Federal

  • January 12, 2026

    Justices Won't Review Truck Co.'s $268M Tax Break Denial

    The U.S. Supreme Court declined Monday to review a Sixth Circuit decision finding that a Tennessee truck company seeking $268 million in excise tax exemptions might not qualify because the company's refurbished tractors may have been previously sold to tax-exempt buyers.

  • January 12, 2026

    Justices Nix Petition On Legal Malpractice Arbitration

    The U.S. Supreme Court declined Monday to review a petition that sought clarity on whether a court or arbitrator decides the issue of class arbitrability when the parties incorporate certain arbitral rules, in a long, winding legal malpractice dispute involving Louisiana medical companies.

  • January 12, 2026

    Justices Won't Review Ore. Tax On Delta's Intangibles

    The U.S. Supreme Court said Monday that it won't review Oregon's taxation of Delta Air Lines' intangible property, refusing to hear the company's appeal of an Oregon Supreme Court decision.

  • January 09, 2026

    7th Circ. Upholds Ex-Atty's Conviction In Burke Bribery Case

    The Seventh Circuit on Friday kept in place the conviction and 32-month prison sentence of a Chicago real estate developer and former attorney for offering legal work to ex-Alderman Edward Burke as a bribe for help with a zoning permit, finding the government presented sufficient evidence to support a guilty verdict and arguments to the contrary were "unavailing."

  • January 09, 2026

    Attys, Broker Ask 4th Circ. To Overturn Tax Fraud Convictions

    Two St. Louis tax attorneys and a North Carolina insurance broker have asked the Fourth Circuit to unravel their convictions for participating in a $22 million tax scheme, arguing the government failed to prove at trial that the tax plan they used was actually illegal.

  • January 09, 2026

    Vanguard Investors Win Final OK For $25M Tax Suit Deal

    A Pennsylvania federal judge finalized a $25 million settlement to end a class action accusing Vanguard of triggering an asset sell-off that saddled investors with capital gains taxes, handing the investors' attorneys more than $8 million in fees.

  • January 09, 2026

    US Disputes Right To Trial Before IRS Assesses FBAR Fines

    A California man wasn't entitled to a jury trial prior to the IRS assessing penalties for his failure to report foreign bank accounts because the U.S. Supreme Court decision he cited limiting administrative courts for securities fraud doesn't apply, the government told a California federal court.

  • January 09, 2026

    Taxation With Representation: King & Spalding, Torys, Milbank

    In this week's Taxation With Representation, power generation company Vistra Corp. acquires Cogentrix Energy from Quantum Capital Group, real estate firm Minto Group partners with Crestpoint Real Estate Investments to take Minto's apartment-focused real estate investment trust private, and engineering services provider Jacobs acquires a remaining stake in PA Consulting.

  • January 09, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, included final regulations for determining whether income of foreign governments derived within the U.S. is taxable.

  • January 08, 2026

    House Sends ACA Credit Expansion Extension To Senate

    The House of Representatives on Thursday approved legislation to reinstate the Affordable Care Act's expired enhanced premium tax credit for three more years, with 17 Republicans voting with Democrats to send the proposal to the Senate.

  • January 08, 2026

    OECD, Gov't Officials Praise 'Side-By-Side' Tax Deal

    Officials from Germany, the U.S. and the OECD on Thursday hailed a recently finalized agreement among roughly 150 countries as a balanced solution to the U.S.' desire for a global minimum tax regime that operates "side by side" with its own rules.

  • January 08, 2026

    Courts Back Agencies Despite Loper Bright Ruling, DOJ Says

    Appellate courts have mostly upheld federal agencies' interpretation of ambiguous statutes, including tax disputes, even after the U.S. Supreme Court's 2024 landmark decision that limited agency deference, a U.S. Department of Justice attorney said Thursday.

  • 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.

Expert Analysis

  • 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.

  • UK's 1st ICSID Claim Shows Bilateral Investment Treaty Reach

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    For the first time, the U.K. is facing a claim under the International Centre for Settlement of Investment Disputes Convention, underscoring the broader reality that treaty protections are no longer confined to investors in emerging markets, says Philipp Kurek at Signature Litigation.

  • Trump Tax Law's Most Impactful Corp. And Individual Changes

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    The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.

  • From Clerkship To Law Firm: 5 Transition Tips For Associates

    Excerpt from Practical Guidance
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    Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.

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