Federal

  • April 10, 2026

    Taxation With Representation: Goodwin, CMS, Wilson Sonsini

    In this week's Taxation With Representation, Gilead Sciences Inc. acquires clinical-stage biotechnology company Tubulis GmbH, private equity firm Court Square Capital Partners closes a multibillion-dollar fund and Neurocrine Biosciences Inc. buys rare-disease drugmaker Soleno Therapeutics Inc.

  • April 10, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service on Friday published its weekly internal revenue bulletin, which included an update on advance pricing agreements for U.S. multinational corporations completed in 2025.

  • April 09, 2026

    Rivera's Ex-Partner Kept Cut Of $50M Venezuela Contract

    Real estate developer and convicted drug trafficker Hugo Perera told jurors Thursday he regretted "1,000%" getting involved with former U.S. Rep. David Rivera in a $50 million contract with a unit of Venezuela's state-owned oil company but admitted he kept his $5 million cut of the deal.

  • April 09, 2026

    IRS Urged To Clarify Foreign-Owner Rules For Energy Credits

    Public power and nuclear associations, along with battery groups, are among stakeholders urging the Internal Revenue Service to clarify foreign ownership rules that could disqualify projects from certain clean energy tax credits, emphasizing that timely guidance is critical to securing project financing.

  • April 09, 2026

    Gov't Pushes DC Circ. To Unblock IRS-ICE Data Sharing

    The D.C. Circuit should remove a block on the IRS' policy of sharing data with immigration authorities, the government said Thursday, arguing that the groups challenging the policy have failed to show irreparable harm.

  • April 09, 2026

    Judge Tosses Ex-IRS Worker's Suit Alleging Political Firing

    A Virginia federal judge tossed a lawsuit by a former Internal Revenue Service employee who claimed she and others were fired in President Donald Trump's sweep of the agency as part of an effort to thwart audits of high-profile entities.

  • April 09, 2026

    Trade Court Shifts Tariff Refund Proceedings To New Suit

    The underlying U.S. Court of International Trade suit serving as the core of the government's development of a refund system for the now-invalidated International Emergency Economic Powers Act tariffs has changed after the original case was dismissed.

  • April 15, 2026

    The 2026 Lawyer Satisfaction Survey: Where Do You Stand?

    How is your work-life balance? Are you content with your compensation and opportunities for advancement at work? Take the 2026 Law360 Lawyer Satisfaction Survey and share your thoughts.

  • April 09, 2026

    IRS Urges Toss Of Revamped Stock Plan Rule Dispute

    A Wisconsin federal court should toss a company's remounted suit claiming the Internal Revenue Service secretly passed a rule targeting its stock ownership plan, the government argued, saying the company still has not presented any evidence that the rule exists.

  • April 08, 2026

    Tax Court Limits Varian's Deemed Dividends Deduction

    A deduction that California-based Varian Medical Systems was allowed for deemed dividends must be reduced by the amount of its corresponding foreign tax credit, the U.S. Tax Court held Wednesday.

  • April 08, 2026

    Tax Preparer Gets 12 Years In Largest-Ever COVID Tax Fraud

    A New Jersey tax preparer was sentenced Wednesday to 12 years in prison and ordered to pay $55 million in restitution to the Internal Revenue Service after a jury convicted him of tax fraud in what authorities said was the nation's largest tax fraud case involving COVID-19 pandemic relief money.

  • April 08, 2026

    IRS Settles FOIA Suit With Sanctioned Ex-Broker

    The federal government has settled a suit seeking the IRS' records of its investigation into an ex-broker sanctioned by the Financial Industry Regulatory Authority for hiding $1.7 million in tax liens, according to documents filed in North Carolina federal court Wednesday.

  • April 08, 2026

    Biz Owner Gets 4 Years, Owes $27M For Tax Credit Scheme

    A Nevada federal court sentenced a business owner to four-and-a-half years in prison and ordered her to pay $27 million to the IRS after she submitted nearly $100 million worth of false claims for employment tax refunds meant to help businesses stay afloat during the pandemic.

