Federal
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October 02, 2026
2nd Circ. Forges Own Path In Limited Partner Tax Ruling
The Second Circuit's decision limiting a self-employment tax break for limited partners with significant managerial roles reached a conclusion similar to that of a recent Fifth Circuit ruling, but practitioners said notable differences between them create a split requiring resolution by the IRS, the U.S. Supreme Court or Congress.
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October 02, 2026
Former Fla. Rep. Gets 10 Years In Venezuela FARA Case
A Florida federal judge on Friday sentenced ex-Florida Rep. David Rivera to 10 years in prison for failing to register as a foreign agent and laundering the proceeds of a $50 million contract with a unit of Venezuela's state-owned oil company.
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October 02, 2026
Taxation With Representation: Hogan Lovells, Davies, Sidley
In this week's Taxation With Representation, semiconductor company Advanced Micro Devices buys AI model developer and research lab World Labs, Brixmor Property Group and private investment management firm Everview Partners acquire Slate Grocery REIT, and cyberintelligence company REDLattice merges with blank check company Bold Eagle Acquisition Corp.
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October 02, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included the release of emissions rates used to calculate the tax credit amount for the domestic production of less-carbon-intensive transportation fuel.
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October 01, 2026
Tax Court OKs Denial Of Whistleblower Award For Bond Info
The IRS properly denied a whistleblower's award claim for reporting a nonprofit correctional corporation that he said failed to meet its tax obligations related to bonds it issued, the U.S. Tax Court ruled, saying the agency didn't collect proceeds from an investigation into the matter.
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October 01, 2026
IRS Proposes Scholarship Contribution Tax Credit Rules
The IRS proposed rules for the new federal tax credit for contributions to scholarship-granting organizations ahead of its planned launch at the start of 2027, including definitions of certain terminology and reporting requirements.
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October 01, 2026
Md. Cancer Research Lab Says $4.5M Tax Bill Unconstitutional
A Maryland cancer research laboratory that said it had no income in 2021 is contesting IRS tax assessments totaling $4.5 million, telling the U.S. Tax Court that the government's imputing of an underpayment violates the U.S. Constitution.
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October 01, 2026
NY Judge Gives Tax Preparers Initial OK For $1M OT Deal
A New York federal magistrate judge gave an initial green light to a $1.05 million class settlement to resolve claims brought by tax preparers who accused a New York tax preparation company of overtime and wage violations, finding the proposed agreement has no obvious deficiencies.
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October 01, 2026
Treasury Enrolls 60M Children In Trump Accounts
The U.S. Department of the Treasury has completed automatic enrollment for tax-advantaged brokerage accounts for children, known as Trump Accounts, enrolling more than 60 million American children in the program, the department announced Thursday.
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October 01, 2026
DOJ Outlines New Corporate Fraud Enforcement Priorities
Federal prosecutors "must place great weight" on a new list of factors when considering potential charges in corporate fraud cases, including whether the matters involve government programs, threats to national security or immigration offenses, according to a memo released Thursday by the U.S. Department of Justice.
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September 30, 2026
3rd Circ. Probes Payment Recipients In Fund's $100M Tax Row
A Third Circuit panel examined dealer-and-customer relations under accounting rules governing their transactions on Wednesday to determine whether the Internal Revenue Service was right to slap a $100 million tax bill against a Cayman Islands hedge fund for payments tied to U.S. portfolio companies.
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September 30, 2026
Senate Approves IRS Taxpayer Service Revamp
The Senate passed a wide-ranging bipartisan package Wednesday that would implement a slew of changes intended to improve taxpayer service, including a mandate that the agency digitize more tax returns and other correspondence.
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September 30, 2026
Tax Court Says Pair Can't Nullify Deadline Extension
The Internal Revenue Service timely sent notices regarding federal income tax deficiencies and accuracy-related penalties to a pair of Florida residents who challenged the agency's determinations, the U.S. Tax Court said Wednesday, rejecting the taxpayers' bid to void an agreement that extended the time for assessment.
