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Federal
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May 22, 2026
FedEx Says Justices' Freight Ruling Backs $89M Tax Refund
The U.S. Supreme Court's opinion this month in a freight negligence case that adhered closely to statutory text bolsters an argument that the plain language of the law entitles FedEx to an $89 million foreign tax credit, notwithstanding a conflicting federal regulation, the company told the Sixth Circuit.
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May 21, 2026
DC Circ. Seeks Trump Admin Input On $5B Award Case
The D.C. Circuit on Thursday sought the views of the Trump administration on a crucial component of Russia's sovereign immunity defense as the appeals court weighs jurisdiction in litigation to enforce a nearly $5 billion arbitral award against the Kremlin, which was issued to Yukos Oil Co.'s financing arm.
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May 21, 2026
Goldstein Taps Ex-SG Prelogar Before Sentence, Likely Appeal
One of the nation's most accomplished oral advocates, Tom Goldstein, revealed Thursday he has retained another of the nation's most accomplished oral advocates, Elizabeth Prelogar, ahead of his sentencing and likely appeal in a criminal tax case that has captivated the appellate bar.
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May 21, 2026
Baltimore Atty Not Liable For Client's Taxes, 4th Circ. Told
A Baltimore attorney is challenging a court's order that he cover unpaid federal income taxes owed by his client's holding company, telling the Fourth Circuit on Thursday that the government is wrongly using the Federal Priority Statute as a workaround for the Federal Tax Lien Act.
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May 21, 2026
Amgen Wants To Preserve Right To Seek Double Tax Relief
Drugmaker Amgen wants to preserve its right to seek a refund for tax years 2010 through 2015 if the IRS "persists" in taking a position inconsistent with the agency's own arguments pertaining to those years in its audit of 2016 to 2018, the company told the U.S. Tax Court.
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May 21, 2026
The Tax Angle: Federal Debt Surge Raises Tax, Spending Risk
From a look at the tax policy implications of the nation's debt reaching 100% of the U.S. gross domestic product to the continuing stalemate in Congress over spending cuts versus tax cuts, here's a peek into a reporter's notebook on developing tax stories.
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May 21, 2026
'Check-The-Box' Correctly Applied To Partnership, IRS Says
The U.S. Tax Court properly applied what are commonly known as check-the-box rules in determining that a company contributing a promissory note for a stake in a partnership had zero basis in the note, the IRS said in objecting to the partnership's motion for reconsideration.
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May 21, 2026
Overseas Use Of IRS Mobile Devices Flagged By TIGTA
There were 173 uses of Internal Revenue Service mobile devices being taken abroad in 2024 without authorization, the Treasury Inspector General for Tax Administration said in a report released Thursday, recommending that the agency put enhanced controls in place to protect sensitive data.
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May 21, 2026
Trade Court Won't Pause Tariff Ruling During US Appeal
The U.S. Court of International Trade won't stay its ruling blocking the collection of temporary global duties for two businesses and the state of Washington while the federal government appeals the judgment to the Federal Circuit, according to an opinion.
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May 21, 2026
IRS Offers Broker-Dealers Additional Compliance Option
Broker-dealers holding custody of retirement accounts can follow the U.S. Securities and Exchange Commission's asset and customer protection rules as another approach to comply with nonbank trustee rules, the IRS said in guidance released Thursday.
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May 20, 2026
Nearly 28M Claim Overtime Deduction, House GOP Says
House Republicans touted results of tax provisions included in last year's budget bill during a House Ways and Means Committee hearing Wednesday, saying that almost 28 million Americans claimed the new tax deduction for overtime pay.
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May 20, 2026
IRS Extends Deadline For Long-Term Care Distributions
The IRS extended the deadline for sponsors of certain defined contribution retirement plans to amend the plans to allow qualified long-term care distributions, according to guidance released Wednesday.
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May 20, 2026
FERC Erred Over Utility's Tax Deferral Method, DC Circ. Told
Wholesale transmission customers of American Electric Power Co. Inc. units told the D.C. Circuit this week that the Federal Energy Regulatory Commission wrongly allowed the utility giant to depart from an established method to allocate carried-forward tax allowances, increasing those customers' rates.