  • April 08, 2026

    Oil Giants Owed Far More Tax Abroad Than In US, Report Says

    Major U.S. energy companies continued to owe far more taxes abroad than domestically last year, with Exxon Mobil and Chevron each incurring less than 10% of their total liabilities from the federal government, the Financial Accountability and Corporate Transparency Coalition said in a report.

  • April 08, 2026

    IRS, NJ Woman Settle Refund Row After High Court Loss

    The IRS and a New Jersey resident reached a settlement in a $42,000 tax refund suit in federal court nearly a year after the U.S. Supreme Court maintained the agency could eliminate her tax debt using overpayments she claims were improperly retained. 

  • April 08, 2026

    1 Year Later, How Tariffs Have Crept Into Real Estate Contracts

    In the year since President Donald Trump's Rose Garden announcement of sweeping worldwide tariffs last April, real estate and construction lawyers have wrestled with how duties or potential duties fit into clients' deals, and sources recently shared more than half a dozen contract examples from the past year with Law360 Real Estate Authority.

  • April 08, 2026

    Senate Panel To Hold IRS Budget Hearing Next Week

    The Senate Finance Committee will hold a hearing April 15 on President Donald Trump's IRS budget proposal for fiscal year 2027 and on the 2026 tax filing season, the panel's chair said Wednesday.

  • April 07, 2026

    Rivera Kept $50M Venezuela Deal Quiet, Ex-Partner Says

    The government's star witness took the stand Tuesday in the criminal case against former U.S. Rep. David Rivera of Florida, telling jurors that Rivera and others kept a $50 million consulting contract with a unit of Venezuela's state-owned oil company quiet because of concerns about how it would be perceived in Miami.

  • April 07, 2026

    3rd Circ. Affirms NJ Man's Conviction For $40M Tax Fraud

    A jury was right to convict a New Jersey man who made $40 million from filing false tax returns in a countrywide securities fraud scheme, the Third Circuit found in upholding the conviction, saying his arguments were not compelling enough to reverse the guilty verdict.

  • April 07, 2026

    Partnership Wants Tax Court To Reconsider Basis Question

    A partnership asked the U.S. Tax Court to reconsider its finding that a company contributing a promissory note for a stake in the partnership had zero basis in the note, saying basis must be determined when a note is contributed, not at its conception.

  • April 07, 2026

    Partnership Tells Tax Court Settlement Was Long-Term Gain

    The $4 million payment a California partnership received in 2021 as part of a settlement should be characterized as long-term gain and not ordinary income, it told the U.S. Tax Court, saying its issue is the same as that in pending cases for prior years.

  • April 07, 2026

    Sen. Justice Challenges IRS Over $3.6M Tax Penalty

    West Virginia Sen. Jim Justice and his wife challenged a $3.6 million tax penalty for claiming what the Internal Revenue Service said was an erroneous refund for $18 million, telling the U.S. Tax Court they were improperly prevented from appealing the fine and can't afford to pay.

  • April 07, 2026

    IRS Updates Foreign Housing Expense Limits For 2026

    The Internal Revenue Service released adjustments Tuesday to the limitation on foreign housing expense deductions and exclusions for 2026.

  • April 07, 2026

    IRS Met Legal Requirements When Asking For Extensions

    The Internal Revenue Service followed the law when asking taxpayers to extend the statute of limitations for assessments, the Treasury Inspector General for Tax Administration said in a report released Tuesday.

  • April 07, 2026

    Floridian Says Jury Was Required Before $20M FBAR Fine

    A dual U.S.-German citizen urged a Florida federal court to reject a magistrate judge's recommendation to uphold a nearly $20 million tax judgment for undisclosed foreign bank account information, contending the judge failed to recognize a recent change in the law about access to jury trials. 

Expert Analysis

  • Aligning Microsoft Tools With NYC Bar AI Recording Guidance

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    The New York City Bar Association’s recently issued formal opinion, providing ethical guidance on artificial intelligence-assisted recording, transcription and summarization, raises immediate questions about data governance and e-discovery for companies that use Microsoft 365 and Copilot, say Staci Kaliner, Martin Tully and John Collins at Redgrave.

