Federal

  • July 13, 2026

    McKesson Says IRS Overreads Law Backing Pricing Rules

    Pharmaceutical giant McKesson asked a Texas federal court to invalidate transfer pricing regulations that underpin the company's $10 million tax refund bid, arguing the U.S. government mistakenly thinks the underlying statute gives the IRS "near-limitless authority" to define key terms.

  • July 13, 2026

    Biofuel Tax Fraudster Loses Bid For Extra Sentence Reduction

    A Utah federal judge declined to reduce further the original sentence of an accomplice in a $500 million biofuel production tax credit fraud scheme, finding that his prior reduction to 12 years had sufficiently reflected his cooperation in the trial of another defendant.

  • July 13, 2026

    US Biz Group Urges EU To Honor Side-By-Side Treatment

    A lobbying group representing U.S. companies called on the European Union to respect the country's side-by-side agreement as the bloc continues to work on a tax simplification overhaul.

  • July 13, 2026

    Trump-IRS Settlement Result Of Sham Suit, Judge Rules

    President Donald Trump's $10 billion suit against his own Internal Revenue Service and the resulting settlement deal lacked a legitimate controversy, given Trump's control over both the agency and the U.S. Department of Justice, a Florida district judge said Monday in an order barring Trump or others from citing the deal.

  • July 10, 2026

    Mattress Seller, Mo. Customers End Use Tax Overcharge Fight

    A Missouri federal court closed a class action by online customers claiming excessive tax charges by a mattress retailer after the parties reached a deal that will see the customers refunded.

  • July 10, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin included a revenue procedure to provide a gift tax reporting safe harbor for certain contributions to the new tax-advantaged brokerage accounts for newborns, known as Trump Accounts.

  • July 10, 2026

    IRS Defends Tax Court's Deduction In Arrest Injury Settlement

    The U.S. Tax Court correctly ruled that part of a man's $35,000 settlement payment from a Massachusetts town is deductible as damages paid for physical injuries, the IRS told the D.C. Circuit on Friday.

  • July 10, 2026

    US-Canada Stalemate Expected To Hold Amid USMCA Review

    The trade stalemate between the U.S. and Canada is likely to continue through a drawn-out review process for the U.S.-Mexico-Canada Agreement, though companies will benefit from an underlying level of stability as the deal remains in effect, trade lawyers said.

  • July 10, 2026

    Vague IRS Rules Should Nix Foreign Gift Penalties, Court Told

    A California civil service worker asked a federal court to waive penalties imposed by the IRS over her failure to report wedding gifts received from family in China, contending the agency was unclear about filing requirements.

  • July 10, 2026

    Taxation With Representation: Cleary, Paul Weiss, Fried Frank

    In this week's Taxation With Representation, Solstice Advanced Materials Inc. acquires specialty chemicals technology company Element Solutions Inc., Vertex Pharmaceuticals Inc. buys Crinetics Pharmaceuticals Inc., and Lockheed Martin acquires naval defense company Ultra Maritime.

  • July 09, 2026

    Judge Backs Feds' Valuation Method In Windfarm Grant Fight

    A U.S. Court of Federal Claims judge ordered several California wind farm owners and the federal government to largely employ a method the government proposed to value their facilities and hash out a decade-old dispute over grants worth hundreds of millions of dollars.

  • July 09, 2026

    Okla. Tax Officials Say McGirt Can't Upend Osage Ruling

    Oklahoma tax officials say the Osage Nation can't rely on a 2020 landmark U.S. Supreme Court ruling to overturn a decision that declined to vacate a 16-year-old determination that its reservation boundaries had been disestablished, telling the Tenth Circuit that the tribe's challenge is too late.

  • July 09, 2026

    IRS Asks 7th Circ. To Rehear $300M Hyatt Perks Tax Dispute

    The IRS asked the Seventh Circuit to reconsider its decision to remand a dispute over $300 million in Hyatt Hotels' loyalty rewards program fund to the U.S. Tax Court for it to determine whether the money can be excluded from taxable income under what's known as the claim of right doctrine.

