Federal
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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.
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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.
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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.
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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.
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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.
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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.
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January 06, 2026
Tax Groups Push Supreme Court On California Tax Rule
A special income tax rule California uses along with its single-sales-factor apportionment method creates distortion and the U.S. Supreme Court should decide if it also violates the constitution, a taxpayer group said Tuesday.
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January 06, 2026
Tax Court Tosses $189K Charity Deduction For Lack of Proof
A California couple is not entitled to deduct nearly $189,000 for thousands of items they donated to a charity, the U.S. Tax Court ruled Tuesday, finding they failed to provide sufficient documentation to substantiate the value of the donated goods.
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January 06, 2026
Tax Court Strips Exempt Status From Powdered Milk Donor
An organization that sent powdered milk donations for children overseas was mostly running a commercial coffee shop and was therefore not entitled to tax-exempt status, the U.S. Tax Court said Tuesday, agreeing with the Internal Revenue Service.
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January 06, 2026
IRS Appeals Pause Of ICE Info-Sharing Agreement
The Internal Revenue Service is appealing to the D.C. Circuit a federal court order temporarily stopping the agency from sharing confidential taxpayer addresses with immigration enforcement officials, according to a filing Tuesday in D.C. federal court.
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January 06, 2026
Tax Firm Says IRS Can't Justify Microcaptive Reporting Rules
A global tax services provider urged a Texas federal court to vacate tax reporting rules for microcaptive insurance companies, arguing that the Internal Revenue Service failed to provide evidence of tax evasion that would justify the regulations.
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January 06, 2026
Paul Hastings Adds Ex-Cravath Tax Pro To Growing M&A Team
After adding 20 partners to its mergers and acquisitions platform over the past two years, Paul Hastings LLP announced on Tuesday that it has hired a former Cravath Swaine & Moore LLP partner who advises on the tax elements of mergers and acquisitions.
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January 05, 2026
Feds Fight To Keep Goldstein 'Sham Employee' Evidence
Federal prosecutors heading to trial against former SCOTUSblog publisher Tom Goldstein are urging a judge to deny his bid to prevent a jury from hearing about four love interests allegedly paid as no-show employees at his former law firm.
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January 05, 2026
'Truly Extreme': 9th Circ. Judges Decry Trump Layoffs Ruling
The Ninth Circuit on Monday refused to revisit a three-judge panel's decision rejecting the Trump administration's challenge of a lower court's ruling requiring production of its plans for large-scale layoffs and reorganizations at various federal agencies, a decision that was met with fiery dissent from several of the court's Republican-appointed judges.
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January 05, 2026
3rd Circ. Won't Rethink Tax On Interest In $191M Pharma Deal
The Third Circuit declined to reconsider its decision that a pharmaceutical company's $191 million payment settling a family feud was for the sale of a family trust's ownership shares and included interest that should be taxed as ordinary income.
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January 05, 2026
Partnership Fights Axed $60M Tax Break For Conservation Gift
A partnership challenged the IRS' denial of its nearly $60 million tax deduction for protecting forestland and other open space in Georgia, telling the U.S. Tax Court the land could have been used for valuable granite mining before the partnership stopped it from being developed.
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January 05, 2026
Gibson Dunn Adds Sidley Tax Pro In Silicon Valley
Gibson Dunn & Crutcher LLP announced Monday that it has bulked up its tax practice group with a partner in Palo Alto, California, who previously co-led the global tax practice and headed up the West Coast tax group at Sidley Austin LLP.
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January 05, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, dated Monday, included guidance for new tax relief for farmers who pay capital gains tax on a farmland property sale to another farmer.
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January 02, 2026
Ga. Partnership Contests Denial Of $15.7M Property Donation
A Georgia partnership invoked the Fifth Amendment in defending its $15.7 million conservation easement tax deduction in the U.S. Tax Court, arguing that the IRS in denying the deduction effectively is taking private property for public use without just compensation.
