Federal

  • 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.

  • 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.

Expert Analysis

  • Senate's 41% Litigation Finance Tax Would Hurt Legal System

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    The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.

  • Drawbacks For Taxpayers From Justices' Levy Dispute Ruling

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    The Supreme Court's June decision in Commissioner v. Zuch, holding the Tax Court lacks jurisdiction to resolve disputes where the IRS has stopped pursuing a levy, may require taxpayers to explore new tactics for mitigating the increased difficulty of appealing their liability via collection due process hearings, says Matthew Roberts at Meadows Collier.

  • How Energy Cos. Can Prepare For Potential Tax Credit Cuts

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    The Senate Finance Committee's version of the One Big Beautiful Bill act would create a steep phaseout of renewable energy tax credits, which should prompt companies to take several actions, including conduct a project review to discern which could begin construction before the end of the year, say attorneys at Husch Blackwell.

  • DOJ Has Deep Toolbox For Corporate Immigration Violations

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    With the U.S. Department of Justice now offering rewards to whistleblowers who report businesses that employ unauthorized workers, companies should understand the immigration enforcement landscape and how they can reduce their risk, say attorneys at McDermott.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.

  • Del. Dispatch: General Partner Discretion In Valuing Incentives

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    In Walker v. FRP Investors, the Delaware Court of Chancery recently held that the general partner of a limited partnership breached its obligations when determining the threshold value of newly issued incentive units, highlighting the court's willingness to reconstruct what a reasonable determination of value by a general partner should have been, say attorneys at Fried Frank.

  • Move Beyond Surface-Level Edits To Master Legal Writing

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    Recent instances in which attorneys filed briefs containing artificial intelligence hallucinations offer a stark reminder that effective revision isn’t just about superficial details like grammar — it requires attorneys to critically engage with their writing and analyze their rhetorical choices, says Ivy Grey at WordRake.

  • 9th Circ. Has Muddied Waters Of Article III Pleading Standard

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    District courts in the Ninth Circuit continue to apply a defunct and especially forgiving pleading standard to questions of Article III standing, and the circuit court itself has only perpetuated this confusion — making it an attractive forum for disputes that have no rightful place in federal court, say attorneys at Gibson Dunn.

  • Steps For Universities To Pass Tax-Exempt Test Amid Scrutiny

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    After decades of a quiet governmental acceptance of tax-exempt status, universities are facing unprecedented and public pressure to defend themselves, and must consider how to protect this valuable status, say attorneys at Eversheds Sutherland.

  • Tax Court Ruling Sets High Bar For Limited Partner Exception

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    The U.S. Tax Court’s recent decision in Soroban Capital Partners v. Commissioner endorsed the IRS’ use of functional analysis to determine whether the limited partner exception applied for taxation under the Self-Employed Contributions Act, highlighting the intense factual analysis that will occur during audits, says Erin Hines at Akerman.

  • How AI May Reshape The Future Of Adjudication

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    As discussed at a recent panel at Texas A&M, artificial intelligence will not erase the human element of adjudication in the next 10 to 20 years, but it will drive efficiencies that spur private arbiters to experiment, lead public courts to evolve and force attorneys to adapt, says Christopher Seck at Squire Patton.

  • When Legal Advocacy Crosses The Line Into Incivility

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    As judges issue sanctions for courtroom incivility, and state bars advance formal discipline rules, trial lawyers must understand that the difference between zealous advocacy and unprofessionalism is not just a matter of tone; it's a marker of skill, credibility and potentially disciplinary exposure, says Nate Sabri at Perkins Coie.

  • Attacks On Judicial Independence Tend To Manifest In 3 Ways

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    Attacks on judicial independence now run the gamut from gross (bald-faced interference) to systemic (structural changes) to insidious (efforts to undermine public trust), so lawyers, judges and the public must recognize the fateful moment in which we live and defend the rule of law every day, says Jim Moliterno at Washington and Lee University.

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