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Federal
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February 23, 2026
Tax Court Rejects Son-of-Boss Promoter's Penalty Dispute
A tax shelter promoter behind Son-of-Boss arrangements cannot challenge certain Internal Revenue Service penalties for failing to report the questionable transactions, the U.S. Tax Court ruled Monday, finding he forfeited that right by not participating in the administrative appeals process.
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February 23, 2026
States Back Challenge To IRS Nix Of Wind, Solar Safe Harbor
Sixteen Democratic-led states are backing a legal challenge to an Internal Revenue Service notice eliminating a safe harbor test that large wind and solar projects could use to qualify for clean energy tax credits.
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February 23, 2026
US Customs Stops Collecting Tariffs Starting Tuesday
U.S. Customs and Border Protection will stop collecting the tariffs President Donald Trump illegally imposed under the International Emergency Economic Powers Act beginning at midnight Tuesday, according to guidance sent late Sunday.
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February 23, 2026
$50M Tax Suit Against Plastics Heirs Is Timely, Court Told
The federal government did not miss the deadline for suing the heirs to a plastics company for more than $50 million in estate taxes, the U.S. Department of Justice told a Connecticut federal court Monday, arguing its proof of claim and a probate suit started the clock.
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February 23, 2026
Justices Won't Review Religious Group's Bid Against IRS Lien
The U.S. Supreme Court declined Monday to review a religious organization's constitutional challenge against the Internal Revenue Service over a lien on church property to collect taxes owed by the group's bankrupt founder and her family.
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February 23, 2026
IRS Updates Timeline On Retirement Plan Min. Distributions
The Internal Revenue Service updated its guidance Monday on the timing of required minimum distributions from several types of individual retirement accounts that were amended by a 2022 retirement savings law.
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February 23, 2026
IRS Workers Received Laptops Late, TIGTA Says
Many employees hired by the Internal Revenue Service may have been unable to work effectively because they didn't receive laptops within a week of their start dates, the Treasury Inspector General for Tax Administration said in a report released Monday.
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February 23, 2026
Justices Won't Review Conviction In $1B Renewables Fraud
The U.S. Supreme Court declined Monday to hear an appeal from the convicted leader of a fraudulent $1 billion renewable-energy scheme who contended that he was unlawfully ordered to forfeit a "gobsmacking" $181 million based on joint and several liability.
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February 23, 2026
Justices Won't Review Sentence Of Bitcoin 'Peace Promoter'
The U.S. Supreme Court declined on Monday to review the eight-year sentence that a church founder and self-described "peace promoter" received after he was charged with tax evasion and other crimes tied to a bitcoin operation he founded in 2014.
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February 20, 2026
3 Questions After Justices Sink Trump's Emergency Tariffs
The U.S. Supreme Court's ruling that President Donald Trump's tariffs imposed under the International Emergency Economic Powers Act are unlawful left open questions for practitioners, including how importers may qualify and claim refunds for the illegal duties paid. Here, Law360 examines three open questions following the justices' ruling.
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February 20, 2026
Treasury, IRS Lay Out Eligibility For Depreciation Allowance
The U.S. Treasury Department and Internal Revenue Service released interim guidance Friday on what production property is eligible for the special depreciation allowance under last summer's federal budget law and announced plans to float official regulations on the provision.
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February 20, 2026
Up Next At High Court: Cuban Seizures & Removal Deadlines
The U.S. Supreme Court will kick off its February oral argument session by hearing cases that could expand or limit the availability of damages for U.S. victims of property seized by the Cuban government and a defendant's chance to remove state court cases to federal court.
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February 20, 2026
Full 8th Circ. Won't Revisit 3M's Win Against IRS
The full Eighth Circuit declined to rethink a panel's ruling that held the Internal Revenue Service lacked the statutory authority to allocate nearly $24 million in royalty payments that 3M Co. said it was blocked from receiving under Brazilian law.
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February 20, 2026
Cozen Adds One Big Beautiful Bill Tax Provision Designer
The architect of the tax provision in the One Big Beautiful Bill Act, who spent the past seven years on Capitol Hill and previously served as the top oversight counsel for the House Ways and Means Committee, has joined Cozen O'Connor Public Strategies, the group recently announced.
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February 20, 2026
Western Digital Wants Back $21M In COVID-Era Tax Interest
The IRS improperly charged hard drive maker Western Digital $21 million in interest on its tax debt during a period when interest was supposed to be suspended because of the COVID-19 pandemic, the company told the U.S. Court of Federal Claims in asking for a refund.
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February 20, 2026
Taxation With Representation: Freshfields, Simpson Thacher
In this week's Taxation With Representation, science and technology company Danaher Corp. acquires medical technology company Masimo Corp., Covetrus merges with a unit of fellow animal health technology company Cencora, and private equity firm Leonard Green & Partners LP buys outstanding Mister Car Wash Inc. shares not already owned by LGP affiliates.
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February 20, 2026
Partnership Defends $22M Donation Under 5th Amendment
A Georgia partnership raised arguments under the Fifth, Seventh and Eighth amendments in defending a $22.9 million conservation easement deduction for 2018, saying the denial of the deduction amounts to the government taking property for public use without just compensation.
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February 20, 2026
AICPA Urges IRS To Provide R&D Tax Break Guidance
The Internal Revenue Service should clarify the capitalization and amortization election as it applies to the tax break for domestic research and development costs enacted under July's budget law, the American Institute of Certified Public Accountants said in a letter released Friday.
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February 20, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included proposed rules clarifying how domestic transportation fuel producers can qualify for the clean energy fuel tax credit under changes made by the Republicans' 2025 budget law.
