Federal

  • August 18, 2026

    Floridian Waived Jury Right In $20M FBAR Case, Judge Says

    A Florida federal judge upheld a nearly $20 million tax judgment against a dual U.S.-German citizen for undisclosed foreign bank account information, holding that he could not justify his delay in asserting his right to a jury trial.

  • August 17, 2026

    Ex-Goldman Exec Ordered To Pay $860K For Not Filing FBAR

    A D.C. federal judge on Monday ordered former Goldman Sachs banking executive Patricia L. Bowden to pay more than $860,000 in damages after she failed to take action in the federal government's lawsuit that alleged she willfully failed to report her Australian bank accounts to the Internal Revenue Service.

  • August 17, 2026

    Pitney Bowes Hit With Tariff Refund Suit By EBay Users

    EBay users hit Pitney Bowes Inc. with a breach of contract proposed class action Monday in Connecticut federal court alleging the global shipping and logistics company failed to return or refund them tariff-related charges that were deemed illegal by the U.S. Supreme Court earlier this year.

  • August 17, 2026

    Law Firm's Challenge To 2021 Statute Falls Short, Judge Says

    A Georgia federal judge on Monday dismissed a lawsuit brought by an attorney and his firm alleging a 2021 law designed to combat money laundering could force the attorney to violate attorney-client privilege, finding the plaintiffs had failed to allege any concrete injury that would empower them to pursue the case. 

  • August 17, 2026

    Tax Court Backs Income Approach For Easement Deduction

    A partnership donor appropriately applied the income approach to appraise a nearly 300-acre conservation easement in Los Angeles County to claim a 2014 charitable deduction, the U.S. Tax Court ruled Monday, finding that the taxpayer adequately substantiated its valuation method.

  • August 17, 2026

    Attorneys Skeptical Of Trump's 11th Circ. Appeal Of IRS Case

    Six attorneys who weighed in on President Donald Trump's $10 billion suit against the Internal Revenue Service told a Florida federal court Monday that he hasn't demonstrated that he will prove that its ruling that the settlement from the suit lacked a legitimate controversy violated due process.

  • August 17, 2026

    Split 10th Circ. Won't Revisit Liberty Global's $2.4B Tax Loss

    The Tenth Circuit said Monday it won't reconsider an April ruling against Liberty Global, upholding a decision that found the telecommunications giant improperly claimed a $2.4 billion deduction based on foreign transactions that lacked economic substance.

  • August 17, 2026

    Biz Pushes Class Cert. As Solution To IEEPA Refund Issues

    The U.S. Court of International Trade should grant class certification to companies seeking refunds of duties paid under the invalidated global tariff regime, the company serving as a test case for the refunds said in arguments mirroring those recently made in the underlying dispute.

  • August 17, 2026

    More IRS Controls Needed To Protect Tax Data, TIGTA Says

    The IRS should take steps to ensure that access to its network and systems containing confidential taxpayer information is removed when employees separate from the agency, the Treasury Inspector General for Tax Administration said.

  • August 17, 2026

    McKesson's $10M Tax Refund Bid Misreads Law, Gov't Says

    The U.S. government urged a Texas federal court to uphold transfer pricing regulations that McKesson is challenging in its push for a nearly $10 million tax refund, arguing the pharmaceutical giant has taken an overly narrow statutory reading.

  • August 17, 2026

    IRS Floats Eased Trust Reporting For Pass-Through Giving

    Eligible trusts that claim charitable contribution deductions only for donations made by pass-through entities would be subject to eased reporting requirements under regulations proposed by the U.S. Department of the Treasury and the Internal Revenue Service.

  • August 14, 2026

    Tax Court Backs IRS' Deficiency Claims Against Conn. Atty

    The IRS correctly determined that a Connecticut licensed attorney who lived in Rhode Island and previously worked for a medical marijuana dispensary is liable for tax deficiencies and penalties across five tax years, the U.S. Tax Court said.

  • August 14, 2026

    Meta's Litigation Distinct From Facebook's, IRS Says

    The case over Meta Platforms' 2017-2019 tax years is not identical to the one brought by its predecessor, Facebook, the IRS said in responding to Meta's claim that the government is seeking to relitigate the earlier dispute, which involved 2010.

