Federal

  • January 08, 2026

    Former IRS Official Criticizes CEO's Tax Prosecution

    A former IRS deputy commissioner criticized the U.S. Department of Justice for indicting a former software executive who was ultimately convicted of failing to pay employment taxes, calling the choice "entirely unwarranted" in a letter filed in North Carolina federal court.

  • January 08, 2026

    US Asks 6th Circ. To Revive Reg In $89M FedEx Tax Suit

    The Sixth Circuit should vacate a judgment that allowed FedEx an $89 million refund by discarding a regulation preventing companies from claiming foreign tax credits on earnings offset by losses, which aren't taxed in the U.S., the government said in an opening brief.

  • January 08, 2026

    4 Executive Pay Trends Attorneys Will Be Watching In 2026

    A potentially sweeping overhaul simplifying the U.S. Securities and Exchange Commission's disclosure regime for public company executive compensation will be top of mind for executive pay practitioners as they look for new developments in the coming year. Here's a look at this and three other areas they'll be keeping an eye on.

  • January 08, 2026

    Audits Get Final Word On Economic Substance, IRS Atty Says

    IRS attorneys provide legal guidance during audits on whether a transaction lacks economic substance, but examiners make the ultimate determination, an agency associate chief counsel said Thursday while explaining how the agency applies a powerful anti-abuse tool in audits.

  • January 08, 2026

    IRS Floats Changes To Third-Party Settlement Payments

    The Internal Revenue Service floated changes Thursday to withholding rules for organizations such as PayPal and Venmo that make payments to settle third-party network transactions, saying the move would align regulations with an increase to the threshold for tax reporting.

  • January 07, 2026

    US Official Gives Rationale For OECD Global Mobility Changes

    Recent changes to the commentary on when a home office gives rise to a permanent establishment in the OECD model tax treaty reflect delegates' unhappiness with previous language on the availability of an office, a U.S. Treasury Department official said Wednesday.

  • January 07, 2026

    House's ACA Credit Expansion Edges Toward Vote

    The House of Representatives voted Wednesday to begin debate on legislation that would reinstate the expired Affordable Care Act's enhanced premium tax credit for three more years.

  • January 07, 2026

    Treasury Eyes Final Easements Settlements, Official Says

    The U.S. Department of the Treasury plans to issue a summary of the IRS' successes in conservation easement cases as it works on a final settlement initiative for hundreds of remaining disputes, a department official said at a tax conference Wednesday.

  • January 07, 2026

    IRS Backdated Docs In Easement Penalty Fight, Tax Court Told

    The Internal Revenue Service improperly backdated documents to impose steep civil fraud penalties over a claimed $48 million deduction for a Louisiana conservation easement donation and bypass the statute of limitations, a partnership alleged in the U.S. Tax Court.

  • January 07, 2026

    Reckless Conduct Can Be Willful FBAR Failure, 2nd Circ. Says

    The standard for willful failure to report foreign bank accounts includes reckless conduct, and a 6% late payment penalty is mandatory for a couple who neglected fines for stashing millions in an undisclosed Swiss account, the Second Circuit said Wednesday, upholding a lower court's judgment.

  • January 07, 2026

    Tax Funding Oil Spill Cleanups Has Expired, IRS Clarifies

    The Internal Revenue Service clarified Wednesday that the part of an added tax on crude oil and petroleum products earmarked for an oil spill cleanup fund expired at the end of 2025.

  • January 07, 2026

    Feds Want To Use Goldstein's Comments To NYT At Trial

    Federal prosecutors preparing to try SCOTUSblog founder Tom Goldstein for tax crimes next week are looking to use his comments in a New York Times Magazine article against him, claiming that admissions and details from the article "directly prove" certain charges the government has brought.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.  

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

Expert Analysis

  • Supreme Court Term Limits Would Carry Hidden Risk

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    While proposals for limiting the terms of U.S. Supreme Court justices are popular, a steady stream of relatively young, highly marketable ex-justices with unique knowledge and influence entering the marketplace of law and politics could create new problems, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.

  • Tariffs And Trade Volatility Drove 2025 Bankruptcy Wave

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    The Trump administration's tariff regime has reshaped the commercial restructuring landscape this year, with an increased number of bankruptcy filings showing how tariffs are influencing first‑day narratives, debtor-in-possession terms and case strategies, say attorneys at Thompson Hine.

  • AI Evidence Rule Tweaks Encourage Judicial Guardrails

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    Recent additions to a committee note on proposed Rule of Evidence 707 — governing evidence generated by artificial intelligence — seek to mitigate potential dangers that may arise once machine outputs are introduced at trial, encouraging judges to perform critical gatekeeping functions, say attorneys at Lankler Siffert & Wohl.

  • The Law Firm Merger Diaries: Getting The Message Across

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    Communications and brand strategy during a law firm merger represent a crucial thread that runs through every stage of a combination and should include clear messaging, leverage modern marketing tools and embrace the chance to evolve, says Ashley Horne at Womble Bond.

  • Horizontal Stare Decisis Should Not Be Casually Discarded

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    Eliminating the so-called law of the circuit doctrine — as recently proposed by a Fifth Circuit judge, echoing Justice Neil Gorsuch’s concurrence in Loper Bright — would undermine public confidence in the judiciary’s independence and create costly uncertainty for litigants, says Lawrence Bluestone at Genova Burns.

  • 10 Commandments For Agentic AI Tools In The Legal Industry

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    Though agentic artificial intelligence has demonstrated significant promise for optimizing legal work, it presents numerous risks, so specific ethical obligations should be built into the knowledge base of every agentic AI tool used in the legal industry, says Steven Cordero at Akerman LLP.

  • A Close Look At The Evolving Interval Fund Space

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    Interval funds — closed-end registered investment companies that make periodic repurchase offers — have recently moved to the center of the conversation about retail access to private markets, spurred along by President Donald Trump's August executive order incorporating alternative assets into 401(k) plans and target date strategies, say attorneys at Simpson Thacher.

  • The Law Firm Merger Diaries: How To Build On Cultural Fit

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    Law firm mergers should start with people, then move to strategy: A two-level screening that puts finding a cultural fit at the pinnacle of the process can unearth shared values that are instrumental to deciding to move forward with a combination, says Matthew Madsen at Harrison.

  • Rare Tariff Authority May Boost US Battery Manufacturing

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    Finalizing preliminary tariffs on active anode material from China — the result of a rare exercise of statutory authority finding that foreign dumping hampered the development of a nascent U.S. industry — should help domestic battery manufacturing, but potential price increases could discourage related clean-energy use, say attorneys at MoloLamken.

  • Considerations When Invoking The Common-Interest Privilege

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    To successfully leverage the common-interest doctrine in a multiparty transaction or complex litigation, practitioners should be able to demonstrate that the parties intended for it to apply, that an underlying privilege like attorney-client has attached, and guard against disclosures that could waive privilege and defeat its purpose, say attorneys at DLA Piper.

  • The Law Firm Merger Diaries: Making The Case To Combine

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    When making the decision to merge, law firm leaders must factor in strategic alignment, cultural compatibility and leadership commitment in order to build a compelling case for combining firms to achieve shared goals and long-term success, says Kevin McLaughlin at UB Greensfelder.

  • What To Watch As NY LLC Transparency Act Is Stuck In Limbo

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    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.

  • Despite Deputy AG Remarks, DOJ Can't Sideline DC Bar

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    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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