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February 20, 2026
Trump Imposes Maximum Tariff After Supreme Court Rebuke
President Donald Trump imposed a temporary global tariff with several exemptions hours after the U.S. Supreme Court struck down tariffs imposed under the International Emergency Economic Powers Act, then announced that he would increase the duty to the 15% maximum.
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February 19, 2026
Takeaways From US-India Interim Trade Deal
Trade tensions between the U.S. and India have cooled off after a deal to reduce U.S. tariffs was reached this month, but questions remain about how the interim agreement will materialize and influence future negotiations. Here, Law360 examines several takeaways from the interim deal and efforts toward a broader deal arrangement.
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February 19, 2026
Coalition Asks Court To Back Probe Into IRS-ICE Data Sharing
More discovery is needed into the IRS' data-sharing agreement with Immigration and Customs Enforcement in light of the tax authority recently admitting to breaching its terms, a coalition challenging the agreement told a D.C. federal court in seeking a remand.
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February 19, 2026
Tax Court Slashes $115M Easement Deduction
A partnership is not entitled to a $115 million tax deduction for donating a conservation easement over rural farmland in Louisiana, the U.S. Tax Court ruled Thursday, saying the amount "grotesquely" exceeded the easement's actual value.
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February 19, 2026
Federal Gov't Overrides DC's Rejection Of Tax Breaks
President Donald Trump signed a resolution repealing a Washington, D.C., law that decoupled sections of the city's tax code from federal changes made as part of last summer's budget law.
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February 19, 2026
IRS Wins Dismissal Of FOIA Suit Over Business Tax Records
A man failed to show entitlement to tax records he sought related to his family printing company, a D.C. federal court found Thursday, granting the Internal Revenue Service's motion to dismiss his Freedom of Information Act suit.
Expert Analysis
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Adapting To Private Practice: From NY Fed To BigLaw
While the move to private practice brings a learning curve, it also brings chances to learn new skills and grow your network, requiring a clear understanding of how your skills can complement and contribute to a firm's existing practice, and where you can add new value, says Meghann Donahue at Covington.
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Top 3 Litigation Finance Deal-Killers, And How To Avoid Them
Like all transactions, litigation finance deals can sometimes collapse, but understanding the most common reasons for failure, including a lack of trust or a misunderstanding of deal terms, can help both parties avoid problems, say Rebecca Berrebi at Avenue 33 and Boris Ziser at Schulte Roth.
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A 2-Step System For Choosing A Digital Asset Reporting Path
Under the Internal Revenue Service's new digital asset reporting regulation, each type of asset may have three potential reporting destinations, so a detailed testing framework can help to determine the appropriate path, says Keval Sonecha at Sonecha & Amlani.
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How Attys Can Use A Therapy Model To Help Triggered Clients
Attorneys can lean on key principles from a psychotherapeutic paradigm known as the "Internal Family Systems" model to help manage triggered clients and get settlement negotiations back on track, says Jennifer Gibbs at Zelle.
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3 Steps For In-House Counsel To Assess Litigation Claims
Before a potential economic downturn, in-house attorneys should investigate whether their company is sitting on hidden litigation claims that could unlock large recoveries to help the business withstand tough times, says Will Burgess at Hilgers Graben.
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IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement
Tax crimes are historically difficult to prosecute, but the Internal Revenue Services’ recent agreement with U.S. Immigration and Customs Enforcement to share taxpayer records of non-U.S. citizens could be used to enhance payroll tax-related enforcement against their employers, say attorneys at Holland & Knight.
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Adapting To Private Practice: From DOJ Enviro To Mid-Law
Practitioners leaving a longtime government role for private practice — as when I departed the U.S. Department of Justice’s environmental enforcement division — should prioritize finding a firm that shares their principles, values their experience and will invest in their transition, says John Cruden at Beveridge & Diamond.
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Legal Ethics Considerations For Law Firm Pro Bono Deals
If a law firm enters into a pro bono deal with the Trump administration in exchange for avoiding or removing an executive order, it has an ethical obligation to create a written settlement agreement with specific terms, which would mitigate some potential conflict of interest problems, says Andrew Altschul at Buchanan Angeli.
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10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks
The ongoing arbitral saga of Sullivan v. Feldman, which has engendered proceedings before 10 different arbitrators in Texas and Louisiana along with last month's Fifth Circuit opinion, showcases both the risks and limitations of arbitration clauses in retainer agreements for resolving attorney-client disputes, says Christopher Blazejewski at Sherin and Lodgen.
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Notable Q1 Updates In Insurance Class Actions
The first quarter of 2025 was filled with the refinement of old theories in the property and casualty space, including in vehicle valuation, time to seek appraisal and materials depreciation, says Mathew Drocton at BakerHostetler.
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Power To The Paralegals: The Value Of Unified State Licensing
Texas' proposal to become the latest state to license paraprofessional providers of limited legal services could help firms expand their reach and improve access to justice, but consumers, attorneys and allied legal professionals would benefit even more if similar programs across the country become more uniform, says Michael Houlberg at the University of Denver.
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10 Soft Skills Every GC Should Master
As businesses face shifting regulatory and technological uncertainty, general counsel will need to strengthen certain soft skills to succeed, from admitting when they make a mistake to maintaining a healthy dose of dispassion, says Douglas Brown at Manatt.
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An Unrestrained, Bright-Eyed View Of Legal AI's Future
Todd Itami at Covington offers a bright-eyed, laughing-all-the-way, skydive look at what the legal industry could look like after an artificial intelligence revolution, which he believes may happen much sooner and more dramatically than we expect.