Federal
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September 14, 2026
IRS Asks 6th Circ. To Uphold Revamped Microcaptive Rules
The Internal Revenue Service asked the Sixth Circuit to affirm a Tennessee federal court's ruling that a set of revised IRS rules requiring taxpayers to disclose some microcaptive insurance arrangements doesn't violate the Administrative Procedure Act, saying the U.S. Treasury Department acted within its authority in promulgating the regulations.
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September 11, 2026
Atlas Energy Inks $17M Deal To End Investor Suit Over Reorg
Atlas Energy Solutions Inc. has reached a $17 million settlement to resolve shareholder claims over the oilfield services company's 2023 reorganization, according to a copy of the proposed agreement filed Friday in the Delaware Chancery Court.
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September 11, 2026
IRS Can Withhold Docs That May Air Taxpayer ID, Court Rules
The IRS may withhold documents sought by a tax news publisher, a Washington, D.C., federal judge said, finding the subject is prominent enough that disclosing the records could allow the taxpayer to be identified using a former IRS contractor's leak of President Donald Trump's tax returns and thousands of others.
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September 11, 2026
OECD Issues Updated Pillar 2 Return For Side-By-Side Deal
The OECD published a revised information return for a worldwide corporate 15% minimum tax agreement known as Pillar Two on Friday, including updated sections to implement a side-by-side safe harbor that exempts U.S. multinational corporations from the global regime.
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September 11, 2026
Corp. Transparency Law Unconstitutional, Justices Told
The Supreme Court should find that the Corporate Transparency Act is unconstitutional to prevent a future administration from reviving its application to domestic entities, the National Small Business Association told the justices.
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September 11, 2026
Trial Errors 'Crippled Goldstein's Defense,' 4th Circ. Hears
Appellate luminary Tom Goldstein unveiled a sweeping and forceful critique aimed at erasing his felony fraud convictions, telling the Fourth Circuit that prosecutors were hell-bent on convicting him "no matter the facts or law," disregarded a star witness' "incompetence" and benefited from a trial judge's "inexplicable" rulings.
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September 11, 2026
Fed. Circ. Scrutinizes Presumptive Date In Turkish Rebar Row
A Federal Circuit panel on Friday looked to clarify the effect of the U.S. Department of Commerce's presumption that invoice dates are generally the best option for determining dates of sale during duty investigations, with a Turkish company claiming the presumption cost it $20 million.
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September 11, 2026
Fox Rothschild Adds Berger Singerman Estate Pro In Miami
Fox Rothschild LLP has deepened its tax and wealth planning department with a Miami-based partner who came aboard from Berger Singerman LLP.
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September 11, 2026
Emails Detail Siemens' Tax Planning For 2018 Deduction
Emails from a former Deloitte Touche Tohmatsu Ltd. senior manager called by the IRS to testify at Siemens' U.S. Tax Court trial this week showed detailed planning behind the 2018 transactions that led to a $3.5 billion deduction in the U.S. for the German company.
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September 11, 2026
Taxation With Representation: Paul Weiss, Troutman, Wachtell
In this week's Taxation With Representation, GE Aerospace buys Consolidated Precision Products from private investment firms Warburg Pincus and Berkshire Partners, Independence Realty Trust Inc. and Centerspace agree to merge, and EverBank Financial Corp. and WaFd Inc. agree to combine through a reverse merger.
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September 11, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included proposed regulations that would link eligibility for certain refunds for immigrants from individual tax credits to welfare requirements rather than just work authorization.
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September 10, 2026
Widow Owes FBAR Penalties On India Account, Judge Rules
A businessman's widow owes penalties for his failure to report his Indian bank account to the Internal Revenue Service after he deposited $1.5 million from the sale of a New York apartment complex, but the penalty amount must be recalculated, a New York federal judge ruled Thursday.
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September 10, 2026
Art Dealer Failed To Report $16.5M In Income, Tax Court Says
An art dealer failed to report $16.5 million in income he received from a business associate in connection to a failed attempt to buy and resell a Pablo Picasso painting, the U.S. Tax Court said Thursday, affirming the $5.1 million tax deficiency determined by the Internal Revenue Service.
