Federal
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September 04, 2026
4 Books Transfer Pricing Economists Think You Should Read
What do transfer pricing experts — economists, specifically — do in the summer? In July, many of them attend the National Association for Business Economics' annual transfer pricing symposium and discuss their favorite books with Law360 during the coffee breaks. Others were kind enough to do it during their regular work hours. Here, Law360 looks at four of their picks.
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September 04, 2026
IRS Finalizes 50% Personal-Use Test For Car Loan Tax Break
A vehicle's amount of personal use would be based on the buyer's expected use over the period of ownership for purposes of determining eligibility for the tax break on car loan interest enacted in last summer's budget law, according to final regulations released Friday.
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September 04, 2026
ERISA Recap: 5 Appellate Rulings To Know From August
The Seventh Circuit kept an Arkansas pharmacy benefit manager rule in place as not preempted by federal benefits law, the Fourth Circuit revived an Altria ex-worker's dispute over benefit plan documents, and the Eleventh Circuit reversed a pretrial win for Royal Caribbean in cruise workers' suit challenging 401(k) funds. Here, Law360 looks at those and two other major appellate decisions from August involving ERISA that benefits attorneys may want to know.
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September 04, 2026
Chrisleys Fight Balch & Bingham's Bid To Ax Malpractice Suit
Reality television stars Todd and Julie Chrisley asked a Georgia federal judge on Friday to reject an attempt by their former attorneys to dismiss a legal malpractice lawsuit that claims a critical pretrial mistake allowed evidence obtained through an unlawful search to be used against them at their criminal trial.
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September 04, 2026
4th Circ. Affirms $2.9M IRS Fine For Unreported Accounts
The Fourth Circuit affirmed a $2.9 million fine Friday against a Hong Kong-based U.S. businessman, holding that he should have known there was a "grave risk" of inaccurate tax filings when he failed to disclose offshore accounts to the IRS.
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September 04, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included proposed rules addressing the 2025 federal budget bill's changes to how U.S. corporations account for the earnings of their offshore affiliates when calculating their taxable income.
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September 04, 2026
IRS Updates Rules For Changing R&D Accounting Methods
The Internal Revenue Service on Friday updated its guidelines for those looking to get automatic consent to change their method of accounting for research and development expenditures to comply with changes made in President Donald Trump's two major tax bills.
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September 04, 2026
IRS Spent 64% Of $26B Current Funding, Watchdog Says
The Internal Revenue Service has already spent 64% of the $26 billion that Congress appropriated earlier this year for the agency through 2031, directing most of the money toward enforcement and taxpayer services, according to the tax administration watchdog's report.
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September 03, 2026
Developer Seeks To Restore $78M In Conservation Tax Perks
The Internal Revenue Service was wrong to disallow two conservation easement deductions worth a combined $78 million based on potential mining activity without adequately explaining why, an Alabama real estate developer told the U.S. Tax Court.
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September 03, 2026
Tax Court Keeps Innocent Spouse Case Over IRS Mail Flaw
The Internal Revenue Service failed to establish that it properly mailed a final determination notice to a Nevada woman, the U.S. Tax Court said Thursday, denying the agency's motion to dismiss for untimely filing.
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September 03, 2026
Social Security Number Needed For COVID Rebate, Court Says
The U.S. Tax Court rejected a man's bid to claim a COVID-19-era tax rebate credit Thursday because he didn't provide a Social Security number on his return, instead using an individual taxpayer identification number.
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September 03, 2026
IRS Needs To Improve Representation Training, TIGTA Says
The Internal Revenue Service needs to overhaul training related to taxpayers' rights to representation and direct contact restrictions after a review found some employees lacked required knowledge, the Treasury Inspector General for Tax Administration said.
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September 03, 2026
IRS Could Improve Follow-Up On Rich Nonfilers, TIGTA Says
The IRS could secure a tax return or make an assessment in over 10,000 cases involving wealthy nonfilers by taking further action on those cases after issuing an initial notice, the Treasury Inspector General for Tax Administration estimated in a report released Thursday.
