Federal
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January 20, 2026
IRS Can't Probe Partner-Tier Employment Taxes, 1st Circ. Told
The IRS is not authorized to scrutinize a partner's taxable net earnings at the business-entity level under a 1982 law governing partnership audits, an energy investment firm told the First Circuit, challenging the agency's bid to subject limited partners to the self-employment tax.
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January 20, 2026
IRS Funding Boost Faces $11.7B Cut In Bipartisan Package
Congress would cut $11.7 billion from the IRS spending boost included in the Inflation Reduction Act under a bipartisan, bicameral spending package released Tuesday by the House and Senate Appropriations committees.
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January 20, 2026
Tax Court Wrongly Cut Conservation Gift Value, 4th Circ. Told
The U.S. Tax Court made multiple errors when it reduced the value of rock-rich land underlying a North Carolina partnership's conservation easement donation, the partnership told the Fourth Circuit, urging it to at least reverse penalties imposed by the court as a result of its findings.
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January 16, 2026
Law360 Names Practice Groups Of The Year
Law360 would like to congratulate the winners of its Practice Groups of the Year awards for 2025, which honor the attorney teams behind litigation wins and significant transaction work that resonated throughout the legal industry this past year.
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January 18, 2026
Trump Threatens 10% Tariff To Goad EU Nations On Greenland
President Donald Trump said he would impose a 10% tariff on several countries in the European Union beginning Feb. 1 as a way to build pressure toward his goal for the U.S. to purchase Greenland, according to a social media post.
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January 17, 2026
5th Circ. OKs Self-Employment Tax Break For Limited Partners
Business partners with limited liability under state law are excluded from the federal self-employment tax, a Fifth Circuit panel ruled, siding with a management consulting firm in its long-running controversy over the levy's limited-partner exception.
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January 16, 2026
DOJ Says Wife Owes FBAR Penalties On India Account
A New York federal court should find that a businessman's wife owes penalties for his failure to report his Indian bank account to the Internal Revenue Service after he deposited $1.5 million from the sale of a New York apartment complex, the U.S. Department of Justice argued Friday.
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January 16, 2026
Treasury's Rule Pace Unchanged After Loper Bright, Atty Says
The U.S. Supreme Court's 2024 landmark decision limiting federal agencies' deference in interpreting ambiguous statutes has not significantly altered the pace and volume of the U.S. Department of the Treasury's rulemaking workload, a Treasury attorney said Friday.
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January 16, 2026
IRS Rightly Withheld Worker Tax Credit FOIA Docs, Court Says
The Internal Revenue Service properly invoked two Freedom of Information Act exemptions to withhold portions of internal directives about the employee retention tax credit requested by an attorney who represents taxpayers in disputes with the agency, an Alabama federal court said.
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January 16, 2026
IRS Boosts Mediation Training In Appeals, Official Says
The IRS has ramped up its training of appeals officers to perform mediation work to account for the recent reduction of staff as part of the agency's ongoing emphasis to quickly resolve taxpayer issues through the alternative dispute resolution process, an official said Friday.
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January 16, 2026
Taxation With Representation: Stibbe, A&O Shearman, Latham
In this week's Taxation With Representation, Keurig Dr Pepper Inc. plans to complete its deal to snap up coffee company JDE Peet's NV, Boston Scientific Corp. acquires medical device company Penumbra Inc., and fitness and wellness platform parent Playlist merges with fitness technology company EGYM.
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January 16, 2026
Paramount Signs 1st Lease At New Manhattan Studio
Realty Trust, Hudson Pacific Properties Inc. and Blackstone Real Estate announced that the joint venture partners behind a Manhattan studio still under construction have signed the property's first lease with Paramount Television Studios.
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January 16, 2026
State Rules Add Wrinkle To Scholarship Tax Break's Rollout
The U.S. Treasury Department is grappling with how to balance federal and state rules to implement a new tax credit for contributions to eligible scholarship programs, an official said Friday, describing states as "gatekeepers" in determining eligibility.
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January 16, 2026
German Co. Cites Good Faith In Disputing $1.2M Tax Bill
A German manufacturer is challenging a $1.2 million tax bill stemming from late information filings, telling the U.S. Tax Court it relied in good faith on its domestic partnership's manager and other qualified professionals.
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January 16, 2026
Spain, US Spell Out Tax Treaty Arbitration Process
Spain and the United States signed an agreement spelling out the process for binding arbitration under their tax treaty, which requires an independent panel to resolve disputes by selecting only one side's position, according to an IRS announcement Friday.
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January 16, 2026
Conservation Easement Was $2.7M 'Swindle,' Investors Say
Two investors have hit the Georgia-based managers of a syndicated conservation easement with a racketeering lawsuit, accusing the managers of lining their own pockets with nearly all the proceeds of a 2024 real estate sale to liquidate the fund.
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January 16, 2026
Tax Court Won't Rethink Late Challenge In $46M Case
The U.S. Tax Court won't reconsider its rejection of a late-filed bid by a partnership seeking to restore its $46 million tax deduction for donating to charity, saying the Alabama company failed to raise a newly available legal argument as required for the second chance.
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January 16, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included final rules for the inclusion of certain qualified derivative payments linked to securities-lending transactions when calculating payments covered by the base erosion and anti-abuse tax.
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January 16, 2026
Basic Allowance For Military Housing Isn't Taxable, IRS Says
The supplemental basic allowance for housing payments made to uniformed military personnel in December are not to be included in income and are not taxable, the Internal Revenue Service and U.S. Department of the Treasury said Friday.
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January 15, 2026
As Goldstein Trial Begins, Gov't Points To 'Lavish' Lifestyle
An accountant for billionaire investor Alec Gores said that Thomas Goldstein had suggested he open a foreign account for Gores' poker-related transactions or even classify him as a professional player for tax purposes, although Gores was just getting started in the high-stakes poker world.
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January 15, 2026
Businesses Seek Clarity On R&D Credit Post-GOP Tax Law
Businesses that use the federal research credit are reexamining how to apply expense reduction rules after last year's GOP tax law changes, but Treasury officials and tax experts said Thursday that revisions, although complex, were intended to coordinate with existing capitalization rules.
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January 15, 2026
US Pillar 2 Deal May Spur Other Nations To Seek Exemptions
International negotiators designed a 15% corporate minimum tax known as Pillar Two to apply worldwide, but a recently agreed-to carveout for the U.S. may prompt other countries with qualifying alternative regimes to seek similar exemptions that ultimately strain the global system.
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January 15, 2026
Private Activity Rules Don't Apply To Tax-Exempt Train Bonds
Private activity bond rules do not apply to certain tax-exempt bonds issued by the Alaska Railroad Corp. to finance certain property, the Internal Revenue Service said Thursday.
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January 15, 2026
$332M Colgate-Palmolive Pension Deal Nabs Final Nod
A New York federal judge handed final approval to a $332 million deal ending a class action accusing Colgate-Palmolive of shorting retirees who opted for lump-sum payments, but has yet to rule on the pensioners' attorneys' bid for $99 million in fees.
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January 15, 2026
IRS Updates Rules For Groups Seeking Tax-Exempt Status
The Internal Revenue Service released new rules Thursday for obtaining tax-exempt status as a group, addressing concerns of religious organizations that had worried they would be excluded if they were forced to submit financial information to their central organizations.
Expert Analysis
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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.
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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.