Federal

  • May 06, 2026

    Investors Want Puerto Rican Opportunity Zone Safe Harbor

    Investors, developers and policy organizations requested clear and timely guidance on the transition protections for existing opportunity zone investments in Puerto Rico before they expire at the end of 2027 in a letter to the U.S. Department of the Treasury released Wednesday.

  • May 06, 2026

    Extend Immediate Expensing For Plastic Recycling, IRS Told

    Advanced plastic recycling should be eligible for a new tax perk allowing full expensing of a qualified production property's costs, a chemical trade association said in a letter, released Wednesday, recommending the industry-specific change for the IRS' upcoming proposed regulations.

  • May 05, 2026

    Tax Shelter Trial Defendants Claim Promoter Misled Them

    More than a dozen lawyers and defendants packed a Colorado federal courtroom Tuesday to mark the first day of testimony in the trial against four individuals accused of using their businesses to help promote and sell abusive trust tax shelters.

  • May 05, 2026

    IRS Modifies Significant Issue Ruling Program

    The IRS outlined the process for taxpayers to request rulings on one or more issues that are solely under the agency's corporate associate chief counsel's jurisdiction that involve certain tax consequences and transactions, according to guidance released Tuesday.

  • May 05, 2026

    Tax Court Revives Ga. Collections Case Over Notice Flaws

    The U.S. Tax Court remanded a Georgia man's collections due process dispute Tuesday, saying that while he "certainly did not facilitate the consideration of his case" with the IRS Office of Appeals, the office improperly failed to consider whether he timely received notices.

  • May 05, 2026

    Ending Carried Interest Tax Break May Net $88B, Report Says

    Ending the carried interest tax break could raise far more than previously estimated, nearly $88 billion in a decade, based on a new methodology put forward in a report by the Yale Budget Lab.

  • May 05, 2026

    IRS Beats Suit Claiming Secret Rule Targeted Stock Plan

    A transportation company cannot pursue its claims that the IRS adopted a secret rule that targeted its stock ownership plan, a Wisconsin federal judge ruled, throwing out the company's suit.

  • May 05, 2026

    Limited Partners Reject Self-Employment Tax In 1st Circ.

    An energy investment company told the First Circuit that its self-employment tax dispute is distinct from that of the taxpayer in a 2009 Federal Circuit ruling that barred refunds to a partnership's individual partners, saying the cases involve different subsections of U.S. income tax law.

  • May 05, 2026

    Wis. Village Urges 7th Circ. To Void Oneida Tribal Trust Order

    A Wisconsin village is asking the Seventh Circuit to undo a U.S. Department of the Interior decision to place 500 acres of properties into trust for the Oneida Nation, arguing that a district court ignored evidence of bias and shielded the transactional record from meaningful scrutiny.

  • May 05, 2026

    US Ends $15M Tax Refund Fight With Gas Biz Partners

    The U.S. government agreed to end litigation alleging that several Texas residents had erroneously claimed a total of about $15 million in tax refunds tied to a partnership involving gas and oil operations in Equatorial Guinea.

  • May 05, 2026

    IRS To Implement Digital Signatures In Penalty Approvals

    The Internal Revenue Service agreed to require supervisors to use digital signatures to approve tax penalties as a way to prevent improper backdating and other edits to the approval documents, the agency watchdog said in a report released Tuesday.

  • May 04, 2026

    Biz Hit With Extra Penalties For Captive Insurance Deductions

    A Florida business must pay additional penalties for deductions taken for microcaptive insurance expenses, the U.S. Tax Court said Monday, backing the IRS' imposition of 40% penalties for tax years 2012 through 2015.

  • May 04, 2026

    Ex-IRS Agent Accused Of Stealing $12M From Fuel Co.

    A former Internal Revenue Service agent was arrested for allegations that he embezzled more than $12 million in his role as a chief financial officer of a New Jersey fuel company, the New Jersey U.S. Attorney's Office said.

  • May 04, 2026

    Ga. Partnership Defends $46M Deduction For Land Donation

    A Georgia partnership defended its claimed deduction of $46 million for 235 acres donated to a land conservation group, saying the IRS wrongly disallowed the amount and determined it underpaid its 2021 taxes by $17 million.

