Federal

  • September 08, 2026

    Judge Nixes Atty's Bid For More Depositions In $12M Tax Suit

    A Colorado federal judge denied a request for additional depositions from counsel of an attorney and others accused of siphoning $12 million while advocating an illegal tax fee after determining the request for the depositions was untimely and made outside the discovery window.

  • September 08, 2026

    Tax Court Adds Five New Trial Locations, Expands Roles

    The U.S. Tax Court's chief judge announced that the court will hear cases in five new cities starting Tuesday, bringing the total to 79, while allowing all types of cases to be heard at each location.

  • September 08, 2026

    Eaton Challenges IRS Example On Intercompany Loans

    The IRS is misusing a regulatory example that is unrelated to its argument that Eaton cannot pay foreign affiliates for support that a lender would assume exists in the agency's bid to reduce related-party interest rates and fees, the company told the U.S. Tax Court.

  • September 08, 2026

    Senate Panel Sets Hearing On IRS Chief Counsel Pick

    The Senate Finance Committee will hold a hearing to consider four of President Donald Trump's nominees for various positions, including chief counsel at the Internal Revenue Service, the panel announced Tuesday.

  • September 08, 2026

    IRS Sets Emission Guidance For Biofuel Tax Credit Eligibility

    The IRS released Tuesday the emissions rates use to calculate the tax credit amount for the domestic production of less carbon intensive transportation fuel, including those made primarily of organic materials and other compounds derived from livestock manure. 

  • September 08, 2026

    With New Tax Partner, Simpson Thacher Boosts Sports Focus

    Jonathan Westreich joined Simpson Thacher & Bartlett LLP as a tax partner in its Los Angeles office, the firm announced Tuesday, deepening the firm's sports, media and entertainment bench.

  • September 08, 2026

    IRS Accepting Applications To 2027 Real-Time Audit Program

    The Internal Revenue Service is accepting applications for its compliance assurance process real-time audit program for 2027, the agency announced Tuesday.

  • September 08, 2026

    Canada Defends Retaliatory Tariffs Against US As Necessary

    Canadian Prime Minister Mark Carney defended Canada's retaliatory tariffs against the U.S. as they went into effect Tuesday, saying they are needed to protect Canadian workers and industries from President Donald Trump's latest trade war action.

  • September 08, 2026

    DC Circ. Affirms Injunction Against IRS-ICE Data Sharing

    The D.C. Circuit affirmed a lower court's preliminary injunction Tuesday barring the IRS from sharing taxpayer data with immigration authorities, finding that the coalition challenging the deal has standing and that the arrangement likely violates the law.

  • September 04, 2026

    DOJ Ordered To Turn Over 'Weaponization' Fund Discovery

    A Virginia federal magistrate judge ordered the Trump administration Friday to move quickly in turning over documents connected to its proposed "Anti-Weaponization Fund," including the names of those who structured it before the idea was shot down in several federal courts and withdrawn by the U.S. Department of Justice.

  • September 04, 2026

    4 Books Transfer Pricing Economists Think You Should Read

    What do transfer pricing experts — economists, specifically — do in the summer? In July, many of them attend the National Association for Business Economics' annual transfer pricing symposium and discuss their favorite books with Law360 during the coffee breaks. Others were kind enough to do it during their regular work hours. Here, Law360 looks at four of their picks.

  • September 04, 2026

    IRS Finalizes 50% Personal-Use Test For Car Loan Tax Break

    A vehicle's amount of personal use would be based on the buyer's expected use over the period of ownership for purposes of determining eligibility for the tax break on car loan interest enacted in last summer's budget law, according to final regulations released Friday.

  • September 04, 2026

    ERISA Recap: 5 Appellate Rulings To Know From August

    The Seventh Circuit kept an Arkansas pharmacy benefit manager rule in place as not preempted by federal benefits law, the Fourth Circuit revived an Altria ex-worker's dispute over benefit plan documents, and the Eleventh Circuit reversed a pretrial win for Royal Caribbean in cruise workers' suit challenging 401(k) funds. Here, Law360 looks at those and two other major appellate decisions from August involving ERISA that benefits attorneys may want to know.