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January 02, 2026
Busy DOJ Tax Atty Seeks More Time In 7th Circ. AbbVie Case
A U.S. Department of Justice tax attorney asked the Seventh Circuit on Friday for another extension to file an opening brief in a dispute over AbbVie's $1.6 billion payment to an Irish biotechnology company, citing staffing shortages and internal procedural requirements.
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January 02, 2026
IRS Floats 50% Personal-Use Test For Car-Loan Tax Break
Individuals, trusts and estates could claim up to $10,000 for the new auto-loan interest deduction only if the vehicle was used more than 50% of the time for personal purposes under proposed regulations published Friday by the IRS.
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January 02, 2026
IRS Floats Updates To Fee Paid By Brand Drugmakers
The Internal Revenue Service floated updates to regulations governing how branded prescription drug manufacturers or importers should calculate an annual fee established by the Affordable Care Act, a move the agency said aims to incorporate changes in drug discount programs and clarify tax reporting.
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January 02, 2026
Guns, Taxes & Labor: Cannabis Litigation Trends To Watch
In 2026, courts throughout the U.S. will consider cases weighing Second Amendment rights of cannabis users, a punitive federal tax policy that affects state-legal marijuana businesses, labor peace requirements in the cannabis space, and whether a constitutional doctrine bars states from preferencing their residents in doling out marijuana licenses.
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January 02, 2026
Federal Tax Policy To Watch In 2026
Changes to federal tax policy are relatively uncommon in midterm election years as lawmakers, many of whom prioritize political positioning over major tax overhauls, show little appetite for sweeping legislation or even narrower fixes that could attract bipartisan support. Here, Law360 examines federal tax policy to watch in 2026.
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January 02, 2026
Top International Tax Cases To Watch In 2026
Major multinational corporations such as McKesson and Coca-Cola will continue to litigate high-stakes international tax cases in 2026, including transfer pricing disputes with billions of dollars on the line and fights over whether regulations exceed the government's authority. Here, Law360 looks at four key international tax cases to follow in the new year.
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.
Countries Reach Deal To Exempt US From Pillar 2 Tax
Nearly 150 countries finalized the details Monday of a safe harbor that would effectively exempt U.S. companies from a 15% global minimum tax known as Pillar Two, following months of international negotiations and retaliatory tax threats from the U.S.
Top Federal Tax Cases To Watch In 2026
The application of self-employment taxes to limited partners, the economic substance doctrine's threshold and the question of whether IRS penalties need a jury's deliberation are topics federal courts likely will examine in coming decisions. Here, Law360 reviews the top federal tax cases to watch in the coming year.
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.
Countries Reach Deal To Exempt US From Pillar 2 Tax
Nearly 150 countries finalized the details Monday of a safe harbor that would effectively exempt U.S. companies from a 15% global minimum tax known as Pillar Two, following months of international negotiations and retaliatory tax threats from the U.S.
Top Federal Tax Cases To Watch In 2026
The application of self-employment taxes to limited partners, the economic substance doctrine's threshold and the question of whether IRS penalties need a jury's deliberation are topics federal courts likely will examine in coming decisions. Here, Law360 reviews the top federal tax cases to watch in the coming year.
Featured Stories
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Guns, Taxes & Labor: Cannabis Litigation Trends To Watch
In 2026, courts throughout the U.S. will consider cases weighing Second Amendment rights of cannabis users, a punitive federal tax policy that affects state-legal marijuana businesses, labor peace requirements in the cannabis space, and whether a constitutional doctrine bars states from preferencing their residents in doling out marijuana licenses.
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Federal Tax Policy To Watch In 2026
Changes to federal tax policy are relatively uncommon in midterm election years as lawmakers, many of whom prioritize political positioning over major tax overhauls, show little appetite for sweeping legislation or even narrower fixes that could attract bipartisan support. Here, Law360 examines federal tax policy to watch in 2026.
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Top Federal Tax Cases To Watch In 2026
The application of self-employment taxes to limited partners, the economic substance doctrine's threshold and the question of whether IRS penalties need a jury's deliberation are topics federal courts likely will examine in coming decisions. Here, Law360 reviews the top federal tax cases to watch in the coming year.
