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Federal
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July 10, 2026
Taxation With Representation: Cleary, Paul Weiss, Fried Frank
In this week's Taxation With Representation, Solstice Advanced Materials Inc. acquires specialty chemicals technology company Element Solutions Inc., Vertex Pharmaceuticals Inc. buys Crinetics Pharmaceuticals Inc., and Lockheed Martin acquires naval defense company Ultra Maritime.
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July 09, 2026
Judge Backs Feds' Valuation Method In Windfarm Grant Fight
A U.S. Court of Federal Claims judge ordered several California wind farm owners and the federal government to largely employ a method the government proposed to value their facilities and hash out a decade-old dispute over grants worth hundreds of millions of dollars.
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July 09, 2026
Okla. Tax Officials Say McGirt Can't Upend Osage Ruling
Oklahoma tax officials say the Osage Nation can't rely on a 2020 landmark U.S. Supreme Court ruling to overturn a decision that declined to vacate a 16-year-old determination that its reservation boundaries had been disestablished, telling the Tenth Circuit that the tribe's challenge is too late.
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July 09, 2026
IRS Asks 7th Circ. To Rehear $300M Hyatt Perks Tax Dispute
The IRS asked the Seventh Circuit to reconsider its decision to remand a dispute over $300 million in Hyatt Hotels' loyalty rewards program fund to the U.S. Tax Court for it to determine whether the money can be excluded from taxable income under what's known as the claim of right doctrine.
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July 09, 2026
IRS Updates Outdated References In Estate Tax Rules
The Internal Revenue Service released final regulations that modify and replace outdated references in rules for deceased taxpayers who have passed their property to a noncitizen spouse in a domestic trust.
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July 09, 2026
Reclassified Debt Didn't Cause $21M Gain, Partnership Says
The IRS wrongly treated the reclassification of $21.1 million in debt to equity as a taxable event when hitting a partnership with $12.8 million in taxes, penalties and estimated interest, the partnership told the U.S. Tax Court.
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July 09, 2026
4th Circ. Rebuffs Tax Attys' Request To Rethink Convictions
The Fourth Circuit will not rethink its decision last month affirming the convictions of two St. Louis attorneys accused of engineering a $22 million tax avoidance scheme.
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July 09, 2026
5 Clifford Chance Finance And Tax Attys Join Sidley In NY, DC
Sidley Austin LLP announced Thursday that five Clifford Chance LLP attorneys have joined the firm's global finance and tax practices in New York and Washington, D.C.
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July 09, 2026
Pillar 2 Carveouts Won't Undercut Global Tax, Official Says
The integrity of the 15% global minimum tax system will not be undermined by a host of nations gaining access to provisions that exempt them from certain obligations, the tax head at the Organization for Economic Cooperation and Development said Thursday.
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July 08, 2026
Partnership Defends $55.6M Deduction For Mo. Land Gift
A partnership that donated over 73 acres in Butler County, Missouri, to a conservation group told the U.S. Tax Court it properly deducted $55.6 million for the gift, saying the value was based on the analysis of two qualified appraisers.
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July 08, 2026
IRS To Give Automatic Penalty Relief To Compliant Taxpayers
Taxpayers with a history of filing and paying on time will no longer have to request penalty relief under an automatic exemption expected to roll out this summer, the IRS announced Wednesday.
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July 08, 2026
IRS Finalizes Life Insurance Reporting Exception Regs
The Internal Revenue Service confirmed that certain tax-free transfers of life insurance contracts are exempt from the 2019 reporting rules for life settlement transactions, including policy sales and death benefit payments, under final regulations released Wednesday.
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July 08, 2026
IRS Urged To Make Digital Broker E-Statements Easier
The IRS should update regulations that would allow digital asset brokers to provide statements electronically to remove operational hurdles and designate more effective communication methods, such as in-app messaging and SMS, stakeholders told the agency Wednesday.