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September 03, 2026
IRS Moves To Strip Schools' Tax Exemptions Over DEI Policies
As many as 18,000 private schools that enact racially based diversity and inclusion policies could lose their federal tax exemptions under a proposed rule released by the Internal Revenue Service on Thursday.
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September 02, 2026
Technology Biz Can't Deduct $59M, Tax Court Says
A California man's technology business can't deduct the $59 million in losses it claimed for 2016 and 2017, the U.S. Tax Court held Wednesday in a case in which it also rejected the IRS' determinations of his individual income.
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September 02, 2026
Airbnb Can't Nix IRS Expert In $1.3B Bill Fight, Tax Court Says
The U.S. Tax Court denied Airbnb's bid to strike IRS expert witness reports from discovery proceedings in the company's challenge against a $1.3 billion tax bill, ruling Wednesday that a procedural rule governing expert testimony applies only to trials.
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September 02, 2026
Vitamin Co. Can't Duck $1.4M Suit Over Ex-Owner's Tax Lien
A vitamin company and its owners must face a suit by the federal government seeking $1.4 million stemming from a tax lien on a former owner's 20% interest in the company, a Connecticut federal judge ruled.
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September 02, 2026
11th Circ. OKs Refusal Of $1.5M Offer To End $140M Tax Debt
The Eleventh Circuit rebuffed a software company founder's $1.5 million offer to settle his $140 million tax debt from 1999, ruling Wednesday that the IRS properly rejected the lowball offer in a case tied to sham arrangements.
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September 02, 2026
Lutnick Says Semiconductor Tariffs Are Coming, With Carveouts
U.S. Secretary of Commerce Howard Lutnick on Wednesday said the U.S. is looking to issue a broad tariff on semiconductors, though he also said it would be structured such that companies that commit to U.S. manufacturing would be exempt.
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September 01, 2026
Siemens Leaders Testify They Were Unaware Of Tax Strategy
Three executives who described how Siemens' digital software business integrated Mentor Graphics' operations after acquiring that electronic design automation company in 2017 seemed oblivious to the tax aspects of the restructuring that occurred in 2018, their testimony Monday and Tuesday showed.
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September 01, 2026
Investment Co. Disputes IRS' $166M Add-On To Capital Gains
An investment company accused the IRS of mistakenly inflating its 2008 short-term capital gains from certain securities investments to about $170 million from $4 million, telling the U.S. Tax Court the gains were properly deferred during the Great Recession.
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September 01, 2026
Strip Club Boss Wants Only Probation After $1.5M Tax Penalty
The former boss of a Connecticut strip club who pled guilty to five charges after being accused of hiding $5.7 million from the IRS told a federal court he should serve no prison time since he already coughed up more than $1.5 million in tax.
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September 01, 2026
Valid Regs Require Abbott To Pay Tax On $8B Gain, IRS Says
The IRS urged the U.S. Tax Court to validate regulations that the agency said required Abbott Laboratories to pay taxes on an $8 billion gain stemming from transactions between its foreign affiliates, arguing the pharmaceutical giant is pushing for "an inappropriately rigid" statutory interpretation.
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September 01, 2026
NC Bar Defends Discipline Of Former Judge To Top Court
The North Carolina State Bar's decision to punish a former judge for actions he took while on the bench is not an attack on judicial independence, the bar argued in urging the state's top court not to take up an appeal challenging an order of discipline against him.
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September 01, 2026
Temporary Tariffs Exceeded Trump's Power, Fed. Circ. Told
President Donald Trump illegally based his temporary tariffs on the misapplication of a law allowing the president to address balance-of-payment deficits, two businesses told the Federal Circuit, pushing the court to preserve a U.S. Court of International Trade ruling against the tariffs.
