Federal

  • September 23, 2026

    Judge Dismisses Son's Bid To Recoup Parents' Tax Payments

    A Tennessee federal judge dismissed a son's bid for a refund of federal income taxes for his dead parents' estates, finding he failed to establish that his father sufficiently participated in an amusement equipment manufacturing business to claim associated losses.

  • September 22, 2026

    IRS Requests Comments On Proposed Opportunity Zone Regs

    The Internal Revenue Service on Tuesday requested comments on the implementation of the federal opportunity zone program, including whether additional guidance is needed to address issues related to opportunity fund investment.

  • September 22, 2026

    Atty Urges 4th Circ. To Reverse Liability For Client's Taxes

    A Baltimore attorney asked the Fourth Circuit to reverse a lower court's order that he cover unpaid federal income taxes owed by his client's holding company, saying he didn't engage in self-dealing.

  • September 22, 2026

    8th Circ. Asked To Nix Fraud Tax Credit Suit, $90M Judgment

    A man accused of helping form a sham limited liability company that fraudulently received millions in alternative fuel mixture tax credits asked the Eighth Circuit on Tuesday to reverse a judgment of more than $90 million against him, saying he shouldn't be personally liable for the company's conduct.

  • September 22, 2026

    US Asks 5th Circ. To Revive IRS Deal On Church Politicking

    The U.S. government urged the Fifth Circuit to revive its deal with four religious groups to allow churches to engage in some political speech without losing their tax-exempt status, saying a lower court improperly dismissed the case in its entirety for lack of jurisdiction.

  • September 22, 2026

    Tax Court OKs $21M Easement Cut In Appeal Process Fight

    The IRS did not wrongfully deny a holding company the chance to appeal a reevaluation that lopped $21 million off the value of a Tennessee conservation easement for which it claimed a deduction, the U.S. Tax Court ruled Tuesday.

  • September 22, 2026

    Dispensary's Tax Deduction Properly Nixed, IRS Tells 9th Circ.

    The U.S. Tax Court correctly ruled that a San Francisco marijuana dispensary's expenses found to be tied to trafficking in controlled substances aren't deductible, the IRS told the Ninth Circuit, saying such a deduction shouldn't be allowed in determining an amount to settle the business's $3 million tax debt.

  • September 22, 2026

    Virgin Islands Tax Agency Can't Ignore Treasury, Judge Says

    The U.S. Supreme Court's 2024 Loper Bright decision does not allow U.S. Virgin Islands revenue collectors to override U.S. Treasury Department regulations exempting residents of the territory from the net investment income tax, a federal judge held.

  • September 21, 2026

    Xbox Buyer Says IEEPA Refund Arbitration Bid Lacks Backing

    Microsoft's bid to force arbitration of an Xbox purchaser's proposed class action accusing the video game giant of wrongfully withholding tariff refunds from consumers should fail because it can't point to a clause that covers his dispute, he told a Washington federal court.

  • September 21, 2026

    IRS Properly Nixed Tax Deals, Couple Owe $1.8M, Judge Says

    A disbarred lawyer and his wife owe more than $1.8 million in outstanding tax liabilities the IRS has tried to collect for more than a decade, a Wisconsin federal judge said, finding the agency substantiated the liabilities and confirmed that it properly rescinded compromise offers to resolve the debts.

  • September 21, 2026

    Partnership Was Diligent After Notice Got Lost, Court Says

    A partnership's late-filed petition in the U.S. Tax Court was due to circumstances beyond its control in a case where the final partnership adjustment from the IRS was mailed correctly but returned by the U.S. Postal Service as undeliverable, the court held Monday.

  • September 21, 2026

    IRS Can Enforce Summons In Korean Probe Of VC Partner

    The IRS can enforce a summons seeking bank information about a venture capitalist on behalf of South Korean tax authorities, a California federal judge ruled, holding that the statutory requirement to provide advance notice applies only to domestic tax liabilities.

  • September 21, 2026

    IRS Again Delaying Dividend Anti-Abuse Regs

    The IRS is again extending the transition period for rules that govern certain financial transactions that could avoid withholding on dividend payments to foreign taxpayers, the agency announced Monday.

