Federal

  • November 02, 2026

    Xbox Buyer's Microsoft Tariff Refund Suit Sent To Arbitration

    A Washington federal judge said Monday that an Xbox buyer must arbitrate his claims that Microsoft unjustly pocketed refunds meant for consumers after the U.S. Supreme Court struck down the Trump administration's global tariff regime, citing an arbitration pact described by the console's packaging and included documents.

  • November 02, 2026

    Eaton Atty Says Island Plants' Activities Critical To Success

    The skilled manufacturing that took place at Eaton's plants in Puerto Rico and the Dominican Republic from 2011 through 2013 was the critical factor in the success of the company's electrical breaker products business, an attorney for Eaton Corp. told the U.S. Tax Court on Monday.

  • November 02, 2026

    Buy.com Founder On Hook For $16M Tax Bill, 10th Circ. Says

    The founder of Buy.com waited too long to challenge a nearly $16 million tax bill tied to his former partnership's investments, the Tenth Circuit ruled Monday, holding that the window had closed by the time the IRS assessed partner-level liabilities.

  • November 02, 2026

    Tax Court Denies IRS Bid To Revisit Easement Case Ruling

    The U.S. Tax Court said Monday it won't reconsider a September opinion finding a partnership's petition was filed late because of circumstances beyond its control, saying the court has already addressed the IRS' arguments that it improperly excused the lateness of the conservation easement suit.

  • November 02, 2026

    IRS Donor Reporting Rule Violates 1st Amendment, Court Told

    The IRS' nonprofit donor disclosure rule violates organizations' and donors' First Amendment rights, a privacy group told a D.C. federal court, saying the rule is subject to a heightened level of judicial scrutiny that the government cannot overcome.

  • November 02, 2026

    MVP: Gibson Dunn's Michael Cannon

    Michael Cannon, a partner in Gibson Dunn & Crutcher LLP's Dallas office, co-led the tax team advising SpaceX on its pivotal transactions that wrapped up this year, including the largest initial public offering and M&A of all time, earning him a spot as one of the 2026 Law360 Tax MVPs.

  • November 02, 2026

    Full 5th Circ. Won't Review Limited Partner Tax Ruling

    The Fifth Circuit denied a Texas business consulting company's request for the full court to review a panel's revised opinion narrowing a tax break for limited partners, saying no judges sought a rehearing.

  • November 02, 2026

    Tax Policy To Watch After The Midterm Elections

    When lawmakers return to Washington, D.C., after the midterm elections, proposals to overhaul the Internal Revenue Service's administration could be ripe for inclusion in a year-end package if the goal is to clear the decks before the next legislative session, according to tax policy observers. Here, Law360 takes a look.

  • October 30, 2026

    Law360 MVP Awards Go To Top Attorneys From 89 Firms

    The lawyers chosen as Law360's 2026 MVPs stand out from their peers by notching significant achievements in high-stakes litigation, complex global matters and record-setting transactions.

  • October 30, 2026

    Key Witness May Be Out In MLB Prop Betting Trial

    A Brooklyn federal judge Friday heard that prosecutors may not call a key witness at the center of a fight over exculpatory evidence disclosure to testify against two Cleveland Guardians players accused of a pitch-fixing conspiracy to profit from rigged proposition bets, and refused a government bid to use a purported $500,000 tax debt against one of the pitchers.

  • October 30, 2026

    Jury Rules Tax Software Co. Didn't Illegally Poach Workers

    Tax software company Avalara did not illegally lure six workers away from a company acquired by rival Vertex, a Pennsylvania federal jury decided, clearing Avalara of trade secrets theft.

  • October 30, 2026

    Hedge Fund Exec Fights $40M In IRS Foreign Reporting Fines

    A hedge fund manager is seeking to recover nearly $40 million in foreign account reporting penalties, telling the U.S. Court of Federal Claims that the IRS violated his due process rights and administrative rules in imposing fines linked to his bankrupt Texas tycoon father's international accounts.

  • October 30, 2026

    Racing Mogul's Estate Asks Tax Court To Ax $58M Tax Bill

    An automobile racing mogul's estate asked the Tax Court to spike a $58.3 million estate tax deficiency, alleging that the IRS erred in revaluing its equity holdings.

