Federal

  • July 10, 2026

    Taxation With Representation: Cleary, Paul Weiss, Fried Frank

    In this week's Taxation With Representation, Solstice Advanced Materials Inc. acquires specialty chemicals technology company Element Solutions Inc., Vertex Pharmaceuticals Inc. buys Crinetics Pharmaceuticals Inc., and Lockheed Martin acquires naval defense company Ultra Maritime.

  • July 09, 2026

    Judge Backs Feds' Valuation Method In Windfarm Grant Fight

    A U.S. Court of Federal Claims judge ordered several California wind farm owners and the federal government to largely employ a method the government proposed to value their facilities and hash out a decade-old dispute over grants worth hundreds of millions of dollars.

  • July 09, 2026

    Okla. Tax Officials Say McGirt Can't Upend Osage Ruling

    Oklahoma tax officials say the Osage Nation can't rely on a 2020 landmark U.S. Supreme Court ruling to overturn a decision that declined to vacate a 16-year-old determination that its reservation boundaries had been disestablished, telling the Tenth Circuit that the tribe's challenge is too late.

  • July 09, 2026

    IRS Asks 7th Circ. To Rehear $300M Hyatt Perks Tax Dispute

    The IRS asked the Seventh Circuit to reconsider its decision to remand a dispute over $300 million in Hyatt Hotels' loyalty rewards program fund to the U.S. Tax Court for it to determine whether the money can be excluded from taxable income under what's known as the claim of right doctrine.

  • July 09, 2026

    IRS Updates Outdated References In Estate Tax Rules

    The Internal Revenue Service released final regulations that modify and replace outdated references in rules for deceased taxpayers who have passed their property to a noncitizen spouse in a domestic trust.

  • July 09, 2026

    Reclassified Debt Didn't Cause $21M Gain, Partnership Says

    The IRS wrongly treated the reclassification of $21.1 million in debt to equity as a taxable event when hitting a partnership with $12.8 million in taxes, penalties and estimated interest, the partnership told the U.S. Tax Court.

  • July 09, 2026

    4th Circ. Rebuffs Tax Attys' Request To Rethink Convictions

    The Fourth Circuit will not rethink its decision last month affirming the convictions of two St. Louis attorneys accused of engineering a $22 million tax avoidance scheme.

  • July 09, 2026

    5 Clifford Chance Finance And Tax Attys Join Sidley In NY, DC

    Sidley Austin LLP announced Thursday that five Clifford Chance LLP attorneys have joined the firm's global finance and tax practices in New York and Washington, D.C.

  • July 09, 2026

    Pillar 2 Carveouts Won't Undercut Global Tax, Official Says

    The integrity of the 15% global minimum tax system will not be undermined by a host of nations gaining access to provisions that exempt them from certain obligations, the tax head at the Organization for Economic Cooperation and Development said Thursday.

  • July 08, 2026

    Partnership Defends $55.6M Deduction For Mo. Land Gift

    A partnership that donated over 73 acres in Butler County, Missouri, to a conservation group told the U.S. Tax Court it properly deducted $55.6 million for the gift, saying the value was based on the analysis of two qualified appraisers.

  • July 08, 2026

    IRS To Give Automatic Penalty Relief To Compliant Taxpayers

    Taxpayers with a history of filing and paying on time will no longer have to request penalty relief under an automatic exemption expected to roll out this summer, the IRS announced Wednesday.

  • July 08, 2026

    IRS Finalizes Life Insurance Reporting Exception Regs

    The Internal Revenue Service confirmed that certain tax-free transfers of life insurance contracts are exempt from the 2019 reporting rules for life settlement transactions, including policy sales and death benefit payments, under final regulations released Wednesday.

  • July 08, 2026

    IRS Urged To Make Digital Broker E-Statements Easier

    The IRS should update regulations that would allow digital asset brokers to provide statements electronically to remove operational hurdles and designate more effective communication methods, such as in-app messaging and SMS, stakeholders told the agency Wednesday.

  • July 08, 2026

    Shopping Center Owner's Estate Disputes $41M Deficiency

    The estate of a man who co-owned a Massachusetts shopping center challenged a $40.8 million deficiency assessment in the U.S. Tax Court, saying the IRS wrongly determined that a 2012 sale of his interest in the partnership owning the center wasn't bona fide.