  • Preferred Equity Monetizations Unlock Energy Tax Credits

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    As private capital funds more energy and infrastructure projects, preferred equity monetization structures — combining elements of tax credit transfers and tax equity partnership-flip transactions with hybrid capital structures — can help project sponsors monetize federal tax credits, access private capital markets and gain structuring flexibility, say attorneys at Willkie.

  • 5 Different AI Systems Raise Distinct Privilege Issues

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    A New York federal court’s recent U.S. v. Heppner decision, holding that a defendant’s use of Claude was not privileged, only addressed one narrow artificial intelligence system, but lawyers must recognize that the spectrum of AI tools raises different confidentiality and privilege questions, says Heidi Nadel at HP.

  • After Learning Resources: A Practical Guide For US Importers

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    Following the U.S. Supreme Court's Feb. 20 decision in Learning Resources v. Trump, U.S. importers and consumers on whom tariffs were imposed under the International Emergency Economic Powers Act can seek relief through existing administrative procedures or a yet-to-be-determined bespoke refund mechanism, and should plan for more changes in the tariff landscape, say attorneys at Baker Botts.

  • AI-Assisted Arbitration Needs Safeguards To Ensure Fairness

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    As tribunals and arbitral institutions increasingly use artificial intelligence tools in their decision-making processes, ​​​​​​​clear disclosure standards and procedural safeguards are necessary to ensure that efficiency gains do not erode the fairness principles on which arbitration depends, says Alexander Lima at Wesco International.

  • AI-Generated Doc Ruling Guides Attys On Privilege Risks

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    A New York federal court's ruling, in U.S. v. Heppner, that documents created by a defendant using an artificial intelligence tool were not privileged, can serve as a guide to attorneys for retaining attorney-client or work-product privilege over client documents created with AI, say attorneys at Sher Tremonte.

  • The Law Firm Merger Diaries: Leadership Strategy After Day 1

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    For law firm leaders, ensuring a newly combined law firm lives up to its promise, both in its first days of operation and well after, includes tough decisions, clear and specific communication, and cheerleading, says Peter Michaud at Ballard Spahr.

  • Calif.'s Civility Push Shows Why Professionalism Is Vital

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    The California Bar’s campaign against discourteous behavior by attorneys, including a newly required annual civility oath, reflects a growing concern among states that professionalism in law needs shoring up — and recognizes that maintaining composure even when stressed is key to both succeeding professionally and maintaining faith in the legal system, says Lucy Wang at Hinshaw.

  • US-Ukraine Reconstruction Fund Tax Exemptions Uncertain

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    Tax provisions in the bilateral agreement to establish the U.S.-Ukraine Reconstruction Investment Fund, which recently announced it is accepting applications, are so broad and imprecise as to leave uncertainty regarding whether and when tax exemptions will apply to investors' income, say attorneys at Avellum and Debevoise.

  • Trivia Competition Makes Me A Better Lawyer

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    Playing trivia taught me to quickly absorb information and recognize when I've learned what I'm expected to know, training me in the crucial skills needed to be a good attorney, and reminding me to be gracious in defeat, says Jonah Knobler at Patterson Belknap.

  • Judges On AI: Practical Use Cases In Chambers

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    U.S. Magistrate Judge Allison Goddard in the Southern District of California discusses how she uses generative artificial intelligence tools in chambers to make work more efficient and effective — from editing jury instructions for clarity to summarizing key documents.

  • What's At Stake In Possible Circuit Split On Medicaid Rule

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    A recent Eleventh Circuit decision, reviving Florida's lawsuit against a federal rule that reduces Medicaid funding based on agreements between hospitals, sets up a potential circuit split with the Fifth Circuit, with important ramifications for states looking to private administrators to run provider tax programs, say Liz Goodman, Karuna Seshasai and Rebecca Pitt at FTI Consulting.

  • Malpractice Claim Assignability Continues To Divide Courts

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    Recent decisions from courts across the country demonstrate how different jurisdictions balance competing policy interests in determining whether legal malpractice claims can be assigned, providing a framework to identify when and how to challenge any attempted assignment, says Christopher Blazejewski at Sherin & Lodgen.

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