  • October 30, 2026

    Brookfield Fights $4.3M Tax Bill Over Lehman Losses

    Asset management giant Brookfield is challenging a $4.3 million tax bill tied to its acquisition of a defunct Lehman Brothers unit, telling the U.S. Tax Court that the IRS incorrectly denied a deduction stemming from the Lehman affiliate's losses.

  • October 30, 2026

    Int'l Tax In October: UK Targets Banks, US Nixes Spinoff Rule

    The U.K. government issued its first budget under a new prime minister in October and is looking to the banking industry to boost revenue, while in the U.S., a dispute over a Minnesota medical device company's pricing with a Puerto Rican affiliate could require a third Tax Court trial after settlement talks failed. Here, Law360 looks at the top international tax developments from the past month.

  • October 30, 2026

    Buchalter Adds Tax Pro In Dallas From Jackson Walker

    Buchalter PC's rapid growth in Texas continues with the addition of a Dallas-based tax partner who came aboard from Jackson Walker LLP.

  • October 30, 2026

    3 Ways Burgeoning AI Use Can Trip Up Benefits Providers

    As the use of artificial intelligence in the employee benefits space grows, experts warn that companies need to be vigilant to guard against mishaps caused by the emerging technology. Here, Law360 looks at three areas where benefits attorneys say AI can cause legal headaches.

  • October 30, 2026

    Taxation With Representation: Kirkland, Gibson Dunn, Cravath

    In this week's Taxation with Representation, Blackstone, Bank of America, Citi and Morgan Stanley announce a financing structure to buy Broadcom artificial intelligence chips and network components for Anthropic, EQT acquires Range Resources to create a powerhouse natural gas company, and DoorDash buys Instacart.

  • October 30, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, contained final rules laying out the process for arbitrating out-of-network medical bills under the No Surprises Act.

  • October 29, 2026

    Union Sues IRS Over Termination Of Workers' Contract

    The Internal Revenue Service violated federal law by terminating its collective bargaining agreement with a union representing the agency's employees in light of a 2025 executive order from President Donald Trump, the union has claimed in a lawsuit filed in Massachusetts federal court.

  • October 29, 2026

    Treasury Asked To Narrow Crackdown On Fund Strategies

    The U.S. Treasury Department should develop targeted rules distinguishing abusive transactions from long-standing investment management practices in new enforcement that scrutinizes novel strategies exploiting the tax benefits of certain investment vehicles and financial products, firms and organizations told the department.

  • October 29, 2026

    German Co. Says $1.2M IRS Tax Bill Rests On Invalid Rule

    A German manufacturer challenging a $1.2 million tax bill stemming from late information filings with the IRS told the U.S. Tax Court it should be able to claim deductions and credits despite missing the statutory due date, saying the agency applied a rule that is procedurally invalid under federal law.

  • October 29, 2026

    Club's Oil Profits Negated Tax-Exempt Status, Tax Court Finds

    A Pennsylvania sports club deserved to have its nonprofit status revoked because the royalties it received from its leasing arrangement with an oil drilling company from 2017-2023 made up more than half its annual income, the U.S. Tax Court held Thursday.

  • October 29, 2026

    Tax Court Backs IRS In Whistleblower Award Denial

    The Internal Revenue Service's Whistleblower Office did not abuse its discretion when it determined that a man who tried to request an award for whistleblowing on tax abuse undertaken by Target was not entitled to it, the U.S. Tax Court said in an opinion released Thursday.

  • October 29, 2026

    US Expatriations In Q3 Down 16% From Last Year, IRS Says

    The number of people who lost or renounced their U.S. citizenship totaled more than 1,300 in the third quarter of 2026 as logged by the U.S. Department of the Treasury, down about 16% year over year and 25% from the previous quarter, the IRS said Thursday.

Expert Analysis

  • FinCEN Exemption Raises Statutory, Administrative Questions

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    The Financial Crimes Enforcement Network's recently rolled-out broad exemption for U.S. companies from Corporate Transparency Act reporting may face administrative law and statutory challenges, so businesses should still preserve ownership records and monitor litigation and congressional action, says David McCarville at Fennemore.