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July 08, 2026
Shopping Center Owner's Estate Disputes $41M Deficiency
The estate of a man who co-owned a Massachusetts shopping center challenged a $40.8 million deficiency assessment in the U.S. Tax Court, saying the IRS wrongly determined that a 2012 sale of his interest in the partnership owning the center wasn't bona fide.
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July 08, 2026
IRS Targets Certain Annuity Trusts As Potential Tax Shelters
The IRS unveiled final rules Wednesday designating certain charitable remainder annuity trusts as reportable transactions because they involve abusive tax avoidance practices, subjecting participants to potential penalties if they do not disclose such arrangements.
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July 08, 2026
Foley Adds Attys From Kirkland, Goodwin To Corporate Team
Foley & Lardner LLP has strengthened its corporate bench with a Dallas-based partner who came aboard from Kirkland & Ellis LLP and a Boston-based partner from Goodwin Procter LLP.
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July 07, 2026
2 Ex-Telehealth Execs Sentenced For $100M Adderall Scheme
A California federal judge on Tuesday sentenced two former executives of a telehealth company who were convicted of operating a $100 million scheme to illegally distribute Adderall over the internet, fining them $1 million each and giving the founder six years in prison.
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July 07, 2026
DC Circ. Backs Tax Bribery Convictions Despite Jury Error
A D.C. Circuit panel refused on Tuesday to reverse a lower court's judgments against two men in connection to a bribery scheme carried out to evade $2.3 million in business tax obligations, finding a jury instruction error "harmless," among other unsuccessful arguments.
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July 07, 2026
Dem Sens. Probe CEOs On Trump-IRS Settlement Immunity
Three senior Democratic senators are investigating whether several companies with ties to President Donald Trump are benefiting from what they alleged was immunity for him, his family and his businesses in the settlement he reached with the Internal Revenue Service.
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July 07, 2026
Exxon Seeks $324M Judgment In Dispute On Qatar Deal Tax
Exxon asked a Texas federal court to rule that it's owed a $273 million tax refund and $51 million in penalties in a dispute with the U.S. government over the tax treatment of a natural gas deal with Qatar.
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July 07, 2026
IRS Denies Blowing Deadline In $34M Easement Dispute
The IRS timely issued a notice of adjustment to a partnership claiming a $34 million easement deduction for its donation to a Cleveland historic preservation group, the agency told the U.S. Tax Court, arguing that the partnership is raising a frivolous contention in seeking to throw out the adjustment and penalties.
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July 07, 2026
Consultant Says FARA Verdict Should Be Erased
A political consultant convicted of knowingly failing to register as a foreign agent as she helped draft a $50 million contract involving a former congressman and Venezuela's state-owned oil enterprise continues to argue she should be acquitted or given a new trial, saying the verdict was "against the great weight of the evidence."
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July 07, 2026
Claims Court Nixes GILTI Tax Rules Under Loper Bright
The U.S. Court of Federal Claims invalidated corporate tax regulations that deny amortization deductions tied to certain overseas intangible asset transfers, holding that the rules are the kind of "agency overreach" foreclosed by the U.S. Supreme Court's Loper Bright ruling.
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July 07, 2026
Grocers' Microcaptive Not Valid For Tax Benefit, 7th Circ. Told
Chicagoland grocery chain owners were not entitled to microcaptive tax benefits because they failed to establish a bona fide in-house insurance arrangement, the government told the Seventh Circuit, saying the U.S. Tax Court correctly held that state law does not control the federal tax definition of insurance.
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July 07, 2026
Simpson Thacher Adds Energy Tax Partner From Weil In NY
Simpson Thacher & Bartlett LLP announced Tuesday that a former Weil Gotshal & Manges LLP partner has joined the firm's New York office to advise clients on the U.S. tax aspects of energy and infrastructure transactions.