  • July 09, 2026

    IRS Updates Outdated References In Estate Tax Rules

    The Internal Revenue Service released final regulations that modify and replace outdated references in rules for deceased taxpayers who have passed their property to a noncitizen spouse in a domestic trust.

  • July 09, 2026

    Reclassified Debt Didn't Cause $21M Gain, Partnership Says

    The IRS wrongly treated the reclassification of $21.1 million in debt to equity as a taxable event when hitting a partnership with $12.8 million in taxes, penalties and estimated interest, the partnership told the U.S. Tax Court.

  • July 09, 2026

    4th Circ. Rebuffs Tax Attys' Request To Rethink Convictions

    The Fourth Circuit will not rethink its decision last month affirming the convictions of two St. Louis attorneys accused of engineering a $22 million tax avoidance scheme.

  • July 09, 2026

    5 Clifford Chance Finance And Tax Attys Join Sidley In NY, DC

    Sidley Austin LLP announced Thursday that five Clifford Chance LLP attorneys have joined the firm's global finance and tax practices in New York and Washington, D.C.

  • July 09, 2026

    Pillar 2 Carveouts Won't Undercut Global Tax, Official Says

    The integrity of the 15% global minimum tax system will not be undermined by a host of nations gaining access to provisions that exempt them from certain obligations, the tax head at the Organization for Economic Cooperation and Development said Thursday.

  • July 08, 2026

    Partnership Defends $55.6M Deduction For Mo. Land Gift

    A partnership that donated over 73 acres in Butler County, Missouri, to a conservation group told the U.S. Tax Court it properly deducted $55.6 million for the gift, saying the value was based on the analysis of two qualified appraisers.

  • July 08, 2026

    IRS To Give Automatic Penalty Relief To Compliant Taxpayers

    Taxpayers with a history of filing and paying on time will no longer have to request penalty relief under an automatic exemption expected to roll out this summer, the IRS announced Wednesday.

  • July 08, 2026

    IRS Finalizes Life Insurance Reporting Exception Regs

    The Internal Revenue Service confirmed that certain tax-free transfers of life insurance contracts are exempt from the 2019 reporting rules for life settlement transactions, including policy sales and death benefit payments, under final regulations released Wednesday.

  • July 08, 2026

    IRS Urged To Make Digital Broker E-Statements Easier

    The IRS should update regulations that would allow digital asset brokers to provide statements electronically to remove operational hurdles and designate more effective communication methods, such as in-app messaging and SMS, stakeholders told the agency Wednesday.

  • July 08, 2026

    Shopping Center Owner's Estate Disputes $41M Deficiency

    The estate of a man who co-owned a Massachusetts shopping center challenged a $40.8 million deficiency assessment in the U.S. Tax Court, saying the IRS wrongly determined that a 2012 sale of his interest in the partnership owning the center wasn't bona fide.

  • July 08, 2026

    IRS Targets Certain Annuity Trusts As Potential Tax Shelters

    The IRS unveiled final rules Wednesday designating certain charitable remainder annuity trusts as reportable transactions because they involve abusive tax avoidance practices, subjecting participants to potential penalties if they do not disclose such arrangements.

  • July 08, 2026

    Foley Adds Attys From Kirkland, Goodwin To Corporate Team

    Foley & Lardner LLP has strengthened its corporate bench with a Dallas-based partner who came aboard from Kirkland & Ellis LLP and a Boston-based partner from Goodwin Procter LLP.

Expert Analysis

  • Tax Court Ruling Sets High Bar For Limited Partner Exception

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    The U.S. Tax Court’s recent decision in Soroban Capital Partners v. Commissioner endorsed the IRS’ use of functional analysis to determine whether the limited partner exception applied for taxation under the Self-Employed Contributions Act, highlighting the intense factual analysis that will occur during audits, says Erin Hines at Akerman.

