Federal
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January 07, 2026
IRS Mulling Budget Bill's Changes To CFC Rules, Official Says
The Internal Revenue Service is weighing a balance between precision and administrability as it works on guidance for U.S. shareholders of foreign companies after the federal budget bill changed how to allocate overseas income, an agency official said Wednesday.
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January 07, 2026
IRS Outlines Process For PFICs Seeking Retroactive Elections
The Internal Revenue Service set out requirements Wednesday for passive foreign investment corporations seeking rulings to allow them to make retroactive qualified electing fund elections.
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January 06, 2026
Ex-Moving Co. Exec Denied New Trial In $8M Payroll Tax Case
A former moving company president who was convicted of scheming to defraud the Internal Revenue Service out of nearly $8 million in payroll taxes cannot get his verdict vacated, a New York federal court ruled, denying his claim of ineffective counsel as untimely.
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January 06, 2026
Tax Groups Push Supreme Court On California Tax Rule
A special income tax rule California uses along with its single-sales-factor apportionment method creates distortion and the U.S. Supreme Court should decide if it also violates the constitution, a taxpayer group said Tuesday.
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January 06, 2026
Tax Court Tosses $189K Charity Deduction For Lack of Proof
A California couple is not entitled to deduct nearly $189,000 for thousands of items they donated to a charity, the U.S. Tax Court ruled Tuesday, finding they failed to provide sufficient documentation to substantiate the value of the donated goods.
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January 06, 2026
Tax Court Strips Exempt Status From Powdered Milk Donor
An organization that sent powdered milk donations for children overseas was mostly running a commercial coffee shop and was therefore not entitled to tax-exempt status, the U.S. Tax Court said Tuesday, agreeing with the Internal Revenue Service.
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January 06, 2026
IRS Appeals Pause Of ICE Info-Sharing Agreement
The Internal Revenue Service is appealing to the D.C. Circuit a federal court order temporarily stopping the agency from sharing confidential taxpayer addresses with immigration enforcement officials, according to a filing Tuesday in D.C. federal court.
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January 06, 2026
Tax Firm Says IRS Can't Justify Microcaptive Reporting Rules
A global tax services provider urged a Texas federal court to vacate tax reporting rules for microcaptive insurance companies, arguing that the Internal Revenue Service failed to provide evidence of tax evasion that would justify the regulations.
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January 06, 2026
Paul Hastings Adds Ex-Cravath Tax Pro To Growing M&A Team
After adding 20 partners to its mergers and acquisitions platform over the past two years, Paul Hastings LLP announced on Tuesday that it has hired a former Cravath Swaine & Moore LLP partner who advises on the tax elements of mergers and acquisitions.
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January 05, 2026
Feds Fight To Keep Goldstein 'Sham Employee' Evidence
Federal prosecutors heading to trial against former SCOTUSblog publisher Tom Goldstein are urging a judge to deny his bid to prevent a jury from hearing about four love interests allegedly paid as no-show employees at his former law firm.
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January 05, 2026
'Truly Extreme': 9th Circ. Judges Decry Trump Layoffs Ruling
The Ninth Circuit on Monday refused to revisit a three-judge panel's decision rejecting the Trump administration's challenge of a lower court's ruling requiring production of its plans for large-scale layoffs and reorganizations at various federal agencies, a decision that was met with fiery dissent from several of the court's Republican-appointed judges.
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January 05, 2026
3rd Circ. Won't Rethink Tax On Interest In $191M Pharma Deal
The Third Circuit declined to reconsider its decision that a pharmaceutical company's $191 million payment settling a family feud was for the sale of a family trust's ownership shares and included interest that should be taxed as ordinary income.
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January 05, 2026
Partnership Fights Axed $60M Tax Break For Conservation Gift
A partnership challenged the IRS' denial of its nearly $60 million tax deduction for protecting forestland and other open space in Georgia, telling the U.S. Tax Court the land could have been used for valuable granite mining before the partnership stopped it from being developed.
