Federal
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September 22, 2026
US Asks 5th Circ. To Revive IRS Deal On Church Politicking
The U.S. government urged the Fifth Circuit to revive its deal with four religious groups to allow churches to engage in some political speech without losing their tax-exempt status, saying a lower court improperly dismissed the case in its entirety for lack of jurisdiction.
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September 22, 2026
Tax Court OKs $21M Easement Cut In Appeal Process Fight
The IRS did not wrongfully deny a holding company the chance to appeal a reevaluation that lopped $21 million off the value of a Tennessee conservation easement for which it claimed a deduction, the U.S. Tax Court ruled Tuesday.
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September 22, 2026
Dispensary's Tax Deduction Properly Nixed, IRS Tells 9th Circ.
The U.S. Tax Court correctly ruled that a San Francisco marijuana dispensary's expenses found to be tied to trafficking in controlled substances aren't deductible, the IRS told the Ninth Circuit, saying such a deduction shouldn't be allowed in determining an amount to settle the business's $3 million tax debt.
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September 22, 2026
Virgin Islands Tax Agency Can't Ignore Treasury, Judge Says
The U.S. Supreme Court's 2024 Loper Bright decision does not allow U.S. Virgin Islands revenue collectors to override U.S. Treasury Department regulations exempting residents of the territory from the net investment income tax, a federal judge held.
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September 21, 2026
Xbox Buyer Says IEEPA Refund Arbitration Bid Lacks Backing
Microsoft's bid to force arbitration of an Xbox purchaser's proposed class action accusing the video game giant of wrongfully withholding tariff refunds from consumers should fail because it can't point to a clause that covers his dispute, he told a Washington federal court.
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September 21, 2026
IRS Properly Nixed Tax Deals, Couple Owe $1.8M, Judge Says
A disbarred lawyer and his wife owe more than $1.8 million in outstanding tax liabilities the IRS has tried to collect for more than a decade, a Wisconsin federal judge said, finding the agency substantiated the liabilities and confirmed that it properly rescinded compromise offers to resolve the debts.
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September 21, 2026
Partnership Was Diligent After Notice Got Lost, Court Says
A partnership's late-filed petition in the U.S. Tax Court was due to circumstances beyond its control in a case where the final partnership adjustment from the IRS was mailed correctly but returned by the U.S. Postal Service as undeliverable, the court held Monday.
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September 21, 2026
IRS Can Enforce Summons In Korean Probe Of VC Partner
The IRS can enforce a summons seeking bank information about a venture capitalist on behalf of South Korean tax authorities, a California federal judge ruled, holding that the statutory requirement to provide advance notice applies only to domestic tax liabilities.
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September 21, 2026
IRS Again Delaying Dividend Anti-Abuse Regs
The IRS is again extending the transition period for rules that govern certain financial transactions that could avoid withholding on dividend payments to foreign taxpayers, the agency announced Monday.
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September 21, 2026
IRS' Economic Substance Doctrine Has Limits, 5th Circ. Told
The IRS should not invoke the economic substance doctrine whenever it dislikes a transaction's tax consequences, an advocacy group told the Fifth Circuit on Monday in an eye doctor and his wife's appeal of a ruling that rejected their ophthalmology practice's microcaptive insurance arrangements.
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September 21, 2026
Varian, Gov't Appeal Foreign Dividend Decision To 9th Circ.
Varian Medical Systems Inc. is appealing a U.S. Tax Court decision that it owes more than $7.2 million to the Internal Revenue Service as a result of the court limiting its deemed dividends deduction, while the government is also appealing, according to filings in the Ninth Circuit.
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September 21, 2026
IRS Asks 5th Circ. To Pause Microcaptive Rules Case
The IRS asked the Fifth Circuit to stay briefing in a global tax services provider's bid to revive its challenge to the agency's reporting rules for microcaptive insurance companies pending the resolution of a related case before the appeals court.
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September 21, 2026
Funder Says $13M Albania Default Judgment Should Stand
Litigation funder Omni Bridgeway has urged a D.C. federal court to preserve a default judgment enforcing a roughly $13 million arbitral award against Albanian state entities, arguing they waited an unreasonable 18 months to appear despite receiving repeated notice of the case.
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September 18, 2026
Ex-DOJ Chief Lambastes 'Abuses Of Power' In Goldstein Case
The U.S. Department of Justice constantly made false statements in its criminal case against famed appellate advocate Tom Goldstein, and his convictions must be erased because "prosecutorial misconduct pervaded every stage of the proceedings," a former DOJ prosecutor told the Fourth Circuit.