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May 20, 2026
Trump-IRS Settlement A 'Corrupt Sham,' Capitol Cops Say
The settlement of President Donald Trump's $10 billion tax leak suit against the Internal Revenue Service — creating a $1.8 billion "anti-weaponization fund" — is a "corrupt sham," a pair of police officers present during the Jan. 6, 2021, Capitol riot told a D.C. federal court Wednesday.
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May 20, 2026
EU Lawmakers Agree To Include Safeguards In US Trade Deal
The Parliament and Council of the European Union reached a provisional agreement Wednesday morning to strengthen safeguards to the trade deal reached last year with the U.S., according to a press release.
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May 20, 2026
NM Marijuana Co. Says IRS Misinterprets Drug's Status
A careful reading of the law shows marijuana is not, as the IRS argues, a controlled substance under federal law, a New Mexico cannabis dispensary operator told the U.S. Tax Court in support of its business expense deductions claimed during 2017 through 2019.
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May 19, 2026
States Tell CIT To Reject Gov't's Request To Stay Tariff Ruling
The federal government's arguments to stay a permanent injunction against the collection of President Donald Trump's temporary global duties for two small businesses and the state of Washington while it appeals the ruling are overblown, a coalition of states told the U.S. Court of International Trade on Tuesday.
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May 19, 2026
Ex-Strip Club Operator To Forfeit $1.5M In Prostitution Plea
The former boss of a Connecticut strip club admitted Tuesday that he failed to pay taxes on income derived from prostitution and ripped off a COVID-19 relief program, and he will forfeit more than $1.5 million under a deal with federal prosecutors.
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May 19, 2026
Costco Calls Suit Over Tariff Refunds Premature
Costco urged an Illinois federal court to toss a putative consumer class action seeking to recoup the higher costs that shoppers paid under President Donald Trump's global tariffs, contending that the case is premature in the wake of uncertain corporate refunds.
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May 19, 2026
House OKs Changes For Tax Collection Due Process Cases
The House passed bipartisan legislation Tuesday billed as improving taxpayers' collection due process rights, including by pausing the statute of limitations for seeking a credit or refund amid a collection action proceeding, sending the measure to the Senate for consideration.
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May 19, 2026
$1.8B IRS Deal Fund 'Not Slush Fund,' Blanche Tells Senators
Acting Attorney General Todd Blanche argued before a Senate committee on Tuesday that the nearly $1.8 billion settlement fund announced on Monday as part of the president's settlement with the Internal Revenue Service over his leaked tax documents "is not a slush fund."
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May 19, 2026
DOJ Adds Sweeping Tax Audit Relief To Trump-IRS Settlement
The U.S. Department of Justice on Tuesday released an addendum to the settlement of President Donald Trump's suit against the IRS over the leak of his tax return information that bars the agency from investigating any pending matters against Trump.
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May 19, 2026
3 Fla. Partnerships Defend $113M Deducted For Land Grants
A trio of partnerships with the same Florida address are contesting in the U.S. Tax Court the total denied deductions of over $113 million, a combined $41.9 million in tax assessments and total penalties of $16.7 million for Alabama land donated to conservation groups in 2021.
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May 19, 2026
GAO Denies Protest Of Alleged Sole-Source IRS Procurement
The U.S. Government Accountability Office said the IRS did not unreasonably restrict competition in its search for a company to help the agency migrate to a new platform, finding the listed requirements were justified.
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May 19, 2026
IRS Finalizes Changes To Partnership Interest Sales
The IRS issued final regulations Tuesday that remove a requirement for partnerships to include information in tax returns to help partners who sold interests in businesses with noncapital assets determine their gain or loss, preserving the rules as proposed last year.
Expert Analysis
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Anticipating The Justices' Potential Ruling On Tax Takings
Recent oral arguments in the U.S. Supreme Court case Pung v. Isabella focused on rules for valuation, timing and administrability of tax auction proceeds and whichever method the court adopts for determining just compensation, it will have far-reaching impacts on tax collection, homeowners' equity and the secondary market for tax-foreclosed property, say attorneys at Holland & Knight.