  • How AI May Reshape The Future Of Adjudication

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    As discussed at a recent panel at Texas A&M, artificial intelligence will not erase the human element of adjudication in the next 10 to 20 years, but it will drive efficiencies that spur private arbiters to experiment, lead public courts to evolve and force attorneys to adapt, says Christopher Seck at Squire Patton.

  • When Legal Advocacy Crosses The Line Into Incivility

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    As judges issue sanctions for courtroom incivility, and state bars advance formal discipline rules, trial lawyers must understand that the difference between zealous advocacy and unprofessionalism is not just a matter of tone; it's a marker of skill, credibility and potentially disciplinary exposure, says Nate Sabri at Perkins Coie.

  • Attacks On Judicial Independence Tend To Manifest In 3 Ways

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    Attacks on judicial independence now run the gamut from gross (bald-faced interference) to systemic (structural changes) to insidious (efforts to undermine public trust), so lawyers, judges and the public must recognize the fateful moment in which we live and defend the rule of law every day, says Jim Moliterno at Washington and Lee University.

  • Increased Tariffs Create Opportunity To Protect IP Rights

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    Heightened tariffs on certain foreign imports have created operational and fiscal challenges for companies, but the corresponding increase in customs inspections could offer a silver lining of more consistent enforcement against counterfeit and infringing goods, says Andraya Pulaski Brunau at Day Pitney.

  • Dissecting House And Senate's Differing No-Tax-On-Tips Bills

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    Employers should understand how the House and Senate versions of no-tax-on-tips bills differ — including in the scope of related deductions and reporting requirements — to meet any new compliance obligations and communicate with their employees, say attorneys at Greenberg Traurig.

  • Section 899 Could Be A Costly Tax Shift For US Borrowers

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    Intended to deter foreign governments from applying unfair taxes to U.S. companies, the proposal adding new Section 899 to the Internal Revenue Code would more likely increase tax burdens on U.S. borrowers than non-U.S. lenders unless Congress limits its scope, says Michael Bolotin at Debevoise.

  • Calif. Bar Exam Fiasco Shows Why Attys Must Disclose AI Use

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    The recent revelation that a handful of questions from the controversial California bar exam administered in February were drafted using generative artificial intelligence demonstrates the continued importance of disclosure for attorneys who use AI tools, say attorneys at Troutman.

  • In 2nd Place, Va. 'Rocket Docket' Remains Old Reliable

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    The U.S. District Court for the Eastern District of Virginia was again one of the fastest civil trial courts in the nation last year, and an interview with the court’s newest judge provides insights into why it continues to soar, says Robert Tata at Hunton.

  • How Attorneys Can Become Change Agents For Racial Equity

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    As the administration targets diversity, equity and inclusion efforts and law firms consider pulling back from their programs, lawyers who care about racial equity and justice can employ four strategies to create microspaces of justice, which can then be parlayed into drivers of transformational change, says Susan Sturm at Columbia Law School.

  • Adapting To Private Practice: From US Attorney To BigLaw

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    When I transitioned to private practice after government service — most recently as the U.S. attorney for the Eastern District of Virginia — I learned there are more similarities between the two jobs than many realize, with both disciplines requiring resourcefulness, zealous advocacy and foresight, says Zach Terwilliger at V&E.

  • Opportunity Zone Revamp Could Improve The Program

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    If adopted, the budget bill's new iteration of the opportunity zone program could renew, refine and enhance the effectiveness and accountability of the original program by including structural reforms, expanded eligibility rules and incentives for rural investment, say attorneys at Pillsbury.

  • The Ins And Outs Of Consensual Judicial References

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    As parties consider the possibility of judicial reference to resolve complex disputes, it is critical to understand how the process works, why it's gaining traction, and why carefully crafted agreements make all the difference, say attorneys at Pillsbury.

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