Federal

  • 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.

  • May 01, 2026

    IRS Says Tribal Fishing Income Counts Toward Retirement

    Income earned by citizens of Native American tribes as payment for services related to fishing rights activities qualifies as compensation for purposes of limits on qualified retirement plan benefits and contributions, the Internal Revenue Service said Friday.

  • May 01, 2026

    Ex-Fla. Rep. Guilty Of FARA Violations For Venezuela Work

    A Florida federal jury on Friday found former Florida congressman David Rivera guilty of failing to register as a foreign agent after signing a $50 million contract with a unit of Venezuela's state-owned oil company.

  • May 01, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, included proposed regulations that would implement a higher threshold of $2,000 for when gambling businesses must report payouts to the government.

  • April 30, 2026

    6th Circ. Judge Skeptical Of IRS In $24M Air Excise Tax Case

    A Sixth Circuit judge expressed confusion Thursday at the IRS' defense of a $24 million air transportation excise tax on monthly management fees paid to a private aviation company after a government attorney conceded that initial ownership payments should also have been taxed.

  • April 30, 2026

    Trump To Drop Scottish Whiskey Tariffs After UK Royal Visit

    The U.S. will grant imported whiskey from the United Kingdom preferential tariff treatment following the visit to the U.S. by King Charles and Queen Camilla, President Donald Trump said on social media Thursday.

  • April 30, 2026

    Trump Order Aims To Help More Workers Save For Retirement

    President Donald Trump signed an executive order Thursday aimed at expanding workers' access to a low-cost retirement plan via a new government website, touting a $1,000 federal contribution match available under authority that Congress provided in a 2022 retirement law, the Secure 2.0 Act.

  • April 30, 2026

    Revenue Jump Doesn't Bar $5M Worker Credit, Lender Says

    A mortgage lender still suffered from suspensions to its business during COVID-19 even if it saw an overall increase in revenue, it told a California federal court, pushing back on the U.S. government's attempt to block it from claiming a $5 million employee retention tax credit.

  • April 30, 2026

    Meta Made $8B From Treasury Guidance On Minimum Tax

    Meta Platforms Inc. booked a more than $8 billion tax benefit from U.S. Treasury Department guidance on the corporate alternative minimum tax that allowed taxpayers to reduce the tax's base, the company said.

  • April 30, 2026

    5th Circ. Tosses FCA Suit Against IT Firm Over Visa Fraud

    The Fifth Circuit upheld the dismissal of a man's claims that an India-based information technology and professional services firm violated the False Claims Act via fraudulent visa applications and improper tax withholding, finding no specific payment obligations under the FCA itself.

  • April 30, 2026

    Wyden Asks IRS To Probe Lawyers For Puerto Rico Tax Advice

    Sen. Ron Wyden, D-Ore., said Thursday that he has asked the IRS to investigate whether two attorneys "inaccurately advised" wealthy individuals that they could avoid taxes on capital gains accrued in the U.S. before becoming residents of Puerto Rico.

  • April 30, 2026

    Judge Seeks Help On Jurisdiction In Trump's Tax Leak Suit

    A Miami federal court appointed six attorneys from three firms to help it determine whether it has jurisdiction in President Donald Trump's suit accusing the IRS of failing to prevent a former contractor from leaking his tax returns to news outlets.

  • April 30, 2026

    IRS Needs To Up Security Of Internal Financial Info, GAO Says

    The U.S. Government Accountability Office identified five new deficiencies mainly related to information security in the Internal Revenue Service's control over its financial reporting, saying Thursday that these add to 16 other outstanding issues from a previous audit.

  • April 30, 2026

    IRS Issues Temporary Rules For Dyed Fuel Tax Refunds

    The Internal Revenue Service on Thursday issued temporary guidelines, effective immediately, for taxpayers looking to submit claims to take advantage of a new refund on the dyed fuel excise tax.

  • April 29, 2026

    Consultant Says Venezuela Work Didn't Require FARA Filing

    The government did not prove that political consultant Esther Nuhfer was operating in bad faith when she worked with former Florida congressman David Rivera under a $50 million contract with a unit of Venezuela's state-owned oil company, Nuhfer's attorney said Wednesday in his final pitch to jurors.

  • April 29, 2026

    5th Circ. Calls Firm's Bid To Arbitrate $70M Award 'A Stretch'

    A Fifth Circuit panel seemed dubious of a law firm's argument that a federal court lacked jurisdiction over a claim that it shuffled assets to avoid paying an arbitration award that totaled $70 million, saying Wednesday that the firm's argument was "a stretch."

  • April 29, 2026

    IRS Urges Dismissal Of Manufacturer's Worker Credit Case

    A Fort Worth manufacturer already received employee retention tax credits for the first three quarters of 2021, rendering moot its challenge to claw back a refund amount, the IRS told a Texas federal court.

Expert Analysis

  • 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.

  • Trump Tax Law's Most Impactful Energy Changes

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    The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.

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