Federal

  • June 29, 2026

    Partnership Asks To Restore $3.7M In Captive Deductions

    The IRS shouldn't have disallowed more than $3.7 million in deductions claimed by a partnership on premiums paid to five captive insurance companies because the transactions had economic substance, the partnership told the U.S. Tax Court.

  • June 29, 2026

    Cole Schotz Adds Tax Atty In Miami From Day Pitney

    Cole Schotz PC announced Monday that it has hired a Day Pitney LLP attorney to bolster its capacity to advise high-net-worth individuals and other clients on tax, trust and estate matters.

  • June 29, 2026

    Tax Attys Cite Justices' Venue Ruling In Seeking 4th Circ. Redo

    A father-daughter attorney duo is asking the full Fourth Circuit to rethink their convictions in a $22 million tax avoidance scheme, arguing a U.S. Supreme Court decision that came down just two days after a panel affirmed their guilty verdicts supports their argument that prosecutors pursued charges in the wrong state.

  • June 29, 2026

    Justices Strike Down Humphrey's Presidential Firing Limits

    The president has unlimited authority to fire members of independent agencies, the U.S. Supreme Court ruled Monday in a major win for President Donald Trump's campaign against officials at the Federal Trade Commission and beyond.

  • June 26, 2026

    PACER Fees Will Rise To Fund Cyber Defense Upgrades

    The federal judiciary announced Friday it will temporarily increase the fees for electronic access to court records to pay for a potential $800 million upgrade that will modernize and strengthen court records systems PACER and CM/ECF, an upgrade it previously said is needed to respond to escalating cyberattacks.

  • June 26, 2026

    Firm Can't Shoot Down IRS Microcaptive Rules, Court Says

    The IRS' reporting rules for microcaptive insurance companies aren't unreasonable, a Texas federal court said Friday, shooting down a global tax consultancy's bid to vacate them.

  • June 26, 2026

    Treasury Wary Of Challenges After Loper Bright, Official Says

    The U.S. Department of the Treasury is less likely to take regulatory positions that could be challenged partly because of the heightened litigation risk following the U.S. Supreme Court's Loper Bright ruling, a department official said Friday.  

  • June 26, 2026

    High Court Ruling Backs Broker On IRS Penalty, Court Told

    A recent U.S. Supreme Court decision upholding agency fines without a jury trial supports an insurance broker's challenge to a $6.6 million tax penalty imposed by the Internal Revenue Service, the broker told a Pennsylvania federal court.

  • June 26, 2026

    Trump Threatens 100% Tariff For EU Nations Planning DSTs

    President Donald Trump threatened to impose a 100% tariff on imports entering the U.S. from countries in the European Union planning to levy new digital service taxes, according to a social media post Friday.

  • June 26, 2026

    Tax Court Tosses Meta's Interest Claim In $16B Dispute

    The U.S. Tax Court said it has no jurisdiction to hear Meta's challenge to the IRS assessing interest on the company until it has decided whether a deficiency or overpayment exists in the company's underlying case over a $15.9 billion tax bill, according to an order.

  • June 26, 2026

    IRS Mulling Digital Asset Disclosure Program, Official Says

    The Internal Revenue Service is weighing whether to create a stand-alone voluntary disclosure practice for digital assets, the head of the agency's criminal investigation unit said Friday.

  • June 26, 2026

    Taxation With Representation: Sidley, Paul Weiss, Kirkland

    In this week's Taxation With Representation, Germany's Merck KGaA acquires life sciences tools supplier Bio-Techne Corp., drugmaker AbbVie buys clinical-stage biotechnology company Apogee Therapeutics, and building materials supplier CRH acquires infrastructure products maker Arcosa Inc.

  • June 26, 2026

    DOJ Fraud Division To Prioritize Tax Crimes, Official Says

    The new fraud enforcement division at the U.S. Department of Justice is moving to pursue tax fraud crimes aggressively, an official said Friday, saying the division is characterizing the effort as an "emergency" to maximize efforts.

  • June 26, 2026

    DOJ Tax Litigation Official Expects Appellate Cases To Rise

    More tax cases are likely to be appealed as textualist interpretations of statutes gain in suits and litigants increasingly invoke recent U.S. Supreme Court precedent, a U.S. Department of Justice official said Friday.

  • June 25, 2026

    Black & Decker Owes Tariff Plan Refunds, DeWalt Buyer Says

    A DeWalt tools purchaser on Thursday filed a proposed class action against its parent company, Stanley Black & Decker, claiming that the company hiked prices as a result of tariffs that were later deemed illegal and now owes consumers refunds as a result.

  • June 25, 2026

    11th Circ. Judges Question Coke's View Of IRS As Arbitrary

    Judges for the Eleventh Circuit probed attorneys for Coca-Cola and the government Thursday about whether the IRS was arbitrary in abandoning its position in a closing agreement the beverage company had relied on for decades to calculate its transfer prices with related foreign suppliers.