  • September 21, 2026

    IRS' Economic Substance Doctrine Has Limits, 5th Circ. Told

    The IRS should not invoke the economic substance doctrine whenever it dislikes a transaction's tax consequences, an advocacy group told the Fifth Circuit on Monday in an eye doctor and his wife's appeal of a ruling that rejected their ophthalmology practice's microcaptive insurance arrangements.

  • September 21, 2026

    Varian, Gov't Appeal Foreign Dividend Decision To 9th Circ.

    Varian Medical Systems Inc. is appealing a U.S. Tax Court decision that it owes more than $7.2 million to the Internal Revenue Service as a result of the court limiting its deemed dividends deduction, while the government is also appealing, according to filings in the Ninth Circuit.

  • September 21, 2026

    IRS Asks 5th Circ. To Pause Microcaptive Rules Case

    The IRS asked the Fifth Circuit to stay briefing in a global tax services provider's bid to revive its challenge to the agency's reporting rules for microcaptive insurance companies pending the resolution of a related case before the appeals court.

  • September 21, 2026

    Funder Says $13M Albania Default Judgment Should Stand

    Litigation funder Omni Bridgeway has urged a D.C. federal court to preserve a default judgment enforcing a roughly $13 million arbitral award against Albanian state entities, arguing they waited an unreasonable 18 months to appear despite receiving repeated notice of the case.

  • September 18, 2026

    Ex-DOJ Chief Lambastes 'Abuses Of Power' In Goldstein Case

    The U.S. Department of Justice constantly made false statements in its criminal case against famed appellate advocate Tom Goldstein, and his convictions must be erased because "prosecutorial misconduct pervaded every stage of the proceedings," a former DOJ prosecutor told the Fourth Circuit.

  • September 18, 2026

    Judge Questions Whether 'Lawfare' Fund Fight Is Really Moot

    A Virginia federal judge seemed unlikely to toss a challenge to the Trump administration's nixed "Anti-Weaponization Fund" and tax audit immunity for the Trump family Friday, saying she worries the fund could be revived in a different form down the road.

  • September 18, 2026

    US Asks Fed. Circ. To Reverse COVID-Era Tax Deadline Ruling

    The government asked the Federal Circuit to overturn a U.S. Court of Federal Claims decision allowing a taxpayer to recover penalties and interest he sought refunds for during the COVID-19 pandemic, saying the claims court wrongly interpreted a statutory 60-day extension as having lasted over three and a half years.

  • September 18, 2026

    Exxon Wins $456M Tax, Penalty Refund In Qatar Gas Case

    Exxon is entitled to a $274 million tax refund for a deduction of interest expenses fully allocated to the company by its partnership with Qatar to extract natural gas, a Texas federal court said Friday in an order that indicated $182 million in penalties should be returned as well.

  • September 18, 2026

    House Bill Would Limit BEAT, Make Other Int'l Tax Changes

    The U.S. would limit the scope of its base erosion and anti-abuse tax and modify several other international tax measures under a bill introduced by a Republican on the House Ways and Means Committee.

  • September 18, 2026

    IRS Security Program 'Not Effective' In 2026, TIGTA Says

    Facets of the IRS' cybersecurity program have improved since last year but are still ultimately "not effective," the Treasury Inspector General for Tax Administration said Friday, finding the deficiencies may leave taxpayer data vulnerable.

  • September 18, 2026

    Tax Tipster Fights For Whistleblower Award At DC Circ.

    U.S. Tax Court wrongly upheld the IRS denying a whistleblower award for information about a taxpayer's transfer pricing despite the agency failing to follow its internal procedures, the individual told the D.C. appeals court.

  • September 18, 2026

    Taxation With Representation: Davis Polk, Latham, Sullivan

    In this week's Taxation With Representation, a group backed by Michael Dell's family office and Sequence Holdings acquires a majority interest in The Baldwin Group, May Mobility merges with a blank check company, and Infineon Technologies sells its memory chip business to Winbond Electronics.

Expert Analysis

  • After Learning Resources: A Practical Guide For US Importers

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    Following the U.S. Supreme Court's Feb. 20 decision in Learning Resources v. Trump, U.S. importers and consumers on whom tariffs were imposed under the International Emergency Economic Powers Act can seek relief through existing administrative procedures or a yet-to-be-determined bespoke refund mechanism, and should plan for more changes in the tariff landscape, say attorneys at Baker Botts.

