Federal
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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September 17, 2026
IRS OK To Target Tax Preparer Over Old Fraudulent Filings
The Internal Revenue Service adequately proved that a Maryland tax preparer fraudulently underreported her income for three years, the U.S. Tax Court said Thursday, finding she can be held liable for deficiencies and penalties despite the returns being filed over a decade ago.
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September 17, 2026
Judge Nixes Workers' Bid To Halt IRS Withholding Rules
A Texas federal judge dismissed two workers' claims that the Internal Revenue Service's income tax withholding regulations resulted in employers overdeducting taxes from their employees' paychecks, finding that federal law bars the workers' bid to prevent tax collection.
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September 16, 2026
House Clears Russia Sanctions Bill With New Tariff Powers
The U.S. House of Representatives approved legislation Wednesday that would enhance President Donald Trump's economic tools to pressure Russia and Iran, including new tariff authorities to impose duties on imports from countries found to economically support Russia, sending the bill to his desk.
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September 16, 2026
Union Says IRS Must Stop Blocking It From Emailing Workers
A D.C. federal judge should order the Internal Revenue Service to resume allowing its workers to access their union's website and letting the union send emails to workers, the union argued, saying the IRS' decision to block the National Treasury Employees Union's domain from its computers is unconstitutional.
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September 16, 2026
House Panel Advances Digital Asset Tax Framework
Congress would create parity between the tax treatment of digital assets and traditional financial assets, as well as institute safeguards against abuse, under a bipartisan digital asset tax framework package passed by the House Ways and Means Committee on Wednesday.
Expert Analysis
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Heppner Ruling Left AI Privilege Risk For Lawyers Unresolved
While a New York federal judge’s recent ruling in U.S. v. Heppner resolved a privilege question surrounding client-side artificial intelligence use, it did not address how to mitigate the risks that can arise when confidential information enters the operative context of an AI system used by an attorney, says Jianfei Chen at Quarles & Brady.
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How To Limit Accounting Fraud Risk As SEC Focus Persists
Despite the U.S. Securities and Exchange Commission's pullback on crypto, cybersecurity and recordkeeping cases, accounting fraud remains a core enforcement priority, making it important for public companies and auditors to strengthen controls, investigations and whistleblower processes, say attorneys at Pillsbury.
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Speed Jigsaw Puzzling Makes Me A Better Lawyer
My passion for speed puzzling — I can complete a 500-piece jigsaw puzzle in under 50 minutes — has sharpened my legal skills in more ways than one, with both disciplines requiring patience, precision and the ability to keep the bigger picture in mind while working through the details, says Tazia Statucki at Proskauer.
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Documenting Business Purpose After IRS' 10th Circ. Win
Following the Tenth Circuit’s recent Liberty Global v. U.S. decision, which held the economic substance doctrine does not require a threshold relevancy determination, taxpayers can prepare for potential audits by maintaining contemporaneous documentation and taking other steps that demonstrate the business purpose of transactions, say attorneys at Crowell & Moring.
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2 AI Snafus Show Why Attys Can't Outsource Judgment
The recent incident involving Sullivan & Cromwell where citations in a filed motion were fabricated by artificial intelligence, as well as a punitive ruling from the Sixth Circuit in U.S. v. Farris, demonstrate that the obligation to supervise AI has belonged and always will belong to lawyers, says John Powell at the Kentucky School Boards Association.
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How Data Center Accounting May Draw Enforcement Scrutiny
As public and media scrutiny of the data center industry intensifies, regulators, enforcement authorities and Congress will likely focus on accounting judgments that rely on aggressive assumptions, opaque financing structures or rapidly evolving collateral classes, heightening the risk of investigations and inquiries, say attorneys at King & Spalding.
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Improving Well-Being In Law, 10 Years After Landmark Study
An important 2016 study revealed significant substance abuse and mental health issues among lawyers, and while the findings helped normalize the conversation around these topics, a decade later, structural change is still needed, says Denise Robinson at PLI.
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How To Gear Up For Trump's Pharma Tariffs
President Donald Trump's proclamation establishing tariffs on certain pharmaceutical products holds a few areas of ambiguity that companies should review and prepare for before the tariffs come into effect later this year, say attorneys at Arnold & Porter.
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Steps To Consider As DOJ Launches Fraud Division
The establishment this month of the National Fraud Enforcement Division within the U.S. Department of Justice is a significant reorganization that suggests an increase in enforcement activity involving federally funded programs but leaves a number of important questions unanswered, say attorneys at Crowell & Moring.
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What To Expect From The SEC's New SOX Group
In a potential shift away from Public Company Accounting Oversight Board enforcement, the U.S. Securities and Exchange Commission's formation of a new group to investigate and litigate potential violations of the Sarbanes-Oxley Act brings both risks and benefits for auditors, say attorneys at King & Spalding.
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Hungary CPAC Funding Probe Could Implicate US Entities
A Hungarian anti-corruption investigation into claims that the former prime minister used taxpayer funds to support the Conservative Political Action Conference could include potential cross-border political and financial dimensions that create multiple touchpoints for U.S. regulatory and enforcement interest, say attorneys at Ballard Spahr.
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Mitigating Multistate Risks As California Expands Tax Reach
Though California's new sourcing rules and extension of the pass-through entity election have created uncertainty, practitioners should file protective returns to respect the law's ambiguity and take certain other steps to protect clients from the costs of losing a future audit, says attorney Delina Yasmeh.
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E-Discovery Quarterly: Recent Rulings On ESI Control
Several recent federal court decisions have perpetuated a split over what constitutes “control” of electronically stored information — with judges divided on whether the standard should turn on a party's legal right or practical ability to obtain the information, say attorneys at Sidley.