  • August 14, 2026

    11th Circ. Mulls Tax Court's Cut To $33M Easement Deduction

    An Eleventh Circuit panel grappled Friday with valuation questions regarding a Georgia conservation easement, including whether the U.S. Tax Court erred in rejecting the IRS' determination while still using the agency's data points in reducing a $33 million tax deduction.

  • August 14, 2026

    IRS Expands Carbon Capture Tax Credit's Safe Harbor

    A safe harbor for the carbon sequestration tax credit's reporting requirements will apply to a method that uses carbon oxide used as a tertiary injectant in qualified oil and gas extraction projects, the IRS announced Friday, expanding earlier guidance for the incentive.

  • August 14, 2026

    Rising Star: Baker McKenzie's Cameron Reilly

    Baker McKenzie partner Cameron Reilly helped secure a key tax court ruling for FedEx Corp. to invalidate regulations on mandatory repatriation under the 2017 federal tax changes, and was a lead attorney in Facebook Inc.'s successful challenge to cost-sharing regulations for multinational corporations, earning him a spot among the tax practitioners under 40 honored by Law360 as Rising Stars.

  • August 14, 2026

    Taxation With Representation: Miller Thomson, Bennett Jones

    In this week's Taxation With Representation, GO Residential Real Estate Investment Trust and a consortium of buyers acquire H&R Real Estate Investment Trust, insurance exchange Accelerant goes private in a deal with Thoma Bravo, and Goldman Sachs acquires NEOS Investments.

  • August 14, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, included guidance for the new premium-based method for employer credit for paid family and medical leave.

  • August 14, 2026

    Mass. Mayor Charged With $1.5M COVID-19 Loan Fraud

    The mayor of Lawrence, Massachusetts, faces federal charges for allegedly obtaining more than $1.5 million in COVID-19 small business loans and using the money to fund his campaign coffers, pay his taxes, and pay off nearly $900,000 in high-interest, hard-money mortgages on properties he owned.

  • August 14, 2026

    Maryland Tax Court Strikes Down Digital Advertising Tax

    Maryland's first-in-the-nation digital advertising tax violates the federal Internet Tax Freedom Act by applying only to electronic commerce, the state's tax court said in a group of decisions Friday, striking down the tax.

  • August 13, 2026

    Split 11th Circ. Backs IRS $1M Value For Contested Easement

    A split Eleventh Circuit panel affirmed a decision to slash three Georgia landowners' conservation easement value from $18 million to $1 million Thursday, saying the U.S. Tax Court didn't need to determine the property's best use because the parties already agreed on that use.

  • August 13, 2026

    Texas Man Cops To Role In $43M Tax Shelter Scheme

    A Texas man pled guilty to conspiring to defraud the IRS by promoting and selling a fraudulent tax shelter in a scheme that resulted in a tax loss to the federal government of approximately $43 million, the U.S. Department of Justice said Thursday.

  • August 13, 2026

    5th Circ. Narrows Tax Break Ruling For Limited Partners

    A Fifth Circuit panel revised its ruling in a long-running feud over the self-employment tax exclusion for certain business partners, adjusting its interpretation of "limited partner" and narrowing its finding that a state's limited liability designation triggers the tax break.

  • August 13, 2026

    Treasury Floats Foreign Currency Rules To Fix Timing Issues

    The U.S. Treasury Department proposed regulations Thursday that would smooth out timing wrinkles companies were facing when determining the taxable income of affiliates that conduct business in a foreign currency for 2025 returns.

  • August 13, 2026

    Rising Star: Covington's Brian Harris

    Brian Harris of Covington & Burling LLP represented companies from the world of biomedicine, retail and even sports after advising on the acquisition and relocation of the NHL's Arizona Coyotes in transactional tax matters, earning him a spot as one of the tax law practitioners under age 40 honored by Law360 as Rising Stars.

Expert Analysis

  • What To Watch As NY LLC Transparency Act Is Stuck In Limbo

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    Just about a month before it's set to take effect, the status of the New York LLC Transparency Act remains murky because of a pending amendment and the lack of recent regulatory attention in New York, but business owners should at least prepare for the possibility of having to comply, says Jonathan Wilson at Buchalter.