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January 05, 2026
Countries Reach Deal To Exempt US From Pillar 2 Tax
Nearly 150 countries finalized the details Monday of a safe harbor that would effectively exempt U.S. companies from a 15% global minimum tax known as Pillar Two, following months of international negotiations and retaliatory tax threats from the U.S.
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January 05, 2026
Gibson Dunn Adds Sidley Tax Pro In Silicon Valley
Gibson Dunn & Crutcher LLP announced Monday that it has bulked up its tax practice group with a partner in Palo Alto, California, who previously co-led the global tax practice and headed up the West Coast tax group at Sidley Austin LLP.
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January 05, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, dated Monday, included guidance for new tax relief for farmers who pay capital gains tax on a farmland property sale to another farmer.
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January 02, 2026
Ga. Partnership Contests Denial Of $15.7M Property Donation
A Georgia partnership invoked the Fifth Amendment in defending its $15.7 million conservation easement tax deduction in the U.S. Tax Court, arguing that the IRS in denying the deduction effectively is taking private property for public use without just compensation.
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January 02, 2026
Busy DOJ Tax Atty Seeks More Time In 7th Circ. AbbVie Case
A U.S. Department of Justice tax attorney asked the Seventh Circuit on Friday for another extension to file an opening brief in a dispute over AbbVie's $1.6 billion payment to an Irish biotechnology company, citing staffing shortages and internal procedural requirements.
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January 02, 2026
IRS Floats 50% Personal-Use Test For Car-Loan Tax Break
Individuals, trusts and estates could claim up to $10,000 for the new auto-loan interest deduction only if the vehicle was used more than 50% of the time for personal purposes under proposed regulations published Friday by the IRS.
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January 02, 2026
IRS Floats Updates To Fee Paid By Brand Drugmakers
The Internal Revenue Service floated updates to regulations governing how branded prescription drug manufacturers or importers should calculate an annual fee established by the Affordable Care Act, a move the agency said aims to incorporate changes in drug discount programs and clarify tax reporting.
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January 02, 2026
Guns, Taxes & Labor: Cannabis Litigation Trends To Watch
In 2026, courts throughout the U.S. will consider cases weighing Second Amendment rights of cannabis users, a punitive federal tax policy that affects state-legal marijuana businesses, labor peace requirements in the cannabis space, and whether a constitutional doctrine bars states from preferencing their residents in doling out marijuana licenses.
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January 02, 2026
Federal Tax Policy To Watch In 2026
Changes to federal tax policy are relatively uncommon in midterm election years as lawmakers, many of whom prioritize political positioning over major tax overhauls, show little appetite for sweeping legislation or even narrower fixes that could attract bipartisan support. Here, Law360 examines federal tax policy to watch in 2026.
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January 02, 2026
Top Federal Tax Cases To Watch In 2026
The application of self-employment taxes to limited partners, the economic substance doctrine's threshold and the question of whether IRS penalties need a jury's deliberation are topics federal courts likely will examine in coming decisions. Here, Law360 reviews the top federal tax cases to watch in the coming year.
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January 02, 2026
Top International Tax Cases To Watch In 2026
Major multinational corporations such as McKesson and Coca-Cola will continue to litigate high-stakes international tax cases in 2026, including transfer pricing disputes with billions of dollars on the line and fights over whether regulations exceed the government's authority. Here, Law360 looks at four key international tax cases to follow in the new year.
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January 01, 2026
4 High Court Cases To Watch This Spring
The U.S. Supreme Court justices will return from the winter holidays to tackle several constitutional disputes that range from who is entitled to birthright citizenship to whether transgender individuals are entitled to heightened levels of protection from discrimination.