Expert Analysis
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How A 1947 Tugboat Ruling May Shape Work Product In AI Era
Rapid advances in generative artificial intelligence test work-product principles first articulated in the U.S. Supreme Court’s nearly 80-year-old Hickman v. Taylor decision, as courts and ethics bodies confront whether disclosure of attorneys’ AI prompts and outputs would reveal their thought processes, say Larry Silver and Sasha Burton at Langsam Stevens.
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Navigating Privilege Law Patchwork In Dual-Purpose Comms
Three years after the U.S. Supreme Court declined to resolve a circuit split in In re: Grand Jury, federal courts remain split as to when attorney-client privilege applies to dual-purpose legal and business communications, and understanding the fragmented landscape is essential for managing risks, say attorneys at Covington.
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Cannabis Industry Faces An Inflection Point This Year
Cannabis industry developments last year — from the passage of a new wholesale tax in Michigan, to an executive order accelerating the federal rescheduling process — presage a more mature phase of legalization this year, with hardening expectations and enforcement to come, says Alex Leonowicz at Howard & Howard.
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4 Ways GCs Can Manage Growing Service Of Process Volume
As automation and arbitration increase the volume of legal filings, in-house counsel must build scalable service of process systems that strengthen corporate governance and manage risk in real time, says Paul Mathews at Corporation Service Co.
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The Law Firm Merger Diaries: Forming Measurable Ties
Relationship-building should begin as early as possible in a law firm merger, as intentional pathways to bringing people together drive collaboration, positive client response, engagements and growth, says Amie Colby at Troutman.
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3 Key Takeaways From Planned Rescheduling Of Cannabis
An executive order reviving cannabis rescheduling represents a monumental change for the industry and, while the substance will remain illegal at the federal level, introduces several benefits, including improving state-legal cannabis operators' tax treatment, lowering the industry's legal risk profile, and leaving state-regulated markets largely intact, say attorneys at Dentons.
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OFAC Sanctions Will Intensify Amid Global Tensions In 2026
The Office of Foreign Assets Control will ramp up its targeting of companies in the private equity, venture capital, real estate and legal markets in 2026, in keeping with the aggressive foreign policy approach embraced by the Trump administration in 2025, say attorneys at Holland & Knight.
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5 E-Discovery Predictions For 2026 And Beyond
2026 will likely be shaped by issues ranging from artificial intelligence regulatory turbulence to potential evidence rule changes, and e-discovery professionals will need to understand how to effectively guide the responsible and defensible adoption of emerging tools, while also ensuring effective safeguards, say attorneys at Littler.
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Judges On AI: How Courts Can Boost Access To Justice
Arizona Court of Appeals Judge Samuel A. Thumma writes that generative artificial intelligence tools offer a profound opportunity to enhance access to justice and engender public confidence in courts’ use of technology, and judges can seize this opportunity in five key ways.
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Examining Privilege In Dual-Purpose Workplace Investigations
The Sixth Circuit's recent holding in FirstEnergy's bribery probe ruling that attorney-client privilege applied to a dual-purpose workplace investigation because its primary purpose was obtaining legal advice highlights the uncertainty companies face as federal circuit courts remain split on the appropriate test, say attorneys at Proskauer.
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Hot Topics For Family Offices In 2026
For family offices, the throughline of 2026 is disciplined readiness, as navigating impact from the One Big Beautiful Bill Act and platform maturation will be necessary to preserve flexibility and enhance client outcomes, say attorneys at Morgan Lewis.
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The Case For Emulating, Not Dividing, The Ninth Circuit
Champions for improved judicial administration should reject the unfounded criticisms driving recent Senate proposals to divide the Ninth Circuit and instead seek to replicate the court's unique strengths and successes, says Ninth Circuit Judge J. Clifford Wallace.
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How Changes At The IRS Will Affect Tax Controversy In 2026
Taxpayers will need to adjust approaches to dealing with the IRS in 2026, as the agency is likely to shift its audit strategies and increases reliance on technology following the significant reductions in funding and personnel last year, say attorneys at Crowell & Moring.