Federal
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October 01, 2026
DOJ Outlines New Corporate Fraud Enforcement Priorities
Federal prosecutors "must place great weight" on a new list of factors when considering potential charges in corporate fraud cases, including whether the matters involve government programs, threats to national security or immigration offenses, according to a memo released Thursday by the U.S. Department of Justice.
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September 30, 2026
3rd Circ. Probes Payment Recipients In Fund's $100M Tax Row
A Third Circuit panel examined dealer-and-customer relations under accounting rules governing their transactions on Wednesday to determine whether the Internal Revenue Service was right to slap a $100 million tax bill against a Cayman Islands hedge fund for payments tied to U.S. portfolio companies.
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September 30, 2026
Senate Approves IRS Taxpayer Service Revamp
The Senate passed a wide-ranging bipartisan package Wednesday that would implement a slew of changes intended to improve taxpayer service, including a mandate that the agency digitize more tax returns and other correspondence.
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September 30, 2026
Tax Court Says Pair Can't Nullify Deadline Extension
The Internal Revenue Service timely sent notices regarding federal income tax deficiencies and accuracy-related penalties to a pair of Florida residents who challenged the agency's determinations, the U.S. Tax Court said Wednesday, rejecting the taxpayers' bid to void an agreement that extended the time for assessment.
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September 30, 2026
Landowners Seek 11th Circ. Redo On Easement Value Cut
Three Georgia conservation easement donors asked the full Eleventh Circuit to review a panel's split decision to slash the value of an easement they donated from $18 million to $1 million, saying the decision failed to take into account the property's highest and best use.
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September 30, 2026
Brothers Cop To Tax Crimes From Golf Side Hustle
Twin brothers pled guilty to failing to report $1.3 million in income to the Internal Revenue Service, including money made from a golf tee-time brokering business they ran as a side hustle, California federal prosecutors said.
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September 30, 2026
IRS Grants Relief To Taxpayers In Israel, West Bank, Gaza
Individuals and businesses in Israel, the West Bank and Gaza have additional time to file U.S. tax returns, make payments and perform other time-sensitive actions, the Internal Revenue Service said Wednesday.
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September 30, 2026
Polish Digital Tax Would Burden US Business, NFTC Says
The National Foreign Trade Council urged the Polish government to pause discussions about a proposed digital services tax, contending the measure would challenge international tax principles by disproportionately targeting U.S. companies.
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September 30, 2026
IRS Lists Budget Bill Guidance Among Top Priorities
Regulations to continue implementing the 2025 budget reconciliation bill are among the key items the Internal Revenue Service listed as priorities for the next 12 months, including guidance that would address changes to the base erosion and anti-abuse tax.
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September 30, 2026
Bessent Owes $910K In Taxes As Limited Partner, Wyden Says
Treasury Secretary Scott Bessent should pay more than $910,000 in payroll taxes as a hedge fund limited partner after the Second Circuit ruled that such partners are subject to the self-employment tax, Senate Finance Committee ranking member Ron Wyden said Wednesday.
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September 29, 2026
Tax Court Eschews IRS' Math In Facebook Royalty Dispute
The U.S. Tax Court rejected the IRS' proposed flat-rate royalty calculation for Facebook's deal with an Irish affiliate to develop intangibles, holding Tuesday that the rate should vary across asset categories and change over time to reflect underlying economic factors.
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September 29, 2026
IRS Plans To Scrap 71 More Guidance Docs Deemed Outdated
A revenue ruling that discussed prohibited allocations of securities in an S corporation and a notice that announced a higher withholding rate for gambling winnings are among dozens of guidance documents the IRS identified as extraneous and up for removal, the agency said Tuesday.
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September 29, 2026
IRS Issues Rules On Establishing Trump Accounts
The Internal Revenue Service released a guidance package Tuesday for tax-advantaged brokerage accounts for children, known as Trump Accounts, including temporary rules on how to establish one.
