Federal

  • July 17, 2026

    Oil Co. Asks Tax Court To Make Additional Tax Credit Claim

    An energy company that the U.S. Tax Court allowed to give up the normal carryback period for its net operating losses without waiving the 10-year period for specified liability losses wants the court to amend its claim to include a higher foreign tax credit.

  • July 17, 2026

    Taxation With Representation: Freshfields, Slaughter And May

    In this week's Taxation With Representation, Uber Technologies Inc. buys food delivery company Delivery Hero SE, engineering group ABB Ltd. acquires flow technology company Rotork PLC, and Eli Lilly and Co. buys drug developer AtaiBeckley Inc.

  • July 17, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, included an update to the list of Native American tribes that have settled tribal trust cases with the federal government for tax purposes.

  • July 16, 2026

    11th Circ. Affirms Quarry Valuation Sank $23M Easement Perk

    A 103-acre tract's best alternative use is not an aggregate quarry, the 11th Circuit ruled, rejecting the valuation that supported a partnership's $23 million deduction claim for donating the Georgia property as a conservation easement.

  • July 16, 2026

    Tile Importer Adds To Tax Dispute Over Captive Arrangement

    A New York glass tile importer that had challenged IRS income adjustments of $4.8 million for 2018 through 2020 related to its captive insurance program added a fourth year to its dispute, saying the agency erred in increasing its income by $1.2 million for 2021.

  • July 16, 2026

    Meta Says Altera Ruling Doesn't Control In Stock Option Fight

    The Ninth Circuit's 2019 ruling against Altera, which upheld an IRS regulation requiring companies to share the cost of stock options in joint ventures with foreign affiliates, has no bearing on Meta Platforms' dispute over the same issue, the social media company told the U.S. Tax Court.

  • July 16, 2026

    Tax Filers Seek Class Cert. In Google Privacy Suit

    Online tax return filers who alleged Google's tracking tool effectively eavesdropped on their confidential tax information asked a California federal judge to certify several classes in their suit against the search giant.

  • July 16, 2026

    US Needs Digital Asset Tax Framework, Treasury Picks Say

    Congress needs to take steps to create a tax structure for the digital asset market, two of President Donald Trump's picks to serve in U.S. Treasury Department posts told the Senate Finance Committee during a hearing Thursday.

  • July 16, 2026

    Senate Democrats Revive Bill To End Federal Marijuana Ban

    Senate Democrats on Thursday once again reintroduced a cannabis legalization bill that would remove the drug entirely from the ambit of the Controlled Substances Act and impose a tax-and-regulate scheme akin to what is currently in place for alcohol and tobacco.

  • July 16, 2026

    Nonprofit Can Proceed In $1M Employee Tax Refund Fight

    A Mississippi federal judge allowed an economic development nonprofit to continue challenging the IRS' denial of more than $1 million in employee retention tax credits, while dismissing its request for a declaratory judgment that the employer is entitled to the incentives.

  • July 16, 2026

    Ashurst Perkins Adds Tax Pro In LA From Stradling Yocca

    Ashurst Perkins Coie announced Thursday that it has bolstered its tax practice with a Los Angeles-based partner who came aboard from Stradling Yocca Carlson & Rauth PC.

  • July 16, 2026

    USTR Broadens Exemptions Ahead Of 25% Brazil Tariff

    A 25% tariff on Brazilian goods will begin next week with an expanded exemption list following public comments on the action, U.S. Trade Representative Jamieson Greer announced.

  • July 15, 2026

    Circuit-By-Circuit Guide To The US Supreme Court's Term

    Federal appeals courts had wide-ranging successes and struggles during the U.S. Supreme Court's recently completed term: One had its best showing in years following its worst showing in years; one felt déjà vu after recently starting to find favor with the justices; and one saw its reputation for independence occupy a rare role in the Supreme Court spotlight.

  • July 15, 2026

    Eaton Says IRS Position Turns 'Arm's Length' On Its Head

    The IRS' argument in support of its income allocations to Eaton Corp. from an Irish affiliate effectively inverts the arm's-length standard underlying U.S. transfer pricing law, seeking to price transactions between related companies by assuming non-arm's-length behavior, the company told the U.S. Tax Court.

