Federal

  • May 09, 2026

    Spinoff Letter Rulings Valuable For IRS Too, Agency Atty Says

    The Internal Revenue Service has resumed issuing letter rulings on significant issues in tax-free spinoffs, and an IRS attorney on Saturday encouraged companies to use the program, as it provides the agency with valuable information on the transactions.

  • May 09, 2026

    Admin Cost Of Tax Presence Shouldn't Top Profit, Pros Say

    The administrative costs for a company or individual triggering a taxable presence, or permanent establishment, in a jurisdiction shouldn't exceed the profit allocable to the entity, transfer pricing specialists said Friday.

  • May 08, 2026

    AI's Use In Transfer Pricing Still Evolving, Tax Pros Say

    The use of artificial intelligence in transfer pricing is expected to ease compliance and reduce costs for clients, but multiple questions remain about the technology's potential and how it should be applied, a panel of tax experts said Friday.

  • May 08, 2026

    Pro Energy Granted $1.85M Refunds Over Pulled Tax License

    A Florida federal judge on Friday ruled Pro Energy LLC can recover $1.85 million in refunds from fuel excise taxes it paid despite being registered as an ultimate vendor, which should have allowed it to make tax-free fuel and gas sales to state and local governments.

  • May 08, 2026

    Disbarred Atty Can't Escape Tax Evasion Case, 2nd Circ. Says

    A disbarred English attorney who assisted the heirs of an American businessman in evading taxation on their inheritance cannot use an "extraordinary" post-conviction remedy to overturn part of the verdict and a $4 million restitution bill, the Second Circuit ruled Friday.

  • May 08, 2026

    Nike Customers Join Tariff Refund Class Action Trend

    A group of Nike customers on Friday joined the growing number of proposed class actions looking to secure legal rights to refunds of costs tied to President Donald Trump's now-invalidated global tariff regime, saying they were the ones who actually bore the costs.

  • May 08, 2026

    Why Trump's 2nd Global Tariff May Fare Better On Appeal

    President Donald Trump's administration on Friday appealed the U.S. Court of International Trade's ruling deeming his temporary global tariff unlawful to the Federal Circuit, where judges may view the executive action with more deference than the measures it immediately replaced.

  • May 08, 2026

    Clarity Sought On Energy Tax Credits And Foreign Debt

    The IRS should issue more guidance on what kind of debt arrangements can limit a development project's access to clean energy tax credits under new prohibited foreign entity requirements as uncertainty over financial liability and ownership becomes a major market concern, practitioners said Friday.

  • May 08, 2026

    US, Romania Have Wrapped Up Tax Treaty Talks, Official Says

    The U.S. and Romania recently completed negotiations on their double-tax treaty and are conducting reviews of the changes, an official with the U.S. Department of the Treasury said Friday.

  • May 08, 2026

    3rd Circ. Rejects NJ Man's Bid To Revisit $40M Tax Conviction

    The Third Circuit has declined to reconsider upholding the conviction of a man who raked in $40 million from filing false tax returns.

  • May 08, 2026

    Prosecutors Oppose Move To Put Off Goldstein Sentencing

    Federal prosecutors are claiming that SCOTUSblog founder Thomas Goldstein may have violated his pretrial release conditions when he racked up over $1.7 million in gambling income last year, telling a federal judge not to delay sentencing for the famed U.S. Supreme Court lawyer.

  • May 08, 2026

    Taxation With Representation: Corrs, Kirkland, Linklaters

    In this week's Taxation With Representation, gold companies Regis Resources and Vault Minerals combine, Long Lake Management acquires American Express Global Business Travel and Vodafone buys out CK Hutchison Holdings to become the sole owner of their telecommunications joint venture.

  • May 08, 2026

    DOL Benefits Chief Warns Of 'Bad Faith' Focus On ESG, DEI

    The top official for the U.S. Department of Labor's employee benefits subagency said at a trade association conference Friday that agency investigations will focus on benefit plan managers' loyalty conflicts, including disloyal pursuits of socially conscious investing or diversity goals.

  • May 08, 2026

    Liberty Global Easy Case For 10th Circ., IRS Atty Says

    The Internal Revenue Service's recent win against telecommunications giant Liberty Global, whose complex transactions were held to be a tax shelter lacking economic substance, was an "easy affirmance" for the Tenth Circuit and an easy decision for the district court, an agency official said Friday.

  • May 08, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, included the nomination process and eligibility requirements for designated qualified opportunity zones and identifying a list of qualifying areas.

  • May 07, 2026

    Jackson Hewitt Tax Loans Flout Military Credit Law, Suit Says

    A U.S. Navy service member has accused tax preparer Jackson Hewitt Inc. of overcharging military clients for short-term loans tied to tax refunds, claiming in a proposed class action the company's effective interest rates for "refund anticipation loans" exceed what is allowed under the federal Military Lending Act.

  • May 07, 2026

    Trump's Temporary Global Tariffs Illegal, Trade Court Rules

    President Donald Trump's temporary global 10% tariffs are unlawful because the narrow set of economic conditions required for the measure to be imposed were not met, the U.S. Court of International Trade said Thursday in a divided opinion.