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September 29, 2026
Tax Court Approves Penalties On Captive Without Substance
The U.S. Tax Court on Tuesday approved IRS penalties imposed on policyholders of a California company's captive insurance policy that the agency determined to be lacking economic substance, finding they failed to report the transactions in their tax returns for 2015.
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September 29, 2026
Full 5th Circ. Asked To Review Limited Partner Tax Ruling
A Texas-based business consulting firm urged the Fifth Circuit's full bench to review a panel's revised opinion that narrowed a tax break for limited partners, arguing it eliminated a clear test for determining which partnership members are exempt from self-employment tax.
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September 29, 2026
Tax Co. Urges 5th Circ. To Deny Microcaptive Rules Case Stay
A global tax services provider asked the Fifth Circuit to deny the IRS' request to stay its challenge to the agency's reporting rules for microcaptive insurance companies pending the resolution of a similar case before the appeals court, saying it should be allowed to present its own arguments.
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September 29, 2026
11th Circ. Won't Pause Sanctions Against Trump In IRS Case
An Eleventh Circuit panel refused Tuesday to pause a district court's sanctions order barring President Donald Trump and others from citing the agreement he made to settle his $10 billion suit against the Internal Revenue Service while they appeal the order.
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September 29, 2026
Calif. Man Can't Duck $1M Penalties For Unreported Accounts
A San Diego businessman is on the hook for more than $1.1 million in civil penalties for failing to disclose offshore accounts to the IRS, a California federal judge said, holding that a disputed conversation between the man and his accountant did not preclude a ruling for the government.
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September 28, 2026
Insurance Broker Loses Bid To Undo $6.6M IRS Penalty
A Pennsylvania federal judge rejected an insurance broker's second attempt at challenging a $6.6 million tax penalty imposed by the Internal Revenue Service, ruling Monday that the penalty doesn't violate the company's Seventh Amendment rights.
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September 28, 2026
3 Takeaways From Siemens' Trial Over $3.5B Tax Deduction
Internal conflict at the IRS over a penalty, the recent court victory for another Siemens entity and the company's detailed tax planning are key factors the U.S. Tax Court will have to consider in deciding Siemens USA's case over a $3.5 billion deduction claimed for 2018.
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September 28, 2026
IRS Warns New ETF Strategies Could Be Abusive
New strategies using exchange-traded funds may be abusing the tax benefits of these legitimate investment vehicles holding various securities, the IRS said Monday, asking for public feedback on future enforcement that can avoid putting long-established tax planning practices at high risk.
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September 28, 2026
IRS Should Improve AI Risk Management, TIGTA Recommends
The Internal Revenue Service should bolster its risk management practices when using artificial intelligence, the Treasury Inspector General for Tax Administration said in a report released Monday.
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September 28, 2026
IRS May Have Shirked Fair Collection Process, TIGTA Says
Some Internal Revenue Service employees may not have adhered to fair practices when attempting to collect taxes, the Treasury Inspector General for Tax Administration said in a report released Monday assessing potential violations in 2024 and 2025.
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September 28, 2026
US, China Reach Deal On Tariff Cuts On $30B In Goods Each
An intergovernmental body tasked with managing trade between the U.S. and China has reached an agreement on $30 billion worth of nonsensitive goods exported from one country to the other that could benefit from more favorable tariff treatment.
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September 28, 2026
'Survivor' Winner Asks 1st Circ. To Vacate $3.3M Tax Ruling
The First Circuit should vacate a Rhode Island federal court's $3.3 million tax judgment against the first "Survivor" winner, he told the appeals court, saying a senior U.S. district judge improperly refused to review an objection he filed challenging his tax debt.
Expert Analysis
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Being A Magician Makes Me A Better Lawyer
The skills I've developed as a lifelong magician have translated directly into tangible benefits in the courtroom because performing magic and trying cases both live at the intersection of psychology, storytelling, timing and disciplined rehearsal, says Mark Dombroff at Fox Rothschild.