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2 Discovery Rulings Break With Heppner On AI Privilege Issue
While a New York federal court’s recent ruling in U.S. v. Heppner suggests that some litigants’ communications with AI tools are discoverable, two other recent federal court decisions demonstrate that such interactions generally qualify for work-product protection under the Federal Rules of Civil Procedure, says Joshua Dunn at Brown Rudnick.
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CBP's $166B Tariff Refund Portal Needs 4 Safeguards
Before launching its automated web portal to process tariff-refund disbursements on April 20, U.S. Customs and Border Protection should apply the expensive lessons learned from the pandemic-era employee retention credit, says Peter Gariepy at RubinBrown.
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How Developers Can Leverage The New Markets Tax Credit
An increased regulatory focus on affordable housing raises important legal considerations for structuring transactions using the oft overlooked New Markets Tax Credit, which can fill a gap in affordable for-sale housing financing by lowering community developer costs but comes with unique compliance, structuring and documentation demands, say attorneys at Stinson.
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Calculating Damages In IEEPA Tariff Refund Litigation
To calculate damages in the spate of refund litigation triggered by the U.S. Supreme Court's recent decision invalidating tariffs collected under the International Emergency Economic Powers Act, the central question will be how to determine where in the supply chain their economic burden ultimately came to rest, say analysts at Charles River Associates.
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Alpine Skiing Makes Me A Better Lawyer
Skiing has shaped habits I rely on daily as an attorney — focus, resilience and the ability to remain steady when circumstances shift rapidly — and influences the way I approach legal strategy, client counseling and teamwork, says Isaku Begert at Marshall Gerstein.
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What A Court Doc Audit Reveals About Erroneous Filings
My audit of 1,522 court documents from last month found that over 95% contained at least one verifiable error, with fewer than 1% showing clear indicators of artificial intelligence use — highlighting above all else that lawyers may want to focus most on strengthening their review processes, says Elliott Ash at ETH Zurich.
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Mich. Banking Brief: All The Notable Legal Updates In Q1
Michigan's financial services sector saw several significant developments in 2026's first quarter, including the state Department of Insurance and Financial Services' issuance of a bulletin on the use of artificial intelligence and the Michigan House's introduction of a bill based on the Model Money Transmission Modernization Act, say attorneys at Dykema.
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Navigating The Perks Of Qualified Opportunity Zones 2.0
The second iteration of the qualified opportunity zone program, effective Jan. 1, 2027, will introduce new tax incentives for rural real estate development, but these benefits can only be realized if proper governance is a priority, including clear documentation and securities law compliance, says Coni Rathbone at VF Law.
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Getting The Most Out Of Learning And Development Programs
Excerpt from Practical Guidance
Junior associates can better develop the legal, business and interpersonal skills they need for long-term success by approaching their firms’ learning and development programs armed with five tips for getting the most out of these resources, says Lauren Hakala at Reed Smith.
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AI Presents A Make-Or-Break Moment For Outside Counsel
The rapid adoption of artificial intelligence by corporate legal departments is forcing a long-overdue reset of the relationship between inside and outside counsel, and introducing a significant opportunity to shed frustrating inefficiencies and strengthen collaboration for firms willing to embrace the shift, says Intel Chief Legal Officer April Miller Boise.
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8 Tariff Refund Questions For Restructuring Professionals
For restructuring and turnaround professionals, seeking refunds following the U.S. Supreme Court's recent decision invalidating tariffs imposed under the International Emergency Economic Powers Act raises several questions about how to capture legitimate recoveries while protecting an enterprise from the consequences of its own history, says Jonny Frank and Laura Greenman at StoneTurn, and Andrew Popescu at Province.
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5 Tips For Navigating Your Firm's All-Attorney Summit
Excerpt from Practical Guidance
Law firm retreats should be approached strategically, as they present valuable opportunities to advance both the firm's objectives and attorneys' professional development through meaningful participation, building and strengthening internal relationships, and proactive follow-up, says James Argionis at Cozen O’Connor.