  • September 04, 2026

    Chrisleys Fight Balch & Bingham's Bid To Ax Malpractice Suit

    Reality television stars Todd and Julie Chrisley asked a Georgia federal judge on Friday to reject an attempt by their former attorneys to dismiss a legal malpractice lawsuit that claims a critical pretrial mistake allowed evidence obtained through an unlawful search to be used against them at their criminal trial.

  • September 04, 2026

    4th Circ. Affirms $2.9M IRS Fine For Unreported Accounts

    The Fourth Circuit affirmed a $2.9 million fine Friday against a Hong Kong-based U.S. businessman, holding that he should have known there was a "grave risk" of inaccurate tax filings when he failed to disclose offshore accounts to the IRS.

  • September 04, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, included proposed rules addressing the 2025 federal budget bill's changes to how U.S. corporations account for the earnings of their offshore affiliates when calculating their taxable income.

  • September 04, 2026

    IRS Updates Rules For Changing R&D Accounting Methods

    The Internal Revenue Service on Friday updated its guidelines for those looking to get automatic consent to change their method of accounting for research and development expenditures to comply with changes made in President Donald Trump's two major tax bills.

  • September 04, 2026

    IRS Spent 64% Of $26B Current Funding, Watchdog Says

    The Internal Revenue Service has already spent 64% of the $26 billion that Congress appropriated earlier this year for the agency through 2031, directing most of the money toward enforcement and taxpayer services, according to the tax administration watchdog's report. 

  • September 03, 2026

    Developer Seeks To Restore $78M In Conservation Tax Perks

    The Internal Revenue Service was wrong to disallow two conservation easement deductions worth a combined $78 million based on potential mining activity without adequately explaining why, an Alabama real estate developer told the U.S. Tax Court.

  • September 03, 2026

    Tax Court Keeps Innocent Spouse Case Over IRS Mail Flaw

    The Internal Revenue Service failed to establish that it properly mailed a final determination notice to a Nevada woman, the U.S. Tax Court said Thursday, denying the agency's motion to dismiss for untimely filing.

  • September 03, 2026

    Social Security Number Needed For COVID Rebate, Court Says

    The U.S. Tax Court rejected a man's bid to claim a COVID-19-era tax rebate credit Thursday because he didn't provide a Social Security number on his return, instead using an individual taxpayer identification number.

  • September 03, 2026

    IRS Needs To Improve Representation Training, TIGTA Says

    The Internal Revenue Service needs to overhaul training related to taxpayers' rights to representation and direct contact restrictions after a review found some employees lacked required knowledge, the Treasury Inspector General for Tax Administration said.

  • September 03, 2026

    IRS Could Improve Follow-Up On Rich Nonfilers, TIGTA Says

    The IRS could secure a tax return or make an assessment in over 10,000 cases involving wealthy nonfilers by taking further action on those cases after issuing an initial notice, the Treasury Inspector General for Tax Administration estimated in a report released Thursday.

  • September 03, 2026

    IRS Moves To Strip Schools' Tax Exemptions Over DEI Policies

    As many as 18,000 private schools that enact racially based diversity and inclusion policies could lose their federal tax exemptions under a proposed rule released by the Internal Revenue Service on Thursday.

  • September 02, 2026

    Technology Biz Can't Deduct $59M, Tax Court Says

    A California man's technology business can't deduct the $59 million in losses it claimed for 2016 and 2017, the U.S. Tax Court held Wednesday in a case in which it also rejected the IRS' determinations of his individual income.

Expert Analysis

  • Parsing Clarifications On Foreign Entity Rules For Tax Credits

    Author Photo

    Recent U.S. Internal Revenue Service and Treasury Department guidance answers taxpayer questions on several key foreign entity rules under the One Big Beautiful Bill Act, but questions remain over transactions with companies that have ties to covered nations such as Iran, say attorneys at Cleary.

  • Aligning Microsoft Tools With NYC Bar AI Recording Guidance

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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

    Author Photo

    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.

Can't find the article you're looking for? Click here to search the Tax Authority Federal archive.