  • AI-Assisted Arbitration Needs Safeguards To Ensure Fairness

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    As tribunals and arbitral institutions increasingly use artificial intelligence tools in their decision-making processes, ​​​​​​​clear disclosure standards and procedural safeguards are necessary to ensure that efficiency gains do not erode the fairness principles on which arbitration depends, says Alexander Lima at Wesco International.

  • AI-Generated Doc Ruling Guides Attys On Privilege Risks

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    A New York federal court's ruling, in U.S. v. Heppner, that documents created by a defendant using an artificial intelligence tool were not privileged, can serve as a guide to attorneys for retaining attorney-client or work-product privilege over client documents created with AI, say attorneys at Sher Tremonte.

  • The Law Firm Merger Diaries: Leadership Strategy After Day 1

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    For law firm leaders, ensuring a newly combined law firm lives up to its promise, both in its first days of operation and well after, includes tough decisions, clear and specific communication, and cheerleading, says Peter Michaud at Ballard Spahr.

  • Calif.'s Civility Push Shows Why Professionalism Is Vital

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    The California Bar’s campaign against discourteous behavior by attorneys, including a newly required annual civility oath, reflects a growing concern among states that professionalism in law needs shoring up — and recognizes that maintaining composure even when stressed is key to both succeeding professionally and maintaining faith in the legal system, says Lucy Wang at Hinshaw.

  • US-Ukraine Reconstruction Fund Tax Exemptions Uncertain

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    Tax provisions in the bilateral agreement to establish the U.S.-Ukraine Reconstruction Investment Fund, which recently announced it is accepting applications, are so broad and imprecise as to leave uncertainty regarding whether and when tax exemptions will apply to investors' income, say attorneys at Avellum and Debevoise.

  • Trivia Competition Makes Me A Better Lawyer

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    Playing trivia taught me to quickly absorb information and recognize when I've learned what I'm expected to know, training me in the crucial skills needed to be a good attorney, and reminding me to be gracious in defeat, says Jonah Knobler at Patterson Belknap.

  • Judges On AI: Practical Use Cases In Chambers

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    U.S. Magistrate Judge Allison Goddard in the Southern District of California discusses how she uses generative artificial intelligence tools in chambers to make work more efficient and effective — from editing jury instructions for clarity to summarizing key documents.

  • What's At Stake In Possible Circuit Split On Medicaid Rule

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    A recent Eleventh Circuit decision, reviving Florida's lawsuit against a federal rule that reduces Medicaid funding based on agreements between hospitals, sets up a potential circuit split with the Fifth Circuit, with important ramifications for states looking to private administrators to run provider tax programs, say Liz Goodman, Karuna Seshasai and Rebecca Pitt at FTI Consulting.

  • Malpractice Claim Assignability Continues To Divide Courts

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    Recent decisions from courts across the country demonstrate how different jurisdictions balance competing policy interests in determining whether legal malpractice claims can be assigned, providing a framework to identify when and how to challenge any attempted assignment, says Christopher Blazejewski at Sherin & Lodgen.

  • Where PCAOB Goes Next After A Year Of Uncertainty

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    The Public Company Accounting Oversight Board will likely bring fewer enforcement matters in 2026, reflecting a notable change in board priorities following the change in administrations, say Robert Cox and Nicole Byrd at Whiteford Taylor and Matthew Rogers at Bridgehaven Consulting.

  • 5th Circ. Ruling Clarifies Tax Rules For Limited Partners

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    The Fifth Circuit’s Jan. 16 decision in Sirius Solutions v. Commissioner provides greater tax planning certainty by adopting a bright-line test for determining when partners in limited liability companies are exempt from self-employment tax, say attorneys at K&L Gates.

  • NYC Bar Opinion Warns Attys On Use Of AI Recording Tools

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    Attorneys who use artificial intelligence tools to record, transcribe and summarize conversations with clients should heed the New York City Bar Association’s recent opinion addressing the legal and ethical risks posed by such tools, and follow several best practices to avoid violating the Rules of Professional Conduct, say attorneys at Smith Gambrell.

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