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

  • Preserving Refunds As Tariffs Await Supreme Court Weigh-In

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    In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.

  • Revamped Opportunity Zones Can Aid Clean Energy Projects

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    The Qualified Opportunity Zone program, introduced in 2017 and reshaped in the One Big Beautiful Bill Act, offers investors federal tax incentives for development in low-income communities — incentives that are especially meaningful for clean energy projects, where capital-intensive infrastructure and long-term planning are essential, say attorneys at Dentons.

  • Writing Musicals Makes Me A Better Lawyer

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    My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.

  • How Fashion, Tech Can Maximize New Small Biz Tax Breaks

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    Fashion and technology companies, which invest heavily in innovation, should consider taking advantage of provisions in the One Big Beautiful Bill Act that favor small businesses, restructuing if necessary to become eligible for expanded research and experimental expenditure credits and qualified small business stock incentives, says Aime Salazar at Olshan Frome.

  • Adapting To Private Practice: From Va. AUSA To Mid-Law

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    Returning to the firm where I began my career after seven years as an assistant U.S. attorney in Virginia has been complex, nuanced and rewarding, and I’ve learned that the pursuit of justice remains the constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.

  • 7 Document Review Concepts New Attorneys Need To Know

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    For new associates joining firms this fall, stepping into the world of e-discovery can feel like learning a new language, but understanding a handful of fundamentals — from coding layouts to metadata — can help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.

  • Agentic AI Puts A New Twist On Attorney Ethics Obligations

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    As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.

  • Opportunity Zone's Future Corp. Tax Benefits Still Uncertain

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    Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.

  • How GILTI Reform Affects M&A Golden Parachute Planning

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    Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.

  • What To Expect As Trump's 401(k) Order Materializes

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    Following the Trump administration’s recent executive order on 401(k) plan investments in alternative assets like cryptocurrencies and real estate, the U.S. Department of Labor and the U.S. Securities and Exchange Commission will need to answer several outstanding questions before any regulatory changes are implemented, say attorneys at Cleary.

  • Demystifying The Civil Procedure Rules Amendment Process

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    Every year, an advisory committee receives dozens of proposals to amend the Federal Rules of Civil Procedure, most of which are never adopted — but a few pointers can help maximize the likelihood that an amendment will be adopted, says Josh Gardner at DLA Piper.

  • Parenting Skills That Can Help Lawyers Thrive Professionally

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    As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.

  • Unpacking The New Opportunity Zone Tax Incentive Program

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    The One Big Beautiful Bill Act brought several improvements to the opportunity zone tax incentive program that should boost investments in qualified funds, including making it permanent, increasing federal income tax benefits in rural areas, redesignating the qualified zones, and requiring more in-depth reporting, says Marc Schultz at Snell & Wilmer.

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