  • IRS Automatic Penalty Relief Needs More Transparency

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    The IRS’ transition from manual first-time abate waivers to automatic penalty relief directly addresses genuine inequities, but its algorithmic framework creates an opaque black box that strips taxpayers of procedural visibility and complicates due process, says Colette Karam at Spencer West.

  • AI Meeting Recaps Pose New Discovery And Privilege Risks

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    The New York City Bar Association’s recent ethics opinion, cautioning attorneys not to record nonclient conversations with artificial intelligence tools, reflects an emerging view that AI meeting recaps are now a distinct business record category, meaning counsel should set meeting-level controls and apply framework-level updates, says William Wright at Faegre Drinker.

  • Playing Bid Whist Makes Me A Better Lawyer

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    As a child, I viewed bid whist as a family tradition and a source of friendly card game competition, but as a lawyer, I see it as a tool that has helped me cultivate skills like communication, teamwork, risk assessment and composure, says Keyonn Pope at Riley Safer.

  • Md. Digital Tax Ruling Is A Road Map For Future Challenges

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    Three Maryland Tax Court rulings that recently struck down the state's digital advertising tax suggest constitutional and statutory vulnerabilities that could be used to challenge newly enacted digital services laws or legislation being considered by other states, say attorneys at Holland & Knight.

  • Calif. Bill Goes Too Far In Trying To Regulate Attorney AI Use

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    California’s first-in-the-nation act regulating how attorneys and arbitrators use generative artificial intelligence will likely soon become law, but read broadly, the provisions may dissuade lawyers from employing AI at all, thereby depriving them of key work tools, says Joshua Wurtzel at Schlam Stone.

  • IRS Notice Helps Bridge Carbon Capture Reporting Gap

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    Recent guidance that extends a safe harbor for taxpayers claiming Section 45Q carbon capture credits provides a temporary reporting method that may keep viable projects moving while the U.S. Department of the Treasury and the Environmental Protection Agency address future reporting standards, says Peter Lowy at Nelson Mullins.

  • Attorneys Using AI May Have Ethical Duty To Redact Docs

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    The trajectory of legal ethics guidance in recent years strongly suggests that as redaction technology becomes more accessible, the failure to use it when uploading highly confidential materials into artificial intelligence tools will become increasingly difficult to defend as reasonable, say attorneys at Lewis Brisbois.

  • Md. Court Got Ad Tax Similarity Analysis Wrong

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    Decisions striking Maryland’s digital advertising tax are fundamentally flawed because the Maryland Tax Court found similarity between digital ads and other ads without considering deep market distinctions, says Darien Shanske at UC Davis School of Law.

  • Planning For The Impact Of FinCEN's CTA Rollback

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    The Financial Crimes Enforcement Network's recent rollback of Corporate Transparency Act reporting obligations should reduce compliance costs, but its plans to revisit customer due diligence rules should prompt companies and financial institutions to reassess state beneficial ownership programs, say attorneys at Sidley.

  • What DOJ Fraud Division Rule Resolves, And What It Doesn't

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    The U.S. Department of Justice’s recently published final rule answers many outstanding questions about the newly created National Fraud Enforcement Division, but overlapping mandates could result in parallel investigations and diverging viewpoints between multiple sets of prosecutors, say attorneys at Gibson Dunn.

  • ERC Filing Deadlines Raise Tax Adviser Liability Risk

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    To minimize their risk, employee retention credit providers and tax advisers should understand that agreements to extend clients’ two-year deadline for challenging disallowances are not effective until the IRS countersigns, and implement an action plan to track filing deadlines and consider other proactive steps, says Michael Williams at CFOMW.

  • Taekwondo Makes Me A Better Lawyer

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    Taekwondo has taught me to recognize when to fight for a position and when to focus on finding a solution, and that the best outcomes are often achieved by solving problems — all of which has improved my work as a bankruptcy lawyer, mediator and Subchapter V trustee, says Amy Denton Mayer at Berger Singerman.

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