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Federal
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June 08, 2026
Liberty Global Seeks Rehearing In $2.4B Tax Substance Fight
Telecommunications firm Liberty Global wants another shot at showing the Tenth Circuit that it's entitled to a $2.4 billion deduction linked to transactions with foreign affiliates, claiming the court misapplied a rule that can disallow tax benefits from transactions that lack economic substance.
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June 08, 2026
Reality TV Stars Say Balch & Bingham Botched Their Defense
Reality television stars Todd and Julie Chrisley, who were pardoned by President Donald Trump in May 2025 after serving over two years in prison for financial crimes, filed suit against Balch & Bingham LLP and their former defense attorney, alleging they wouldn't have been convicted "had their lawyers done their jobs."
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June 08, 2026
Okla. Firm Urges Dismissal Of EDNY Misclassification Suit
Oklahoma-based Arnold & Smith Law PLLC on Friday asked a New York federal judge to dismiss a New York attorney's lawsuit accusing the firm of misclassifying employees as contractors to avoid paying benefits, saying there is no reason to believe any of the alleged misconduct happened in New York.
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June 08, 2026
Energy Transactions Atty Returns To McGuireWoods In SF
A senior vice president with Aon's global mergers and acquisitions and transactions solutions team has rejoined McGuireWoods LLP as a partner in San Francisco, the firm announced Monday.
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June 08, 2026
Developers Stumped By Energy Credits' Foreign Debt Limits
Developers seeking to finalize projects financed with clean energy tax credits and several loans are hitting a roadblock in demonstrating to the IRS that their debt has limited ties to prohibited foreign entities, a requirement for qualifying for the incentives.
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June 08, 2026
McKesson Can't Defeat Valid Cost-Sharing Rules, Gov't Says
The U.S. government urged a Texas federal court to uphold transfer pricing regulations that pharmaceutical giant McKesson is challenging in its push for a nearly $10 million tax refund, arguing the rules fall "well within the bounds" of the underlying statutory text.
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June 08, 2026
IRS Identity Theft Partnership Designates New Work Groups
A public-private partnership between the Internal Revenue Service and the tax community to help crack down on tax-related identity theft is restructuring and creating new work groups to improve information sharing across the U.S. tax system to help crack down on such theft, the agency announced Monday.
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June 05, 2026
Calif.'s Global Reporting Bill Could Embolden Other States
A California bill that would require multinational corporations to report their global profits could spark similar legislation across the U.S. if lawmakers of revenue-hungry states perceive shortcomings in federal and international efforts to tackle profit shifting.
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June 05, 2026
11th Circ. Lets Man Fight $2.2M FBAR Penalties As Excessive
A Georgia federal court correctly found that the owner of a sports equipment business willfully failed to disclose his foreign bank accounts, but it must give him a chance to challenge $2.2 million in resulting penalties as excessive under the Eighth Amendment, the Eleventh Circuit said.
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June 05, 2026
IRS To Release Guidance On Tax-Exempt Org. Pay Excise Tax
The IRS is planning to issue proposed guidance on the expanded 21% excise tax on excess compensation at tax-exempt organizations, including updated definitions that align with changes passed under Republicans' 2025 tax overhaul, according to a notice released Friday.
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June 05, 2026
Abbott Says Timing Mismatch Lets $8B Gain Go Untaxed
Abbott Laboratories asked the U.S. Tax Court to find that it needn't recognize an $8 billion gain in 2020 from transactions between several of its controlled foreign corporations because of a mismatch in the effective dates of different sections of the 2017 U.S. Tax Cuts and Jobs Act.
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June 05, 2026
Judge Asks How FCC Ruling Affects $6.6M IRS Penalty Fight
A Pennsylvania federal judge ordered briefing on how the U.S. Supreme Court's new decision upholding agency fines without a jury trial affects a $6.6 million tax penalty dispute, signaling potential reconsideration of last year's opinion in the case.
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June 05, 2026
Taxation With Representation: Simpson Thacher, Fried Frank
In this week's Taxation With Representation, Berkshire Hathaway Inc. takes Taylor Morrison Home Corp. private, global real estate investment company Kennedy Wilson forms a residential joint venture with Netherlands pension services provider APG, and Wellington Management acquires Hartford Funds from insurer The Hartford.
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June 05, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included an extension for sponsors of certain defined contribution retirement plans to amend the plans to allow qualified long-term care distributions.
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June 04, 2026
Jury Hears Closings In Trial Over Alleged Tax Shelter Scheme
Prosecutors told a Colorado federal jury Thursday that four individuals defrauded the government by using their businesses to help promote and sell abusive and illegal trust tax shelters, while the defendants argued they lacked knowledge of the alleged scheme and can't be held responsible.