  • May 04, 2026

    Tax Court Slashes $30M Deductions For Georgia Easements

    The U.S. Tax Court slashed two partnerships' charitable tax deductions worth a combined $30 million for a pair of conservation easement donations, ruling Monday that the easements' outsize valuation was an attempt to make "too many fast nickels."

  • May 04, 2026

    Managers Of Embattled Easement Say RICO Suit Lacks Details

    Investment fund managers behind a conservation easement donation whose charitable tax deduction was embroiled in litigation asked a Georgia federal court to toss a racketeering suit against them by a pair of investors, arguing the fraud claims do not match the allegations.

  • May 04, 2026

    IRS Issues Employer Payment Index For Coverage Penalties

    The IRS provided indexing adjustments Monday for calculating penalties against large employers that don't offer health insurance to their full-time workers or whose full-time workers opt to enroll in government-subsidized health coverage using premium tax credits.

  • May 04, 2026

    IRS Approves Co.'s Retroactive Transfer Pricing Changes

    The IRS Office of Chief Counsel has endorsed a company's proposal to reduce certain transfer pricing adjustments through a setoff after retroactively changing how it allocated costs between related companies, according to a memorandum.

  • May 04, 2026

    Partnership Defends $3M Deduction For Yacht Purchase

    A partnership said the IRS wrongly disallowed expenses associated with its boat chartering and fishing tournament activities, including the purchase of a $3 million yacht, during 2020 and 2021, when the COVID-19 pandemic severely disrupted its business.

  • May 01, 2026

    Biz Group Slams IRS' 'Implicit Support' Argument In Eaton

    An international business group urged the U.S. Tax Court to reject IRS arguments that Eaton Corp. deserved a higher credit rating due to its foreign parent's "implicit support," saying the case could significantly affect its members' U.S. tax liabilities.

  • May 01, 2026

    Int'l Tax In April: Progress On Tariff Refunds, New Tax Cuts

    U.S. Customs and Border Protection continued to make progress in April on its system for paying back the tariffs that President Donald Trump imposed under the International Emergency Economic Powers Act. Meanwhile, several countries and one U.S. state cut fuel taxes in response to the U.S. and Israel's war with Iran. Here, Law360 looks at those and other international tax developments from the past month.

  • May 01, 2026

    Tax Shelter Defendant Says Discovery Errors Allow Dismissal

    A man charged with promoting abusive and illegal tax shelters for decades asked a Colorado federal judge just days before trial to throw out the indictment against him, contending the government withheld material exculpatory evidence for more than a year.

  • May 01, 2026

    Kostelanetz Adds Ex-IRS Criminal Investigation Chief In NY

    Kostelanetz LLP has hired a former chief of the U.S. Internal Revenue Service's law enforcement branch who spent more than 30 years there investigating tax and financial crime, domestically and abroad, the firm announced Friday.

  • May 01, 2026

    Texas Plastics Co. Seeks To Nix Full Captive Rules In 5th Circ.

    A plastics company is appealing a Texas district court's decision to partially vacate IRS regulations that listed captive insurance as potentially abusive tax avoidance schemes and will ask the Fifth Circuit to strike down the entire set of regulations, according to a notice.

  • May 01, 2026

    IRS Failed To Vet GILTI Regs For Small Biz, Court Told

    The Internal Revenue Service failed to assess how final regulations implementing the 2017 tax law's global intangible low-taxed income regime would affect small businesses, an Israeli law firm told the D.C. federal court Friday, arguing the rules violate administrative law.

Expert Analysis

  • 5 Tips For Navigating Your Firm's All-Attorney Summit

    Excerpt from Practical Guidance
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    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.

  • How Bankrupt Cos. Can Seek Refunds For Illegal Tariffs

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    In light of the U.S. Supreme Court's recent decision striking down President Donald Trump's International Emergency Economic Powers Act tariffs as illegal, some companies may have strong prospects for recovering refunds from the government, and trustees in bankruptcy may have a significant role to play in seeking such recovery, say attorneys at Stinson.

