Federal
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September 10, 2026
IRS Proposes Opportunity Zone Information Reporting Rules
The Internal Revenue Service proposed rules on Thursday for implementing new statutory requirements for opportunity funds to file information returns to improve the agency's ability to administer and enforce the federal opportunity zone program's tax benefits.
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September 10, 2026
Treasury Floats Foreign Tax Credit Rules After '25 Budget Bill
The U.S. Treasury Department proposed regulations Thursday that would clarify the 2025 federal budget bill's reduction to the range of expenses that companies must allocate to overseas affiliates when calculating foreign tax credits.
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September 10, 2026
McGuireWoods Adds Polsinelli Nonprofit Tax Atty In Atlanta
McGuireWoods LLP has added a partner in Atlanta from Polsinelli PC, strengthening its tax-exempt organizations team with an attorney who has guided nonprofits and tax-exempt organizations on tax matters, the firm announced Thursday.
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September 10, 2026
Tax Court Nod To Income Approach Props Easement Valuation
The IRS has been adversarial toward taxpayers using what is known as the income approach to value conservation easements, but the method's legitimacy was significantly reinforced by the U.S. Tax Court in a recent decision that endorsed the use of the method to value a Los Angeles-area donated property.
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September 10, 2026
US Asks 1st Circ. To Back $3.3M Tax Bill For 'Survivor' Winner
A Rhode Island federal court correctly entered a $3.3 million tax judgment against the first "Survivor" winner, the government told the First Circuit, saying the former contestant failed to refute the tax assessments and had agreed to a U.S. Tax Court decision that determined his liability and penalties.
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September 09, 2026
Defunct Tax Startup CEO Charged In $13.3M Investor Fraud
The CEO of a defunct tax-compliance startup has been arrested on fraud charges based on allegations she defrauded investors out of more than $13 million by lying about her credentials and her company's revenues, the U.S. Department of Justice said Wednesday.
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September 09, 2026
Tax Pros Recall Wrangling Over Siemens' Restructuring
Tax professionals from Siemens and Deloitte described for the U.S. Tax Court on Tuesday and Wednesday the wrangling that went on between the German company and its advisers over the 2018 restructuring plan that led to a $3.5 billion tax deduction in the U.S.
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September 09, 2026
11th. Circ. Upholds Ga. Tax Fraudster's 12½-Year Sentence
The Eleventh Circuit affirmed on Wednesday a12½-year prison sentence for an Atlanta man who was convicted of masterminding a fraudulent tax return scheme that brought in millions of dollars.
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September 09, 2026
Tax Court Backs IRS On Partnership Adjustment Deadline
An Internal Revenue Service notice disallowing a charitable deduction claimed by a Louisiana business partnership was issued in a timely fashion because both sides agreed to an extension that applied to the entire process, the U.S. Tax Court ruled Wednesday.
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September 09, 2026
Economists Tell Fed. Circ. Float Rates Bar Temporary Tariff
President Donald Trump's temporary global tariff lacked legal justification in the current international monetary system, a group of economists, including former U.S. Treasury secretary and Federal Reserve Chair Janet Yellen, told the Federal Circuit on Wednesday in a brief supporting challenges to the duties.
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September 09, 2026
10th Circ. Sets Redo Of Tax Fraud Case To Study Legal Advice
The Tenth Circuit ordered a Kansas federal court to revisit a woman's assertions that ineffective counsel led her to plead guilty to bank and tax fraud charges, saying the trial court needs to further examine whether she indeed received insufficient legal advice.
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September 09, 2026
US Bans Canadian Alcohol, Motorcycles After Tariff Retaliation
President Donald Trump continued the U.S. trade offensive against Canada after its northern neighbor's retaliatory tariffs went into effect, announcing a ban on Canadian imports of certain alcohol, dairy products and motorcycles starting this month.
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September 08, 2026
Judge Nixes Atty's Bid For More Depositions In $12M Tax Suit
A Colorado federal judge denied a request for additional depositions from counsel of an attorney and others accused of siphoning $12 million while advocating an illegal tax fee after determining the request for the depositions was untimely and made outside the discovery window.
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September 08, 2026
Tax Court Adds Five New Trial Locations, Expands Roles
The U.S. Tax Court's chief judge announced that the court will hear cases in five new cities starting Tuesday, bringing the total to 79, while allowing all types of cases to be heard at each location.
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September 08, 2026
Eaton Challenges IRS Example On Intercompany Loans
The IRS is misusing a regulatory example that is unrelated to its argument that Eaton cannot pay foreign affiliates for support that a lender would assume exists in the agency's bid to reduce related-party interest rates and fees, the company told the U.S. Tax Court.