  • July 15, 2026

    CIT Judge Says Order Incoming For Next Tariff Refund Phase

    The U.S. Court of International Trade judge overseeing U.S. Customs and Border Protection's development of a duty refund system for tariffs struck down by the U.S. Supreme Court forecast new directions for the government as it prepares another phase of its tariff refund system, according to an order published Wednesday.

  • July 15, 2026

    Siemens Wins Tax Deduction In IRS Rules Mismatch Case

    Siemens Medical Solutions is allowed the full dividends-received deduction it claimed for 2019, the U.S. Tax Court held Wednesday, throwing out an IRS regulation that attempted to reduce the deduction by aligning the effective date of different provisions under 2017 tax legislation.

  • July 15, 2026

    Judge Won't Revive Feds' $24M Tax Case Against NC Couple

    A North Carolina federal judge refused to reconsider his decision that the federal government's bid to collect on what it claimed was a couple's $24 million tax bill came too late, saying the government failed to show that the ruling should be changed.

  • July 15, 2026

    Tax Court Slashes Ala. Easement Writeoff By Tens Of Millions

    An Alabama partnership massively overstated the value of a claimed conservation easement deduction, the U.S. Tax Court found Wednesday, cutting the claimed $42.2 million deduction to $800,000 when properly considering the use of the property.

  • July 15, 2026

    Fed. Circ. Gives Pa. Biz A 2nd Go At $1.5M Tax Penalty Refund

    The Federal Circuit gave a Pennsylvania electrical contractor another chance to pursue a $1.53 million refund claim for penalties paid to the Internal Revenue Service after its owner pled guilty to criminal tax evasion, according to an opinion published Wednesday.

  • July 15, 2026

    Tax Code Allows Political Speech By Churches, 5th Circ. Told

    A Texas federal court wrongly rejected the IRS' proposed settlement that would allow churches to engage in political speech without jeopardizing their tax-exempt status, conservative groups told the Fifth Circuit, arguing that federal tax assessment protections do not bar the court from implementing the deal.

  • July 15, 2026

    Cornyn, Tillis Still Waver On Blanche AG Bid After Hearing

    Todd Blanche had his nomination hearing to be attorney general on Wednesday and two key Republican senators still have yet to say if they will support him.

  • July 15, 2026

    TIGTA Worried About IRS Zero Paper Push Security Breaches

    Unauthorized employees have accessed restricted areas because of physical security gaps at two sites where contractors are supporting the Internal Revenue Service's push to eliminate paper processing of tax returns, the Treasury Inspector General for Tax Administration said in a management alert released Wednesday.

  • July 15, 2026

    Russia Sanctions Bill Goes Too Far On Tariff Power, Dems Say

    A reworked version of a bipartisan bill aimed at sanctioning Russia over the war in Ukraine wrongly places too much tariff power in the hands of President Donald Trump, some leading congressional Democrats said.

  • July 15, 2026

    Pillar 2 Revenue Intake Falls Short Of Predictions, OECD Says

    The worldwide corporate 15% minimum tax agreement known as Pillar Two has so far brought in less revenue than expected, the Organization for Economic Cooperation and Development said Wednesday.

  • July 15, 2026

    Mich. Tax Biz Barred From Preparing Federal Returns By Court

    A federal judge granted the federal government's bid to bar a Michigan-based tax and accounting business from preparing federal tax returns over allegations it prepared fraudulent returns that cost the government a tax revenue loss estimated at over $2 million.

Expert Analysis

  • 9th Circ. Has Muddied Waters Of Article III Pleading Standard

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    District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.

  • Steps For Universities To Pass Tax-Exempt Test Amid Scrutiny

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    After decades of a quiet governmental acceptance of tax-exempt status, universities are facing unprecedented and public pressure to defend themselves, and must consider how to protect this valuable status, say attorneys at Eversheds Sutherland.

  • 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.

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