  • Legal And Industry Impacts Of America's Maritime Action Plan

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    America's Maritime Action Plan, unveiled by the White House last month, introduces changes to trade investigations, a new maritime trust fund and more — adding regulatory and compliance obligations for companies and counsel, but also new avenues for client engagement in project finance, contract negotiation and dispute resolution, say attorneys at Holland & Knight.

  • 4 Ways To Help CBP Curb Shell Co. Import Schemes

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    Shifting to a proactive rather than reactive enforcement posture in addressing shell companies set up to skirt tariffs requires equipping U.S. Customs and Border Protection with enhanced investigative authorities, better intelligence support, and mechanisms to identify and hold accountable the ultimate illicit actors, say attorneys at Kelley Drye.

  • 7 Steps For Gov't Contractors In Post-IEEPA Tariff Landscape

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    In response to U.S. Supreme Court's recent decision to strike down tariffs issued by the Trump administration under the International Emergency Economic Powers Act, there are several actions federal contractors should take to preserve their place in any refund waterfall, and to manage audit, overpayment and False Claims Act risk, say attorneys at Holland & Knight.

  • The Benefits Of Choosing A Niche Practice In The AI Age

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    As artificial intelligence becomes increasingly accessible, lawyers with a niche practice may stand out as clients seek specialized judgment that automation cannot replicate, but it is important to choose a niche that is durable, engaging and a good personal fit, says Daniel Borneman at Lowenstein Sandler.

  • Section 122 Tariffs Show Shift In Strategy, Not Trade Policy

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    By imposing temporary tariffs under Section 122 of the Trade Act as a stopgap measure while it pivots to less transitory statutory authorities, the Trump administration sent a clear message that the U.S. Supreme Court’s decision in Learning Resources v. Trump, invalidating duties imposed under the International Emergency Economic Powers Act, will not precipitate a change in policy direction, say attorneys at Snell & Wilmer.

  • Tax Court Ruling Signals Cross-Border Loan Scrutiny

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    The U.S. Tax Court’s recent decision in Aventis v. Commissioner compounds ongoing regulatory focus on debt originations and should prompt practitioners to assess their existing cross-border lending structures for potential exposure to U.S. federal income tax, say attorneys at Eversheds.

  • Lessons From Justices' Split On Major Questions Doctrine

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    The justices' varied opinions in Learning Resources v. Trump, which held the International Emergency Economy Powers Act did not confer the power to impose tariffs, offer a meaningful window into the U.S. Supreme Court's perspective on the major questions doctrine that will likely shape lower courts' approach to executive action challenges, say attorneys at Venable.

  • Resilience Planning As Nat'l Security Shifts Tech Import Policy

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    In response to a sustained reorientation of U.S. trade policy around national security considerations, businesses reliant on processed critical minerals must closely monitor diplomatic negotiations and the potential expansion of trade measures, incorporating contingency planning into procurement and long-term investment strategies, says attorney Sohan Dasgupta.

  • How The New Tariff Landscape May Unfold

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    To replace tariffs formerly imposed under the International Emergency Economic Powers Act, the administration will rely on a patchwork of statutes, potentially leading to procedural challenges and a complex tariff landscape with varying levels, durations and applicability, says Joseph Grossman-Trawick at King & Spalding.

  • What Orgs. Should Note In IRS Group Tax Exemption Overhaul

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    In a significant update, the IRS Revenue Procedure 2026-8 shows that the group exemption program is moving into a new regulatory era involving more uniformity, oversight and compliance obligations, and early action is key to preserve group exemption status and avoid disruption for subordinate organizations, says Ravi Sundara at Spencer Fane.

  • How Banks Can Apply FinCEN Beneficial Ownership Relief

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    A recent Financial Crimes Enforcement Unit order limiting the circumstances under which banks should identify and verify beneficial owners may allow banks to tailor their approach to verification compliance, but only after reviewing customer due diligence policies and evaluating alignment with their risk profiles, say attorneys at Cleary.

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