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A 3-Part Blueprint For Sentencing Variance Arguments
Tom Goldstein’s upcoming sentencing provides a useful lens for defense practitioners seeking a variance from the guidelines range, serving as a reminder to distinguish those requests from guidelines challenges and build an evidence-based case well before the hearing, says Joseph De Gregorio of Sentencing Advocacy Group.
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Mich. Banking Brief: All The Notable Legal Updates In Q2
The second quarter brought several notable financial services law developments to Michigan, including a U.S. Supreme Court ruling on state tax foreclosures, progress on a money transmission modernization bill package, and continued legislative momentum on cryptocurrency and mortgage lending, say attorneys at Dykema.
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Proof, Not Just Timing, Will Decide Clean Energy Credits
For wind and solar projects that sprinted to begin construction before the accelerated placed-in-service deadline of July 4, project owners must now assemble and maintain documentation to qualify the project and defend against a potential clean energy credit audit, says Peter Lowy at Nelson Mullins.
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Choral Singing Makes Me A Better Lawyer
Singing in the New York City Bar Chorus — a hobby partly inspired by the late U.S. District Judge Richard Owen, who infused my clerkship year with opera music — has improved my legal career by refining my abilities to listen, exude confidence and develop emotional intelligence, says Bonnie Baker at Friedman Kaplan.
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Tariff Refunds May Reshape Loan Covenant Calculations
Tariff refunds issued after the U.S. Supreme Court's Learning Resources decision may complicate borrowers' covenant calculations depending on accounting treatment, the timing of recognition, customer reimbursement obligations and credit agreement language, say attorneys at Mayer Brown.
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Power To The Paralegals: Burnout As A Structural Problem
Law firm leadership can best retain their paralegals not by encouraging self-care, but by seeking top-down structural solutions for the quiet proliferation of responsibilities and the vicarious exposure to client trauma that particularly drive burnout in this vital role, says Erika Sneeringer at Brockstedt Mandalas.
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Managing Post-IEEPA Tariff Refunds, Replacements And Risks
Companies and investors reeling from the rapid changes resulting from February's U.S. Supreme Court ruling that the International Emergency Economic Powers Act doesn't authorize tariffs should focus on understanding the duty refund process, the likely replacement tariffs and the operational ways they can minimize their tariff exposure, say attorneys at Debevoise.
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Wire Fraud Ruling May Upend White Collar Enforcement
A Texas federal court’s recent decision in U.S. v. Garza, dismissing wire fraud charges arising from an alleged $1 billion tax shelter scheme, advances a broader constitutional principle that could affect sentencing and reshape charging practices across white collar criminal cases involving specialized statutory regimes, say attorneys at Benesch.
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Economic Questions To Ask Amid Tariff Refund Class Actions
The U.S. Supreme Court's recent holding that the International Emergency Economic Powers Act doesn't authorize the president to impose tariffs has sparked class actions, but determining whether a retailer received a windfall is complex, even if it passed tariff costs into consumer prices before receiving a refund, say economists at Ankura Consulting Group.
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Cow Horse Makes Me A Better Lawyer
Moving an unwilling 800-pound cow while riding a horse at high speed is exhilarating, a little unhinged and, at least for me, a surprisingly effective training ground for litigation — both demand focus, preparation over rigid planning and the willingness to act despite fear, says Ashley Zitrin at Glenn Agre.
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Checking For AI Errors Is Now A Two-Way Street
A handful of recent federal and state cases demonstrate the importance of checking for errors generated by artificial intelligence not only in your own court submissions, but also your opponent's, as well as when catching opposing counsel's AI mistakes could result in an award for attorney fees, says Tamara Barago at Hollingsworth.
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5 Things Associates Must Ask About Their Firm's Merger Plan
The associates who navigate law firm mergers best ask the right questions early, such as inquiring about partners' plans, to assess how the merger could affect their workflow and career path, says Jackie Bokser-LeFebvre at Major Lindsey.