  • May 07, 2026

    Wyden Probes Wall Street Firms For Tariff Refund Stakes' Info

    The top Democratic lawmakers on the Senate Finance Committee sent letters to major Wall Street firms Thursday about their activity in buying the rights to importers' tariff refund interests at a discount following the U.S. Supreme Court's decision in February striking down President Donald Trump's emergency tariff regime. 

  • May 07, 2026

    Wyden Questions Company On Tribal Tax Credit Sales

    The Senate Finance Committee's top Democrat asked a company that he said may have defrauded clients into buying millions of dollars in nonexistent tribal tax credits to explain the extent of its involvement in such conduct in a letter released Thursday.

  • May 07, 2026

    IRS Needs Reliable Data To Reduce Improper EITC Payments

    The Internal Revenue Service doesn't have the data necessary to efficiently identify and prevent improper earned income tax credit payments made by noncitizens who are not authorized to work in the U.S., the Treasury Inspector General for Tax Administration said in a report Thursday.

  • May 07, 2026

    Judge Cuts 13 Wire Fraud Counts From $1B Tax Shelter Case

    A Texas federal judge dismissed 13 wire fraud charges against four men accused of running a $1 billion tax shelter scheme, ruling prosecutors improperly relied on a statute with a lower intent standard than the applicable tax fraud law.

  • May 07, 2026

    Stinson Real Estate Finance Atty Joins Reed Smith In DC

    Reed Smith LLP has hired a Stinson LLP lawyer who focuses her practice on real estate finance matters, renewable energy tax credit and new market tax credit issues, the firm has announced.

  • May 07, 2026

    Toss Of Ex-Shkreli Atty's Deal May Be Error, 2nd Circ. Hints

    A Second Circuit judge hinted Thursday that a trial judge may have erred in rejecting a retirement-fund garnishment deal that would have protected Martin Shkreli's convicted former lawyer from a potential $1 million "punitive tax event."

  • May 06, 2026

    Sony Reaped 'Windfall' From Illegal Tariffs, Gamers Say

    Sony Interactive Entertainment LLC retained a "substantial windfall" generated by illegal tariffs imposed under the International Emergency Economic Powers Act, two Sony PlayStation console owners said Wednesday in a proposed class action in California federal court.

  • May 06, 2026

    Calif. Tribe Can't Get ATF's Cigarette Sales Decision Tossed

    A Ninth Circuit panel determined Wednesday that federal tobacco regulators acted appropriately when placing the Twenty-Nine Palms Band of Mission Indians on a noncompliance list, concluding the tribe's remote cigarette sales to retailers of other tribes count as "off-reservation" activities covered by California state tax and licensing laws.

Expert Analysis

  • How Hyperlinks Are Changing E-Discovery Responsibilities

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    A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.

  • Preserving Refunds As Tariffs Await Supreme Court Weigh-In

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    In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.

  • Revamped Opportunity Zones Can Aid Clean Energy Projects

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    The Qualified Opportunity Zone program, introduced in 2017 and reshaped in the One Big Beautiful Bill Act, offers investors federal tax incentives for development in low-income communities — incentives that are especially meaningful for clean energy projects, where capital-intensive infrastructure and long-term planning are essential, say attorneys at Dentons.

  • Writing Musicals Makes Me A Better Lawyer

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    My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.

  • How Fashion, Tech Can Maximize New Small Biz Tax Breaks

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    Fashion and technology companies, which invest heavily in innovation, should consider taking advantage of provisions in the One Big Beautiful Bill Act that favor small businesses, restructuing if necessary to become eligible for expanded research and experimental expenditure credits and qualified small business stock incentives, says Aime Salazar at Olshan Frome.

  • Adapting To Private Practice: From Va. AUSA To Mid-Law

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    Returning to the firm where I began my career after seven years as an assistant U.S. attorney in Virginia has been complex, nuanced and rewarding, and I’ve learned that the pursuit of justice remains the constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.

  • 7 Document Review Concepts New Attorneys Need To Know

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    For new associates joining firms this fall, stepping into the world of e-discovery can feel like learning a new language, but understanding a handful of fundamentals — from coding layouts to metadata — can help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.

  • Agentic AI Puts A New Twist On Attorney Ethics Obligations

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    As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.

  • Opportunity Zone's Future Corp. Tax Benefits Still Uncertain

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    Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.

  • How GILTI Reform Affects M&A Golden Parachute Planning

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    Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.

  • What To Expect As Trump's 401(k) Order Materializes

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    Following the Trump administration’s recent executive order on 401(k) plan investments in alternative assets like cryptocurrencies and real estate, the U.S. Department of Labor and the U.S. Securities and Exchange Commission will need to answer several outstanding questions before any regulatory changes are implemented, say attorneys at Cleary.

  • Demystifying The Civil Procedure Rules Amendment Process

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    Every year, an advisory committee receives dozens of proposals to amend the Federal Rules of Civil Procedure, most of which are never adopted — but a few pointers can help maximize the likelihood that an amendment will be adopted, says Josh Gardner at DLA Piper.

  • Parenting Skills That Can Help Lawyers Thrive Professionally

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    As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.

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