Federal
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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August 13, 2026
IRS Failed To Test Workers For Drug Use, TIGTA Says
The Internal Revenue Service didn't conduct reasonable-suspicion testing for employees suspected of illegal drug use in fiscal years 2022 to 2024, the Treasury Inspector General for Tax Administration said in a report released Thursday.
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August 12, 2026
$190K Or $1.9M? Goldstein, DOJ 'At Impasse' Over Forfeiture
Tom Goldstein and the U.S. Department of Justice aired dramatically divergent views Wednesday of a looming financial penalty for his fraud convictions, with the famed appellate advocate voicing constitutional objections to the DOJ's request for almost $2 million and revealing that prosecutors spurned a far smaller offer.
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August 12, 2026
Trump Tells 11th Circ. Sanctions In IRS Case Must Be Paused
President Donald Trump urged the Eleventh Circuit on Wednesday to halt sanctions imposed by a lower court over an immunity deal that would have given him broad protections from federal tax audits and investigations, arguing he and the government have distinct interests.
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August 12, 2026
Businessman Entitled To $925K Theft Loss, Tax Court Says
A self-employed businessman who has worked in his family's jewelry business since the 1990s is entitled to a $925,000 theft loss deduction for 2010, the U.S. Tax Court said in a memorandum opinion Wednesday.
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August 12, 2026
Senate OKs Extension Of Tax Deduction For Disaster Losses
The U.S. Senate approved a bill that would extend a federal tax deduction for qualified disaster-related personal casualty losses and a gross income exclusion for eligible wildfire relief payments, sending it to President Donald Trump for consideration.
Expert Analysis
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What To Watch As NY LLC Transparency Act Is Stuck In Limbo
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.
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Despite Deputy AG Remarks, DOJ Can't Sideline DC Bar
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.
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8th Circ. Decision Shipwrecks IRS On Shoals Of Loper Bright
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.
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Rule Amendments Pave Path For A Privilege Claim 'Offensive'
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.
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Litigation Funding Could Create Ethics Issues For Attorneys
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.
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SEC's Dual Share Class Approval Signals New Era For ETFs
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.
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E-Discovery Quarterly: Recent Rulings On Dynamic Databases
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.
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What To Do If A Retirement Plan Participant Is Deported
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.
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Defeating Estoppel-Based Claims In Legal Malpractice Actions
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.
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The Biz Court Digest: How It Works In Massachusetts
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.
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Why Appellees Should Write Their Answering Brief First
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.
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Attys Beware: Generative AI Can Also Hallucinate Metadata
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.
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When Atty Ethics Violations Give Rise To Causes Of Action
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.