRS expert witness reports from discovery proceedings in the company's challenge against a $1.3 billion tax bill, ruling Wednesday that a procedural rule governing expert testimony applies only to trials.  

  • September 02, 2026

    Vitamin Co. Can't Duck $1.4M Suit Over Ex-Owner's Tax Lien

    A vitamin company and its owners must face a suit by the federal government seeking $1.4 million stemming from a tax lien on a former owner's 20% interest in the company, a Connecticut federal judge ruled.

  • September 02, 2026

    11th Circ. OKs Refusal Of $1.5M Offer To End $140M Tax Debt

    The Eleventh Circuit rebuffed a software company founder's $1.5 million offer to settle his $140 million tax debt from 1999, ruling Wednesday that the IRS properly rejected the lowball offer in a case tied to sham arrangements.

  • September 02, 2026

    Lutnick Says Semiconductor Tariffs Are Coming, With Carveouts

    U.S. Secretary of Commerce Howard Lutnick on Wednesday said the U.S. is looking to issue a broad tariff on semiconductors, though he also said it would be structured such that companies that commit to U.S. manufacturing would be exempt.

Expert Analysis

  • Legal And Industry Impacts Of America's Maritime Action Plan

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    America's Maritime Action Plan, unveiled by the White House last month, introduces changes to trade investigations, a new maritime trust fund and more — adding regulatory and compliance obligations for companies and counsel, but also new avenues for client engagement in project finance, contract negotiation and dispute resolution, say attorneys at Holland & Knight.

  • 4 Ways To Help CBP Curb Shell Co. Import Schemes

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    Shifting to a proactive rather than reactive enforcement posture in addressing shell companies set up to skirt tariffs requires equipping U.S. Customs and Border Protection with enhanced investigative authorities, better intelligence support, and mechanisms to identify and hold accountable the ultimate illicit actors, say attorneys at Kelley Drye.

  • 7 Steps For Gov't Contractors In Post-IEEPA Tariff Landscape

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    In response to U.S. Supreme Court's recent decision to strike down tariffs issued by the Trump administration under the International Emergency Economic Powers Act, there are several actions federal contractors should take to preserve their place in any refund waterfall, and to manage audit, overpayment and False Claims Act risk, say attorneys at Holland & Knight.

  • The Benefits Of Choosing A Niche Practice In The AI Age

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    As artificial intelligence becomes increasingly accessible, lawyers with a niche practice may stand out as clients seek specialized judgment that automation cannot replicate, but it is important to choose a niche that is durable, engaging and a good personal fit, says Daniel Borneman at Lowenstein Sandler.

  • Section 122 Tariffs Show Shift In Strategy, Not Trade Policy

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    By imposing temporary tariffs under Section 122 of the Trade Act as a stopgap measure while it pivots to less transitory statutory authorities, the Trump administration sent a clear message that the U.S. Supreme Court’s decision in Learning Resources v. Trump, invalidating duties imposed under the International Emergency Economic Powers Act, will not precipitate a change in policy direction, say attorneys at Snell & Wilmer.

  • Tax Court Ruling Signals Cross-Border Loan Scrutiny

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    The U.S. Tax Court’s recent decision in Aventis v. Commissioner compounds ongoing regulatory focus on debt originations and should prompt practitioners to assess their existing cross-border lending structures for potential exposure to U.S. federal income tax, say attorneys at Eversheds.

  • Lessons From Justices' Split On Major Questions Doctrine

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    The justices' varied opinions in Learning Resources v. Trump, which held the International Emergency Economy Powers Act did not confer the power to impose tariffs, offer a meaningful window into the U.S. Supreme Court's perspective on the major questions doctrine that will likely shape lower courts' approach to executive action challenges, say attorneys at Venable.

  • Resilience Planning As Nat'l Security Shifts Tech Import Policy

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    In response to a sustained reorientation of U.S. trade policy around national security considerations, businesses reliant on processed critical minerals must closely monitor diplomatic negotiations and the potential expansion of trade measures, incorporating contingency planning into procurement and long-term investment strategies, says attorney Sohan Dasgupta.

  • How The New Tariff Landscape May Unfold

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    To replace tariffs formerly imposed under the International Emergency Economic Powers Act, the administration will rely on a patchwork of statutes, potentially leading to procedural challenges and a complex tariff landscape with varying levels, durations and applicability, says Joseph Grossman-Trawick at King & Spalding.

  • What Orgs. Should Note In IRS Group Tax Exemption Overhaul

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    In a significant update, the IRS Revenue Procedure 2026-8 shows that the group exemption program is moving into a new regulatory era involving more uniformity, oversight and compliance obligations, and early action is key to preserve group exemption status and avoid disruption for subordinate organizations, says Ravi Sundara at Spencer Fane.

  • How Banks Can Apply FinCEN Beneficial Ownership Relief

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    A recent Financial Crimes Enforcement Unit order limiting the circumstances under which banks should identify and verify beneficial owners may allow banks to tailor their approach to verification compliance, but only after reviewing customer due diligence policies and evaluating alignment with their risk profiles, say attorneys at Cleary.

  • Parsing Clarifications On Foreign Entity Rules For Tax Credits

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    Recent U.S. Internal Revenue Service and Treasury Department guidance answers taxpayer questions on several key foreign entity rules under the One Big Beautiful Bill Act, but questions remain over transactions with companies that have ties to covered nations such as Iran, say attorneys at Cleary.

  • Aligning Microsoft Tools With NYC Bar AI Recording Guidance

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    The New York City Bar Association’s recently issued formal opinion, providing ethical guidance on artificial intelligence-assisted recording, transcription and summarization, raises immediate questions about data governance and e-discovery for companies that use Microsoft 365 and Copilot, say Staci Kaliner, Martin Tully and John Collins at Redgrave.

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