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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.
Expert Analysis
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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.
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Legal And Industry Impacts Of America's Maritime Action Plan
America's Maritime Action Plan, unveiled by the White House last month, introduces changes to trade investigations, a new maritime trust fund and more — adding regulatory and compliance obligations for companies and counsel, but also new avenues for client engagement in project finance, contract negotiation and dispute resolution, say attorneys at Holland & Knight.
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4 Ways To Help CBP Curb Shell Co. Import Schemes
Shifting to a proactive rather than reactive enforcement posture in addressing shell companies set up to skirt tariffs requires equipping U.S. Customs and Border Protection with enhanced investigative authorities, better intelligence support, and mechanisms to identify and hold accountable the ultimate illicit actors, say attorneys at Kelley Drye.
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7 Steps For Gov't Contractors In Post-IEEPA Tariff Landscape
In response to U.S. Supreme Court's recent decision to strike down tariffs issued by the Trump administration under the International Emergency Economic Powers Act, there are several actions federal contractors should take to preserve their place in any refund waterfall, and to manage audit, overpayment and False Claims Act risk, say attorneys at Holland & Knight.
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The Benefits Of Choosing A Niche Practice In The AI Age
As artificial intelligence becomes increasingly accessible, lawyers with a niche practice may stand out as clients seek specialized judgment that automation cannot replicate, but it is important to choose a niche that is durable, engaging and a good personal fit, says Daniel Borneman at Lowenstein Sandler.
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Section 122 Tariffs Show Shift In Strategy, Not Trade Policy
By imposing temporary tariffs under Section 122 of the Trade Act as a stopgap measure while it pivots to less transitory statutory authorities, the Trump administration sent a clear message that the U.S. Supreme Court’s decision in Learning Resources v. Trump, invalidating duties imposed under the International Emergency Economic Powers Act, will not precipitate a change in policy direction, say attorneys at Snell & Wilmer.
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Tax Court Ruling Signals Cross-Border Loan Scrutiny
The U.S. Tax Court’s recent decision in Aventis v. Commissioner compounds ongoing regulatory focus on debt originations and should prompt practitioners to assess their existing cross-border lending structures for potential exposure to U.S. federal income tax, say attorneys at Eversheds.
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Lessons From Justices' Split On Major Questions Doctrine
The justices' varied opinions in Learning Resources v. Trump, which held the International Emergency Economy Powers Act did not confer the power to impose tariffs, offer a meaningful window into the U.S. Supreme Court's perspective on the major questions doctrine that will likely shape lower courts' approach to executive action challenges, say attorneys at Venable.
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Resilience Planning As Nat'l Security Shifts Tech Import Policy
In response to a sustained reorientation of U.S. trade policy around national security considerations, businesses reliant on processed critical minerals must closely monitor diplomatic negotiations and the potential expansion of trade measures, incorporating contingency planning into procurement and long-term investment strategies, says attorney Sohan Dasgupta.
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How The New Tariff Landscape May Unfold
To replace tariffs formerly imposed under the International Emergency Economic Powers Act, the administration will rely on a patchwork of statutes, potentially leading to procedural challenges and a complex tariff landscape with varying levels, durations and applicability, says Joseph Grossman-Trawick at King & Spalding.
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What Orgs. Should Note In IRS Group Tax Exemption Overhaul
In a significant update, the IRS Revenue Procedure 2026-8 shows that the group exemption program is moving into a new regulatory era involving more uniformity, oversight and compliance obligations, and early action is key to preserve group exemption status and avoid disruption for subordinate organizations, says Ravi Sundara at Spencer Fane.
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How Banks Can Apply FinCEN Beneficial Ownership Relief
A recent Financial Crimes Enforcement Unit order limiting the circumstances under which banks should identify and verify beneficial owners may allow banks to tailor their approach to verification compliance, but only after reviewing customer due diligence policies and evaluating alignment with their risk profiles, say attorneys at Cleary.