Federal

  • 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decade, a Wisconsin federal judge said, finding the agency substantiated the liabilities and confirmed that it properly rescinded compromise offers to resolve the debts.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.

  • September 18, 2026

    TerrAscend Says Feds Sued Fake Co. In $8M Clawback Suit

    Multistate cannabis operator TerrAscend USA Inc. asked a New Jersey federal court to throw out the federal government's suit seeking to claw back an $8 million tax refund, saying the government sued a nonexistent entity and even if it substituted the correct one, the suit still wouldn't belong in New Jersey.

  • September 18, 2026

    IRS Updates Corp. Bond Monthly Yield Curve For September

    The IRS updated the corporate bond monthly yield curve used in calculations for defined benefit plans for September on Thursday as well as corresponding segment rates and the interest rate for 30-year U.S. Treasury Department securities.

  • September 18, 2026

    IRS Floats Tax Return Form With Question About Citizenship

    The Internal Revenue Service released a draft version of the Form 1040 individual tax return that for the first time would include a question about the filer's citizenship status.

  • September 18, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, included a proposal to revoke federal tax exemptions for as many as 18,000 private schools that enact racially based diversity and inclusion policies.

  • September 17, 2026

    Firm Partners Can't Get Employment Tax Break, 2nd Circ. Says

    The Second Circuit held Thursday that $141.5 million in partnership income distributed to an investment company's principals was subject to self-employment taxes, following the Fifth Circuit's narrow interpretation for determining eligibility for a self-employment tax exemption for limited partners.

  • September 17, 2026

    IRS Defends Regs In Meta's Fight Against $16B Tax Bill

    The IRS urged the U.S. Tax Court to validate regulations that Facebook parent Meta is challenging in its fight against a nearly $16 billion tax bill, arguing that the social media giant is recycling arguments the Ninth Circuit already rejected.

  • September 17, 2026

    IRS Properly Nixed Whistleblower's Award Bid, Tax Court Says

    The IRS didn't abuse its discretion in denying a whistleblower's bid for an award for information regarding alleged underpayments by a large multinational corporation, the U.S. Tax Court ruled Thursday, upholding the agency's determination that it had already identified the key issues for its investigation.

Expert Analysis

  • Navigating The Perks Of Qualified Opportunity Zones 2.0

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    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.

  • Getting The Most Out Of Learning And Development Programs

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    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.

  • AI Presents A Make-Or-Break Moment For Outside Counsel

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    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.

  • 8 Tariff Refund Questions For Restructuring Professionals

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    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.

  • 5 Tips For Navigating Your Firm's All-Attorney Summit

    Excerpt from Practical Guidance
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    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.

  • How Bankrupt Cos. Can Seek Refunds For Illegal Tariffs

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    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.

  • Legal And Industry Impacts Of America's Maritime Action Plan

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    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.

  • 4 Ways To Help CBP Curb Shell Co. Import Schemes

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    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.

  • 7 Steps For Gov't Contractors In Post-IEEPA Tariff Landscape

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    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.

  • The Benefits Of Choosing A Niche Practice In The AI Age

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    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.

  • Section 122 Tariffs Show Shift In Strategy, Not Trade Policy

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    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.

  • Tax Court Ruling Signals Cross-Border Loan Scrutiny

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    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.

  • Lessons From Justices' Split On Major Questions Doctrine

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    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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