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September 30, 2026
Landowners Seek 11th Circ. Redo On Easement Value Cut
Three Georgia conservation easement donors asked the full Eleventh Circuit to review a panel's split decision to slash the value of an easement they donated from $18 million to $1 million, saying the decision failed to take into account the property's highest and best use.
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September 30, 2026
Brothers Cop To Tax Crimes From Golf Side Hustle
Twin brothers pled guilty to failing to report $1.3 million in income to the Internal Revenue Service, including money made from a golf tee-time brokering business they ran as a side hustle, California federal prosecutors said.
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September 30, 2026
IRS Grants Relief To Taxpayers In Israel, West Bank, Gaza
Individuals and businesses in Israel, the West Bank and Gaza have additional time to file U.S. tax returns, make payments and perform other time-sensitive actions, the Internal Revenue Service said Wednesday.
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September 30, 2026
Polish Digital Tax Would Burden US Business, NFTC Says
The National Foreign Trade Council urged the Polish government to pause discussions about a proposed digital services tax, contending the measure would challenge international tax principles by disproportionately targeting U.S. companies.
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September 30, 2026
IRS Lists Budget Bill Guidance Among Top Priorities
Regulations to continue implementing the 2025 budget reconciliation bill are among the key items the Internal Revenue Service listed as priorities for the next 12 months, including guidance that would address changes to the base erosion and anti-abuse tax.
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September 30, 2026
Bessent Owes $910K In Taxes As Limited Partner, Wyden Says
Treasury Secretary Scott Bessent should pay more than $910,000 in payroll taxes as a hedge fund limited partner after the Second Circuit ruled that such partners are subject to the self-employment tax, Senate Finance Committee ranking member Ron Wyden said Wednesday.
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September 29, 2026
Tax Court Eschews IRS' Math In Facebook Royalty Dispute
The U.S. Tax Court rejected the IRS' proposed flat-rate royalty calculation for Facebook's deal with an Irish affiliate to develop intangibles, holding Tuesday that the rate should vary across asset categories and change over time to reflect underlying economic factors.
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September 29, 2026
IRS Plans To Scrap 71 More Guidance Docs Deemed Outdated
A revenue ruling that discussed prohibited allocations of securities in an S corporation and a notice that announced a higher withholding rate for gambling winnings are among dozens of guidance documents the IRS identified as extraneous and up for removal, the agency said Tuesday.
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September 29, 2026
IRS Issues Rules On Establishing Trump Accounts
The Internal Revenue Service released a guidance package Tuesday for tax-advantaged brokerage accounts for children, known as Trump Accounts, including temporary rules on how to establish one.
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September 29, 2026
Tax Court Approves Penalties On Captive Without Substance
The U.S. Tax Court on Tuesday approved IRS penalties imposed on policyholders of a California company's captive insurance policy that the agency determined to be lacking economic substance, finding they failed to report the transactions in their tax returns for 2015.
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September 29, 2026
Full 5th Circ. Asked To Review Limited Partner Tax Ruling
A Texas-based business consulting firm urged the Fifth Circuit's full bench to review a panel's revised opinion that narrowed a tax break for limited partners, arguing it eliminated a clear test for determining which partnership members are exempt from self-employment tax.
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September 29, 2026
Tax Co. Urges 5th Circ. To Deny Microcaptive Rules Case Stay
A global tax services provider asked the Fifth Circuit to deny the IRS' request to stay its challenge to the agency's reporting rules for microcaptive insurance companies pending the resolution of a similar case before the appeals court, saying it should be allowed to present its own arguments.
Expert Analysis
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Taekwondo Makes Me A Better Lawyer
Taekwondo has taught me to recognize when to fight for a position and when to focus on finding a solution, and that the best outcomes are often achieved by solving problems — all of which has improved my work as a bankruptcy lawyer, mediator and Subchapter V trustee, says Amy Denton Mayer at Berger Singerman.