  • July 08, 2026

    IRS Targets Certain Annuity Trusts As Potential Tax Shelters

    The IRS unveiled final rules Wednesday designating certain charitable remainder annuity trusts as reportable transactions because they involve abusive tax avoidance practices, subjecting participants to potential penalties if they do not disclose such arrangements.

  • July 08, 2026

    Foley Adds Attys From Kirkland, Goodwin To Corporate Team

    Foley & Lardner LLP has strengthened its corporate bench with a Dallas-based partner who came aboard from Kirkland & Ellis LLP and a Boston-based partner from Goodwin Procter LLP.

  • July 07, 2026

    2 Ex-Telehealth Execs Sentenced For $100M Adderall Scheme

    A California federal judge on Tuesday sentenced two former executives of a telehealth company who were convicted of operating a $100 million scheme to illegally distribute Adderall over the internet, fining them $1 million each and giving the founder six years in prison.

  • July 07, 2026

    DC Circ. Backs Tax Bribery Convictions Despite Jury Error

    A D.C. Circuit panel refused on Tuesday to reverse a lower court's judgments against two men in connection to a bribery scheme carried out to evade $2.3 million in business tax obligations, finding a jury instruction error "harmless," among other unsuccessful arguments.

  • July 07, 2026

    Dem Sens. Probe CEOs On Trump-IRS Settlement Immunity

    Three senior Democratic senators are investigating whether several companies with ties to President Donald Trump are benefiting from what they alleged was immunity for him, his family and his businesses in the settlement he reached with the Internal Revenue Service. 

  • July 07, 2026

    Exxon Seeks $324M Judgment In Dispute On Qatar Deal Tax

    Exxon asked a Texas federal court to rule that it's owed a $273 million tax refund and $51 million in penalties in a dispute with the U.S. government over the tax treatment of a natural gas deal with Qatar.

  • July 07, 2026

    IRS Denies Blowing Deadline In $34M Easement Dispute

    The IRS timely issued a notice of adjustment to a partnership claiming a $34 million easement deduction for its donation to a Cleveland historic preservation group, the agency told the U.S. Tax Court, arguing that the partnership is raising a frivolous contention in seeking to throw out the adjustment and penalties.

  • July 07, 2026

    Consultant Says FARA Verdict Should Be Erased

    A political consultant convicted of knowingly failing to register as a foreign agent as she helped draft a $50 million contract involving a former congressman and Venezuela's state-owned oil enterprise continues to argue she should be acquitted or given a new trial, saying the verdict was "against the great weight of the evidence."

  • July 07, 2026

    Claims Court Nixes GILTI Tax Rules Under Loper Bright

    The U.S. Court of Federal Claims invalidated corporate tax regulations that deny amortization deductions tied to certain overseas intangible asset transfers, holding that the rules are the kind of "agency overreach" foreclosed by the U.S. Supreme Court's Loper Bright ruling.

  • July 07, 2026

    Grocers' Microcaptive Not Valid For Tax Benefit, 7th Circ. Told

    Chicagoland grocery chain owners were not entitled to microcaptive tax benefits because they failed to establish a bona fide in-house insurance arrangement, the government told the Seventh Circuit, saying the U.S. Tax Court correctly held that state law does not control the federal tax definition of insurance.

  • July 07, 2026

    Simpson Thacher Adds Energy Tax Partner From Weil In NY

    Simpson Thacher & Bartlett LLP announced Tuesday that a former Weil Gotshal & Manges LLP partner has joined the firm's New York office to advise clients on the U.S. tax aspects of energy and infrastructure transactions.

Expert Analysis

  • 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.

  • Unpacking The New Opportunity Zone Tax Incentive Program

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    The One Big Beautiful Bill Act brought several improvements to the opportunity zone tax incentive program that should boost investments in qualified funds, including making it permanent, increasing federal income tax benefits in rural areas, redesignating the qualified zones, and requiring more in-depth reporting, says Marc Schultz at Snell & Wilmer.

  • Trump Tax Law's Most Impactful Energy Changes

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    The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.

  • Adapting To Private Practice: From Texas AUSA To BigLaw

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    As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.

  • Advice For 1st-Gen Lawyers Entering The Legal Profession

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    Nikki Hurtado at The Ferraro Law Firm tells her story of being a first-generation lawyer and how others who begin their professional journeys without the benefit of playbooks handed down by relatives can turn this disadvantage into their greatest strength.

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