  • Despite Deputy AG Remarks, DOJ Can't Sideline DC Bar

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    Deputy Attorney General Todd Blanche’s recent suggestion that the D.C. Bar would be prevented from reviewing misconduct complaints about U.S. Department of Justice attorneys runs contrary to federal statutes, local rules and decades of case law, and sends the troubling message that federal prosecutors are subject to different rules, say attorneys at HWG.

  • 8th Circ. Decision Shipwrecks IRS On Shoals Of Loper Bright

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    The Eighth Circuit’s recent decision invalidating transfer pricing regulations in 3M Co. v. Commissioner may be the most significant tax case implementing Loper Bright's rejection of agency deference as a judicial tool in statutory construction, says Edward Froelich at McDermott.

  • Rule Amendments Pave Path For A Privilege Claim 'Offensive'

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    Litigators should consider leveraging forthcoming amendments to the Federal Rules of Civil Procedure, which will require early negotiations of privilege-related discovery claims, by taking an offensive posture toward privilege logs at the outset of discovery, says David Ben-Meir at Ben-Meir Law.

  • Litigation Funding Could Create Ethics Issues For Attorneys

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    A litigation investor’s recent complaint claiming a New York mass torts lawyer effectively ran a Ponzi scheme illustrates how litigation funding arrangements can subject attorneys to legal ethics dilemmas and potential liability, so engagement letters must have very clear terms, says Matthew Feinberg at Goldberg Segalla.

  • SEC's Dual Share Class Approval Signals New Era For ETFs

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    The U.S. Securities and Exchange Commission's recent approval of the dual share class structure marks a landmark moment for the U.S. fund industry, opening the door for asset managers to benefit from combining mutual fund and exchange-traded fund share classes under a single portfolio, say Ilan Guedj at Bates White and Brian Henderson at George Washington University.

  • E-Discovery Quarterly: Recent Rulings On Dynamic Databases

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    Several recent federal court decisions illustrate how parties continue to grapple with the discovery of data in dynamic databases, so counsel involved in these disputes must consider how structured data should be produced consistent with the requirements of the Federal Rules of Civil Procedure, say attorneys at Sidley.

  • What To Do If A Retirement Plan Participant Is Deported

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    Given recent immigration policy changes in the U.S., many businesses are experiencing employee deportations, but retirement plan administrators should still pay and report benefits to avoid violating the plan, the Employee Retirement Income Security Act or tax reporting requirements, says Teri King at Smith Gambrell.

  • Defeating Estoppel-Based Claims In Legal Malpractice Actions

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    State supreme court cases from recent years have addressed whether positions taken by attorneys in an underlying lawsuit can be used against them in a subsequent legal malpractice action, providing a foundation to defeat ex-clients’ estoppel claims, says Christopher Blazejewski at Sherin and Lodgen.

  • The Biz Court Digest: How It Works In Massachusetts

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    Since its founding in 2000, the Massachusetts Business Litigation Session's expertise, procedural flexibility and litigant-friendly case management practices have contributed to the development of a robust body of commercial jurisprudence, say James Donnelly at Mirick O’Connell, Felicia Ellsworth at WilmerHale and Lisa Wood at Foley Hoag.

  • Why Appellees Should Write Their Answering Brief First

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    Though counterintuitive, appellees should consider writing their answering briefs before they’ve ever seen their opponent’s opening brief, as this practice confers numerous benefits related to argument structure, time pressures and workflow, says Joshua Sohn at the U.S. Department of Justice.

  • Attys Beware: Generative AI Can Also Hallucinate Metadata

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    In addition to the well-known problem of AI-generated hallucinations in legal documents, AI tools can also hallucinate metadata — threatening the integrity of discovery, the reliability of evidence and the ability to definitively identify the provenance of electronic documents, say attorneys at Law & Forensics.

  • When Atty Ethics Violations Give Rise To Causes Of Action

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    Though the Model Rules of Professional Conduct make clear that a violation of the rules does not automatically create a cause of action, attorneys should beware of a few scenarios in which they could face lawsuits for ethical lapses, says Brian Faughnan at Faughnan Law.

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