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Where DOJ's Fraud Priorities Memo May Actually Matter
The U.S. Department of Justice’s recently released memo outlining priorities for its newly created fraud division will shape how cases are identified, staffed and sequenced, meaning white collar defense work must begin earlier, say David Tarras at Tarras Defense and Trevor Jones at Dynamis.
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Monitor Exposure, Stay Flexible Amid Tariff Uncertainty
To navigate an unstable trade environment, businesses must evaluate their exposure to new tariffs invoked under a patchwork of statutory authorities and be prepared to adapt to further changes that may be on the horizon, says Bhargav Prajapati at Capital Trade.
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Being In A Band Made Me A Better Lawyer
Playing shows in storied New York City venues and rehearsing with my bandmates in poorly ventilated rooms helped develop the professional qualities I rely on as a litigator, including an ability to collaborate with strong-minded equals and the determination to treat each client with singular focus, says Eliad Shapiro at Herrick Feinstein.
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The Divergent Approaches In US, EU Forced Labor Standards
Forced labor guidance documents recently issued by the U.S. and the European Union have meaningful differences, with the U.S. taking a documentary approach to compliance and the EU emphasizing human rights risks as a governance challenge, but one model will likely exert greater influence, say attorneys at Steptoe.
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Going To Hardcore Shows Makes Me A Better Lawyer
While government contracts law and the hardcore scene may seem entirely unrelated, in my experience, both are about community, focus, being prepared for the unexpected and managing chaos, says Isaac Natter at Fluet.
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Handling Section 301 Tariffs When CBP Detains Goods
Importers subject to Section 301 tariffs on goods under a U.S. Customs and Border Protection forced labor hold should consider three approaches when deciding whether to pay tariffs on goods that may ultimately be excluded, or wait and watch port demurrage compound daily, says James Ferry at Ferry Trade.
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Justices' FTC Ruling Weakens Qui Tam's Constitutional Base
The U.S. Supreme Court’s holding in Trump v. Slaughter, expanding presidential control over those exercising executive power, suggests that courts may be receptive to arguments challenging the constitutional foundations of the False Claims Act’s qui tam mechanism, says Daniel Passeser at Wiggin.
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5 Financial Statement Fraud Red Flags To Spot Post-Sripetch
The U.S. Supreme Court recently held in Sripetch v. U.S. Securities and Exchange Commission that disgorgement exists to strip a wrongdoer of unjust enrichment, not merely to compensate victims for what they lost, shifting the work at the center of securities fraud cases in five ways, says Rand Manasse at Green Lane Partners.
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Assessing The Benefits Of Fla.'s Newest Business Structure
As of July 1, Florida business owners can create protected series LLCs to shield assets from liability while avoiding increased costs and wasted time, but burdensome recordkeeping obligations are crucial to maintaining the very protection that makes them attractive in the first place, says Gregory Ritter at Moritt Hock.
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Justices' Tax Sale Ruling Tees Up Auction Fairness Battles
The U.S. Supreme Court’s recent decision in Pung v. Isabella County, Michigan, that taxpayers are not entitled to fair market value of real property seized to satisfy a tax debt shifts attention to the fairness of state and local auction procedures, and whether taxpayers claiming surplus proceeds face unwarranted hurdles, say attorneys at Miller Canfield.
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Judges On AI: Examining Administrative, Organizational Uses
U.S. District Judge Alan Albright of the Western District of Texas examines how artificial intelligence could transform a court's ability to deal with administrative work and organize materials when preparing for hearings or drafting opinions, thereby affording judges more time to resolve contested issues.
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Being A Magician Makes Me A Better Lawyer
The skills I've developed as a lifelong magician have translated directly into tangible benefits in the courtroom because performing magic and trying cases both live at the intersection of psychology, storytelling, timing and disciplined rehearsal, says Mark Dombroff at Fox Rothschild.