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September 18, 2026
Judge Questions Whether 'Lawfare' Fund Fight Is Really Moot
A Virginia federal judge seemed unlikely to toss a challenge to the Trump administration's nixed "Anti-Weaponization Fund" and tax audit immunity for the Trump family Friday, saying she worries the fund could be revived in a different form down the road.
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September 18, 2026
US Asks Fed. Circ. To Reverse COVID-Era Tax Deadline Ruling
The government asked the Federal Circuit to overturn a U.S. Court of Federal Claims decision allowing a taxpayer to recover penalties and interest he sought refunds for during the COVID-19 pandemic, saying the claims court wrongly interpreted a statutory 60-day extension as having lasted over three and a half years.
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September 18, 2026
Exxon Wins $456M Tax, Penalty Refund In Qatar Gas Case
Exxon is entitled to a $274 million tax refund for a deduction of interest expenses fully allocated to the company by its partnership with Qatar to extract natural gas, a Texas federal court said Friday in an order that indicated $182 million in penalties should be returned as well.
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September 18, 2026
House Bill Would Limit BEAT, Make Other Int'l Tax Changes
The U.S. would limit the scope of its base erosion and anti-abuse tax and modify several other international tax measures under a bill introduced by a Republican on the House Ways and Means Committee.
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September 18, 2026
IRS Security Program 'Not Effective' In 2026, TIGTA Says
Facets of the IRS' cybersecurity program have improved since last year but are still ultimately "not effective," the Treasury Inspector General for Tax Administration said Friday, finding the deficiencies may leave taxpayer data vulnerable.
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September 18, 2026
Tax Tipster Fights For Whistleblower Award At DC Circ.
U.S. Tax Court wrongly upheld the IRS denying a whistleblower award for information about a taxpayer's transfer pricing despite the agency failing to follow its internal procedures, the individual told the D.C. appeals court.
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September 18, 2026
Taxation With Representation: Davis Polk, Latham, Sullivan
In this week's Taxation With Representation, a group backed by Michael Dell's family office and Sequence Holdings acquires a majority interest in The Baldwin Group, May Mobility merges with a blank check company, and Infineon Technologies sells its memory chip business to Winbond Electronics.
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September 18, 2026
TerrAscend Says Feds Sued Fake Co. In $8M Clawback Suit
Multistate cannabis operator TerrAscend USA Inc. asked a New Jersey federal court to throw out the federal government's suit seeking to claw back an $8 million tax refund, saying the government sued a nonexistent entity and even if it substituted the correct one, the suit still wouldn't belong in New Jersey.
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September 18, 2026
IRS Updates Corp. Bond Monthly Yield Curve For September
The IRS updated the corporate bond monthly yield curve used in calculations for defined benefit plans for September on Thursday as well as corresponding segment rates and the interest rate for 30-year U.S. Treasury Department securities.
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September 18, 2026
IRS Floats Tax Return Form With Question About Citizenship
The Internal Revenue Service released a draft version of the Form 1040 individual tax return that for the first time would include a question about the filer's citizenship status.
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September 18, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included a proposal to revoke federal tax exemptions for as many as 18,000 private schools that enact racially based diversity and inclusion policies.
Expert Analysis
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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.
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A Close Look At The Evolving Interval Fund Space
Interval funds — closed-end registered investment companies that make periodic repurchase offers — have recently moved to the center of the conversation about retail access to private markets, spurred along by President Donald Trump's August executive order incorporating alternative assets into 401(k) plans and target date strategies, say attorneys at Simpson Thacher.
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The Law Firm Merger Diaries: How To Build On Cultural Fit
Law firm mergers should start with people, then move to strategy: A two-level screening that puts finding a cultural fit at the pinnacle of the process can unearth shared values that are instrumental to deciding to move forward with a combination, says Matthew Madsen at Harrison.
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Rare Tariff Authority May Boost US Battery Manufacturing
Finalizing preliminary tariffs on active anode material from China — the result of a rare exercise of statutory authority finding that foreign dumping hampered the development of a nascent U.S. industry — should help domestic battery manufacturing, but potential price increases could discourage related clean-energy use, say attorneys at MoloLamken.
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Considerations When Invoking The Common-Interest Privilege
To successfully leverage the common-interest doctrine in a multiparty transaction or complex litigation, practitioners should be able to demonstrate that the parties intended for it to apply, that an underlying privilege like attorney-client has attached, and guard against disclosures that could waive privilege and defeat its purpose, say attorneys at DLA Piper.