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September 08, 2026
Senate Panel Sets Hearing On IRS Chief Counsel Pick
The Senate Finance Committee will hold a hearing to consider four of President Donald Trump's nominees for various positions, including chief counsel at the Internal Revenue Service, the panel announced Tuesday.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
Expert Analysis
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2 Discovery Rulings Break With Heppner On AI Privilege Issue
While a New York federal court’s recent ruling in U.S. v. Heppner suggests that some litigants’ communications with AI tools are discoverable, two other recent federal court decisions demonstrate that such interactions generally qualify for work-product protection under the Federal Rules of Civil Procedure, says Joshua Dunn at Brown Rudnick.
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CBP's $166B Tariff Refund Portal Needs 4 Safeguards
Before launching its automated web portal to process tariff-refund disbursements on April 20, U.S. Customs and Border Protection should apply the expensive lessons learned from the pandemic-era employee retention credit, says Peter Gariepy at RubinBrown.
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How Developers Can Leverage The New Markets Tax Credit
An increased regulatory focus on affordable housing raises important legal considerations for structuring transactions using the oft overlooked New Markets Tax Credit, which can fill a gap in affordable for-sale housing financing by lowering community developer costs but comes with unique compliance, structuring and documentation demands, say attorneys at Stinson.
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Calculating Damages In IEEPA Tariff Refund Litigation
To calculate damages in the spate of refund litigation triggered by the U.S. Supreme Court's recent decision invalidating tariffs collected under the International Emergency Economic Powers Act, the central question will be how to determine where in the supply chain their economic burden ultimately came to rest, say analysts at Charles River Associates.
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Alpine Skiing Makes Me A Better Lawyer
Skiing has shaped habits I rely on daily as an attorney — focus, resilience and the ability to remain steady when circumstances shift rapidly — and influences the way I approach legal strategy, client counseling and teamwork, says Isaku Begert at Marshall Gerstein.
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What A Court Doc Audit Reveals About Erroneous Filings
My audit of 1,522 court documents from last month found that over 95% contained at least one verifiable error, with fewer than 1% showing clear indicators of artificial intelligence use — highlighting above all else that lawyers may want to focus most on strengthening their review processes, says Elliott Ash at ETH Zurich.
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Mich. Banking Brief: All The Notable Legal Updates In Q1
Michigan's financial services sector saw several significant developments in 2026's first quarter, including the state Department of Insurance and Financial Services' issuance of a bulletin on the use of artificial intelligence and the Michigan House's introduction of a bill based on the Model Money Transmission Modernization Act, say attorneys at Dykema.
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Navigating The Perks Of Qualified Opportunity Zones 2.0
The second iteration of the qualified opportunity zone program, effective Jan. 1, 2027, will introduce new tax incentives for rural real estate development, but these benefits can only be realized if proper governance is a priority, including clear documentation and securities law compliance, says Coni Rathbone at VF Law.
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Getting The Most Out Of Learning And Development Programs
Excerpt from Practical Guidance
Junior associates can better develop the legal, business and interpersonal skills they need for long-term success by approaching their firms’ learning and development programs armed with five tips for getting the most out of these resources, says Lauren Hakala at Reed Smith.
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AI Presents A Make-Or-Break Moment For Outside Counsel
The rapid adoption of artificial intelligence by corporate legal departments is forcing a long-overdue reset of the relationship between inside and outside counsel, and introducing a significant opportunity to shed frustrating inefficiencies and strengthen collaboration for firms willing to embrace the shift, says Intel Chief Legal Officer April Miller Boise.
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8 Tariff Refund Questions For Restructuring Professionals
For restructuring and turnaround professionals, seeking refunds following the U.S. Supreme Court's recent decision invalidating tariffs imposed under the International Emergency Economic Powers Act raises several questions about how to capture legitimate recoveries while protecting an enterprise from the consequences of its own history, says Jonny Frank and Laura Greenman at StoneTurn, and Andrew Popescu at Province.
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5 Tips For Navigating Your Firm's All-Attorney Summit
Excerpt from Practical Guidance
Law firm retreats should be approached strategically, as they present valuable opportunities to advance both the firm's objectives and attorneys' professional development through meaningful participation, building and strengthening internal relationships, and proactive follow-up, says James Argionis at Cozen O’Connor.
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How Bankrupt Cos. Can Seek Refunds For Illegal Tariffs
In light of the U.S. Supreme Court's recent decision striking down President Donald Trump's International Emergency Economic Powers Act tariffs as illegal, some companies may have strong prospects for recovering refunds from the government, and trustees in bankruptcy may have a significant role to play in seeking such recovery, say attorneys at Stinson.