Expert Analysis
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How Changes At The IRS Will Affect Tax Controversy In 2026
Taxpayers will need to adjust approaches to dealing with the IRS in 2026, as the agency is likely to shift its audit strategies and increases reliance on technology following the significant reductions in funding and personnel last year, say attorneys at Crowell & Moring.
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5 Tariff And Trade Developments To Watch In 2026
A new trade landscape emerged in 2025, the contours of which will be further defined by developments that will merit close attention this year, including a key ruling from the U.S. Supreme Court and a review of the U.S.-Mexico-Canada Agreement, says Ted Posner at Baker Botts.
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4 Developments That Defined The 2025 Ethics Landscape
The legal profession spent 2025 at the edge of its ethical comfort zone as courts, firms and regulators confronted how fast-moving technologies and new business models collide with long-standing professional duties, signaling that the profession is entering a period of sustained disruption that will continue into 2026, says Hilary Gerzhoy at HWG Law.
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How Fractional GCs Can Manage Risks Of Engagement
As more organizations eliminate their in-house legal departments in favor of outsourcing legal work, fractional general counsel roles offer practitioners an engaging and flexible way to practice at a high level, but they can also present legal, ethical and operational risks that must be proactively managed, say attorneys at Boies Schiller.
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How OECD Tax Update Tackles Mobile Workforce Complexity
The Organization for Economic Cooperation and Development’s recently updated model tax convention — a recalibration of international tax principles in response to an increasingly mobile workforce — should prompt companies to reevaluate cross-border operations, transfer pricing policies and tax controversy strategies, say attorneys at Eversheds.
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A Uniform Federal Rule Would Curb Gen AI Missteps In Court
To address the patchwork of courts’ standing orders on generative artificial intelligence, curbing abuses and relieving the burden on judges, the federal judiciary should consider amending its civil procedure rules to require litigants to certify they’ve reviewed legal filings for accuracy, say attorneys at Shook Hardy.
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Nonprofits Face Uncertainty Over Political Activity Rules
Two federal court decisions suggesting that the Internal Revenue Service's rules for 501(c)(4) organizations' political activity may be too vague to survive constitutional scrutiny leave nonprofit organizations caught between constitutional limits on government regulation of speech and tax limits on their exempt status, say attorneys at BakerHostetler.
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Supreme Court Term Limits Would Carry Hidden Risk
While proposals for limiting the terms of U.S. Supreme Court justices are popular, a steady stream of relatively young, highly marketable ex-justices with unique knowledge and influence entering the marketplace of law and politics could create new problems, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.
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Tariffs And Trade Volatility Drove 2025 Bankruptcy Wave
The Trump administration's tariff regime has reshaped the commercial restructuring landscape this year, with an increased number of bankruptcy filings showing how tariffs are influencing first‑day narratives, debtor-in-possession terms and case strategies, say attorneys at Thompson Hine.
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AI Evidence Rule Tweaks Encourage Judicial Guardrails
Recent additions to a committee note on proposed Rule of Evidence 707 — governing evidence generated by artificial intelligence — seek to mitigate potential dangers that may arise once machine outputs are introduced at trial, encouraging judges to perform critical gatekeeping functions, say attorneys at Lankler Siffert & Wohl.
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The Law Firm Merger Diaries: Getting The Message Across
Communications and brand strategy during a law firm merger represent a crucial thread that runs through every stage of a combination and should include clear messaging, leverage modern marketing tools and embrace the chance to evolve, says Ashley Horne at Womble Bond.
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Horizontal Stare Decisis Should Not Be Casually Discarded
Eliminating the so-called law of the circuit doctrine — as recently proposed by a Fifth Circuit judge, echoing Justice Neil Gorsuch’s concurrence in Loper Bright — would undermine public confidence in the judiciary’s independence and create costly uncertainty for litigants, says Lawrence Bluestone at Genova Burns.
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10 Commandments For Agentic AI Tools In The Legal Industry
Though agentic artificial intelligence has demonstrated significant promise for optimizing legal work, it presents numerous risks, so specific ethical obligations should be built into the knowledge base of every agentic AI tool used in the legal industry, says Steven Cordero at Akerman LLP.