  • June 25, 2026

    SCOTUSblog Founder Goldstein Blasts 'Inflated' DOJ Tax Math

    Convicted SCOTUSblog founder Tom Goldstein and federal prosecutors are clashing again over their dramatically divergent sentencing recommendations, with the defense accusing the government of presenting a "one-dimensional caricature" of the famed lawyer in seeking an eight-year sentence, and prosecutors accusing him of potentially deleting "secret chats" with his gambling backers.

  • June 25, 2026

    NC Tax Preparer Will Pay $13.9M For COVID Refund Scheme

    A North Carolina woman who owned a tax return preparation business will be ordered to pay just under $13.9 million after she pled guilty to conspiring to prepare false tax returns, according to a press release from the U.S. Attorney's Office for the Eastern District of North Carolina.

  • June 25, 2026

    Clinic Manager Asks 4th Circ. To Upend 6-Year Fraud Sentence

    A clinic manager who paid patients in gift cards is challenging her six-year prison sentence, telling the Fourth Circuit on Thursday that a federal judge failed to consider other mitigating factors when sentencing her for healthcare fraud and failing to file a tax return.

  • June 25, 2026

    Spanish Broadcasting Gets Green Light For Ch. 11 Plan

    A Delaware bankruptcy judge said Thursday he will confirm Spanish-language radio station operator Spanish Broadcasting System's Chapter 11 plan once he gets the final draft of its plan documents, largely overruling an outstanding objection.

  • June 25, 2026

    IRS Had No Exit Strategy For Cloud-Run Systems, TIGTA Says

    Most of the IRS' cloud-managed contracts did not include all elements of an exit strategy that would allow the agency to transition seamlessly to an alternative cloud if necessary, the Treasury Inspector General for Tax Administration said in a report Thursday.

  • June 25, 2026

    IRS 'Embracing' AI For Fraud Checks, Agency Official Says

    The IRS is "embracing" artificial intelligence to help with taxpayer compliance, such as using the technology to detect patterns and identify fraud, while at the same time working with guardrails to protect private information, an agency official said Thursday.

  • June 25, 2026

    EU Implements US Trade Deal, With Safeguards

    The European Union granted final approval Thursday to its modified version of a trade deal with the U.S. that will cut tariff rates on U.S. goods, albeit with guardrails.

  • June 25, 2026

    Tax Court To Try Out Holding Sessions At Law Schools

    The U.S. Tax Court will launch a law school outreach initiative this year in which the court will hold a session at a school to strengthen engagement with taxpayers and help cultivate future tax professionals, the court's chief judge announced Thursday.

  • June 25, 2026

    IRS Correctly Withheld Info In FOIA Requests, TIGTA Says

    The Internal Revenue Service correctly withheld information in 97% of Freedom of Information Act requests sampled by the Treasury Inspector General for Tax Administration, according to a report released Thursday.

Expert Analysis

  • 5 Real Estate Takeaways From Trump's Sweeping Tax Law

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    Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.

  • Evaluating The Current State Of Trump's Tariff Deals

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    As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.

  • How Hyperlinks Are Changing E-Discovery Responsibilities

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    A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.

  • Preserving Refunds As Tariffs Await Supreme Court Weigh-In

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    In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.

  • Revamped Opportunity Zones Can Aid Clean Energy Projects

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    The Qualified Opportunity Zone program, introduced in 2017 and reshaped in the One Big Beautiful Bill Act, offers investors federal tax incentives for development in low-income communities — incentives that are especially meaningful for clean energy projects, where capital-intensive infrastructure and long-term planning are essential, say attorneys at Dentons.

  • Writing Musicals Makes Me A Better Lawyer

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    My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.

  • How Fashion, Tech Can Maximize New Small Biz Tax Breaks

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    Fashion and technology companies, which invest heavily in innovation, should consider taking advantage of provisions in the One Big Beautiful Bill Act that favor small businesses, restructuing if necessary to become eligible for expanded research and experimental expenditure credits and qualified small business stock incentives, says Aime Salazar at Olshan Frome.

  • Adapting To Private Practice: From Va. AUSA To Mid-Law

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    Returning to the firm where I began my career after seven years as an assistant U.S. attorney in Virginia has been complex, nuanced and rewarding, and I’ve learned that the pursuit of justice remains the constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.

  • 7 Document Review Concepts New Attorneys Need To Know

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    For new associates joining firms this fall, stepping into the world of e-discovery can feel like learning a new language, but understanding a handful of fundamentals — from coding layouts to metadata — can help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.

  • Agentic AI Puts A New Twist On Attorney Ethics Obligations

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    As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.

  • Opportunity Zone's Future Corp. Tax Benefits Still Uncertain

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    Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.

  • How GILTI Reform Affects M&A Golden Parachute Planning

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    Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.

  • What To Expect As Trump's 401(k) Order Materializes

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    Following the Trump administration’s recent executive order on 401(k) plan investments in alternative assets like cryptocurrencies and real estate, the U.S. Department of Labor and the U.S. Securities and Exchange Commission will need to answer several outstanding questions before any regulatory changes are implemented, say attorneys at Cleary.

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