Expert Analysis
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Law School's Missed Lessons: Educating Your Community
Nearly two decades prosecuting scammers and elder fraud taught me that proactively educating the public about the risks they face and the rights they possess is essential to building trust within our communities, empowering otherwise vulnerable citizens and preventing wrongdoers from gaining a foothold, says Roger Handberg at GrayRobinson.
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5 Crisis Lawyering Skills For An Age Of Uncertainty
As attorneys increasingly face unprecedented and pervasive situations — from prosecutions of law enforcement officials to executive orders targeting law firms — they must develop several essential competencies of effective crisis lawyering, says Ray Brescia at Albany Law School.
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It's Time For The Judiciary To Fix Its Cybersecurity Problem
After recent reports that hackers have once again infiltrated federal courts’ electronic case management systems, the judiciary should strengthen its cybersecurity practices in line with executive branch standards, outlining clear roles and responsibilities for execution, says Ilona Cohen at HackerOne.
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Rules Of Origin Revamp May Be Next Big Trade Development
The rules of origin for determining what tariff applies to any given import appear to be on the cusp of an important rethink, and it seems likely that the administration will try to align the rule with its overall tariff strategy in one of three ways, says Ted Posner at Baker Botts.
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IRS Shutdown Backlog May Trigger Collection, Refund Chaos
As the IRS continues to send automated collection notices amid the ongoing federal government shutdown, a mounting backlog of unprocessed refunds, collections filings and mail is causing problems for taxpayers that will continue even after the shutdown ends, says Meeren Amin at Fox Rothschild.
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SDNY OpenAI Order Clarifies Preservation Standards For AI
The Southern District of New York’s recent order in the OpenAI copyright infringement litigation, denying discovery of The New York Times' artificial intelligence technology use, clarifies that traditional preservation benchmarks apply to AI content, relieving organizations from using a “keep everything” approach, says Philip Favro at Favro Law.
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High Court, Not A Single Justice, Should Decide On Recusal
As public trust in the U.S. Supreme Court continues to decline, the court should adopt a collegial framework in which all justices decide questions of recusal together — a reform that respects both judicial independence and due process for litigants, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.
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Adapting To Private Practice: 3 Tips On Finding The Right Job
After 23 years as a state and federal prosecutor, when I contemplated moving to a law firm, practicing solo or going in-house, I found there's a critical first step — deep self-reflection on what you truly want to do and where your strengths lie, says Rachael Jones at McKool Smith.
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Painting Makes Me A Better Lawyer
Painting trains me to see both the fine detail and the whole composition at once, enabling me to identify friction points while keeping sight of a client's bigger vision, but the most significant lesson I've brought to my legal work has been the value of originality, says Jana Gouchev at Gouchev Law.
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Compliance Pointers Amid Domestic Terrorism Clampdown
A recent presidential memorandum marks a shift in federal domestic-terrorism enforcement that should prompt nonprofits to enhance diligence related to grantees, vendors and events, and financial institutions to shore up their internal resources for increased suspicious-activity monitoring and reporting obligations, say attorneys at Morgan Lewis.
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Trump Tax Law Has Mixed Impacts On Commercial Real Estate
The One Big Beautiful Bill Act brings sweeping changes to the real estate industry — and while the permanency of opportunity zones and bonus depreciation creates predictability for some taxpayers, sunsetting incentives for renewable energy projects will leave others with hard choices, says Jordan Metzger at Cole Schotz.
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Protecting Sensitive Court Filings After Recent Cyber Breach
In the wake of a recent cyberattack on federal courts' Case Management/Electronic Case Files system, civil litigants should consider seeking enhanced protections for sensitive materials filed under seal to mitigate the risk of unauthorized exposure, say attorneys at Redgrave.
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What Ethics Rules Say On Atty Discipline For Online Speech
Though law firms are free to discipline employees for their online commentary about Charlie Kirk or other social media activity, saying crude or insensitive things on the internet generally doesn’t subject attorneys to professional discipline under the Model Rules of Professional Conduct, says Stacie H. Rosenzweig at Halling & Cayo.