Expert Analysis
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How The CRE Industry Is Adapting To Tariff Uncertainty
Amid uncertainty about pending tariffs and their potential ripple effects, including higher material costs, supply chain delays and tighter margins, commercial real estate industry players are focusing on strategic planning and risk mitigation, says Daniel Diaz Leyva at Day Pitney.
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Law Firm Executive Orders Create A Legal Ethics Minefield
Recent executive orders targeting BigLaw firms create ethical dilemmas — and raise the specter of civil or criminal liability — for the government attorneys tasked with implementing them and for the law firms that choose to make agreements with the administration, say attorneys at Buchalter.
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Trade Policy Shifts Raise Hurdles For Gov't And Cos. Alike
The persistent tension between the Trump administration's fast-moving and aggressive trade policies and the compliance-heavy nature of the trade industry creates implementation challenges for both the business community and the government, says Sara Schoenfeld at Kamerman.
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Firms Must Embrace Alternative Billing Models Or Fall Behind
As artificial intelligence tools eliminate inefficiencies and the Big Four accounting firms enter the legal market, law firms that pivot from the entrenched billable hour model to outcomes-based pricing will see a distinct competitive advantage, says attorney William Brewer.
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How Attorneys Can Master The Art Of On-Camera Presence
As attorneys are increasingly presented with on-camera opportunities, they can adapt their traditional legal skills for video contexts — such as virtual client meetings, marketing content or media interviews — by understanding the medium and making intentional adjustments, says Kerry Barrett.
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Adapting To Private Practice: From Fed. Prosecutor To BigLaw
Making the jump from government to private practice is no small feat, but, based on my experience transitioning to a business-driven environment after 15 years as an assistant U.S. attorney, it can be incredibly rewarding and help you become a more versatile lawyer, says Michael Beckwith at Dickinson Wright.
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Justices' False Statement Ruling Curbs Half-Truth Liability
The U.S. Supreme Court’s recent Thompson v. U.S. decision clarified that a federal statute used to prosecute false statements made to bank regulators only criminalizes outright falsehoods, narrowing prosecutors’ reach and providing defense counsel a stronger basis to challenge indictments of merely misleading statements, says Tamara de Silva at De Silva Law Offices.
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Perfecting Security Interests In Renewable Energy Tax Credits
The ability to transfer renewable energy tax credits has created new opportunities for developers, investors and lenders, but it also raises important questions regarding when and how the security interests in these credits are perfected — questions that must be answered definitively to protect credit claims and transactions, says Harry Teichman at Stinson.
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Firms Still Have Lateral Market Advantage, But Risks Persist
Partner and associate mobility data from the fourth quarter of 2024 shows that we’re in a new, stable era of lateral hiring where firms have the edge, but leaders should proceed cautiously, looking beyond expected revenue and compensation analyses for potential risks, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
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Making The Opportunity Zones Program Great At Last
As the opportunity zone program approaches its expiration, the Republican-led government could take specific steps to extend and improve the program, address its structural flaws, encourage broader participation and enable it to live up to its promised outcomes, say attorneys at Pillsbury.
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We Must Allow Judges To Use Their Independent Judgment
As two recent cases show, the ability of judges to access their independent judgment crucially enables courts to exercise the discretion needed to reach the right outcome based on the unique facts within the law, says John Siffert at Lankler Siffert & Wohl.
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Preparing For Tariffs On Canadian Power In The Northeast
The on-again, off-again risk of import and export tariffs on energy transactions between the U.S. and Canada may have repercussions for U.S. energy stakeholders in the ISO New England and New York Independent System Operator electricity markets — but there are options that could help reduce cost impacts, say attorneys at Husch Blackwell.
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Making The Case For Rest In The Legal Profession
For too long, a culture of overwork has plagued the legal profession, but research shows that attorneys need rest to perform optimally and sustainably, so legal organizations and individuals must implement strategies that allow for restoration, says Marissa Alert at MDA Wellness, Carol Ross-Burnett at CRB Global, and Denise Robinson at The Still Center.