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June 04, 2026
Bessent Mum On Details Of Trump-IRS Settlement
Treasury Secretary Scott Bessent gave House Democrats few answers Thursday to their questions on the scope and limitations of President Donald Trump's settlement with the IRS over the leak of his tax data that includes an exemption from tax audits for Trump and members of his family.
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June 04, 2026
Tax Court Confirms IRS Computations In Easement Case
A partnership, in objecting to IRS computations, improperly raised new arguments in a case where the U.S. Tax Court reduced a conservation easement deduction by over $10 million, the tax court said in upholding the agency's calculations, which included a 40% penalty.
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June 04, 2026
Feds Appeal Trade Court's Emergency Tariff Refund Order
The federal government has appealed the U.S. Court of International Trade's order requiring refunds on all duties paid under the International Emergency Economic Powers Act after the U.S. Supreme Court struck them down this year, according to filings in the trade court and Federal Circuit.
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June 04, 2026
IRS To Hold Hearing On Trump Accounts In July
The Internal Revenue Service will hold a public hearing July 16 on proposed rules related to the new tax-advantaged brokerage accounts for newborns called Trump accounts, the agency said Thursday.
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June 04, 2026
Ex-Surgeon Agrees To $7.7M Tax Bill From Offshore Scheme
A retired plastic surgeon reached a $7.7 million settlement with the federal government to resolve an Internal Revenue Service case alleging that he ran an offshore employee leasing scheme, according to an agreement filed in an Ohio federal court.
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June 04, 2026
Californian's Crypto Staking Rewards Taxable, Tax Court Says
A California man's cryptocurrency staking rewards, in the form of additional tokens for supporting a blockchain platform, are taxable income, a U.S. Tax Court judge ruled Thursday, saying he could have converted the tokens into cash at any time.
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June 04, 2026
Goldstein Seeks Sentencing Delay, Citing New Tax Claims
SCOTUSblog founder Thomas Goldstein renewed his push Wednesday in Maryland federal court for a delayed sentencing, saying prosecutors blindsided his defense by including additional uncharged years of alleged tax avoidance in the government's sentencing memorandum.
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June 04, 2026
Blanche's AG Bid Could Face Rocky Path In Senate
Acting Attorney General Todd Blanche will be tapped for the permanent role, but he might not have a smooth path to confirmation.
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June 04, 2026
Tax Court Didn't Err In Voiding $713M Deduction, IRS Says
A real estate development partnership failed to show that the U.S. Tax Court made errors that undermined its ruling eliminating a $713 million deduction to the partnership for 2012, the IRS argued, saying the court shouldn't gratuitously decide issues that don't affect a case's disposition.
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June 03, 2026
Dems Press Bessent On 'Weaponization' Fund, Trump Audits
Senate Democrats questioned Treasury Secretary Scott Bessent on Wednesday about details of a settlement that included a since-dropped plan for a $1.8 billion fund that could have been used to pay off Jan. 6 defendants and an exemption from IRS audits for President Donald Trump and members of his family.
Expert Analysis
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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.
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2 Rulings Highlight IRS' Uncertain Civil Fraud Penalty Powers
Conflicting decisions from the U.S. Tax Court and the Northern District of Texas that hinge on whether the IRS can administratively assert civil fraud penalties since the U.S. Supreme Court’s 2024 decision in SEC v. Jarkesy provide both opportunities and potential pitfalls for taxpayers, says Michael Landman at Bird Marella.
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Junior Attys Must Beware Of 5 Common Legal Brief Mistakes
Excerpt from Practical Guidance
Junior law firm associates must be careful to avoid five common pitfalls when drafting legal briefs — from including every possible argument to not developing a theme — to build the reputation of a sought-after litigator, says James Argionis at Cozen O'Connor.
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Digital Asset Report Opens Doors For Banks, But Risks Linger
A recent report from a White House working group discussing digital asset market structure signals how banks may elect to expand into digital asset custody, trading and related services in the years ahead, but the road remains layered with challenges, say attorneys at Foley & Lardner.
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Power To The Paralegals: How And Why Training Must Evolve
Empowering paralegals through new models of education that emphasize digital fluency, interdisciplinary collaboration and human-centered lawyering could help solve workforce challenges and the justice gap — if firms, educators and policymakers get on board, say Kristine Custodio Suero and Kelli Radnothy.
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5 Real Estate Takeaways From Trump's Sweeping Tax Law
Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.
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Evaluating The Current State Of Trump's Tariff Deals
As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.
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How Hyperlinks Are Changing E-Discovery Responsibilities
A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.
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Preserving Refunds As Tariffs Await Supreme Court Weigh-In
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.
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Revamped Opportunity Zones Can Aid Clean Energy Projects
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.
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Writing Musicals Makes Me A Better Lawyer
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.
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How Fashion, Tech Can Maximize New Small Biz Tax Breaks
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.