Federal

  • May 14, 2026

    Fed. Circ. Affirms $80M Penalty For Trust Caught In Tax Fraud

    A group of family trusts failed Thursday to convince the Federal Circuit to reverse a lower court ruling that held them liable for an $80 million tax bill after being conned by a fraudster who then engaged in abusive tax shelter transactions behind their backs.

  • May 14, 2026

    SC Co. Defends $24M Deduction For Ga. Land Donation

    A partnership based in South Carolina said the IRS erred in disallowing its $24 million deduction in 2019 for 122 acres donated to a conservancy in Georgia and in assessing a 40% penalty.

  • May 14, 2026

    Wyden Seeks June Vote For Bipartisan IRS Reform Bill

    The Senate Finance Committee's top Democrat would like his committee to vote as soon as next month on a bipartisan package that would implement several National Taxpayer Advocate-backed fixes at the Internal Revenue Service, he said Thursday.

  • May 14, 2026

    Gov't Asks 6th Circ. To Reverse FedEx's $89M Tax Credit Win

    The U.S. government urged the Sixth Circuit to reverse a Tennessee federal court's decision that invalidated foreign tax credit regulations and allowed FedEx an $89 million refund, arguing that the rules reflect Congress' intent to prevent windfalls under the 2017 tax overhaul.

  • May 14, 2026

    Corp. AMT Proposal Coming In February, Official Says

    The U.S. plans to propose its entire package of rules on the corporate alternative minimum tax — which has so far been the subject of five Internal Revenue Service notices — in February, an official from the U.S. Department of the Treasury said Thursday.

  • May 14, 2026

    'Pig Butchering' Crypto Scam Victim Seeks $962K From IRS

    An Ohio man told a district court that the Internal Revenue Service wrongly denied his tax deduction claim for a loss of over $800,000 from a cryptocurrency "pig butchering" scheme despite the extensive documentation of the fraud he said he provided to the agency.

  • May 13, 2026

    Lawmakers Float Allowing Charitable Gifts From 401(k) Plans

    A bipartisan group of federal lawmakers on Wednesday introduced a bill that would allow workers to make tax-free charitable donations directly from their employer-sponsored retirement plans, building on a section of the retirement policy overhaul known as Secure 2.0.

  • May 13, 2026

    Meta Must Share Option Costs Post-Altera, IRS Says

    The Ninth Circuit's 2019 ruling against Altera Corp., which upheld rules requiring companies to share the cost of employee stock options with foreign affiliates, means that Meta's income for 2017-18 should be increased by roughly $3 billion, the IRS told the U.S. Tax Court.

  • May 13, 2026

    Tax Bill Challenge Filing Deadline Is Flexible, 4th Circ. Told

    A man who missed the deadline for challenging his tax bill in the U.S. Tax Court urged the Fourth Circuit to revive his suit, saying the statutory cutoff for filing petitions does not have to be strictly followed in every case.

  • May 13, 2026

    DOJ Fraud Division Set To Shake Up White-Collar Enforcement

    President Donald Trump's administration created the U.S. Department of Justice's National Fraud Enforcement Division with a narrow focus on combating government program fraud, but a move to retain federal prosecutors focused on other types of fraud could signal a wider scope with potential ripple effects across white-collar enforcement.

  • May 13, 2026

    Accendra Pays $19M To Settle IRS Transfer Pricing Matter

    Accendra Health Inc. paid $19 million to the Internal Revenue Service to conclude tax matters related to international transfer pricing activity between 2015 and 2018, according to a recent earnings call with investors.

  • May 13, 2026

    Trump 1st-Term Tariff Hikes On China Legal, Feds Tell Justices

    President Donald Trump's first administration was well within its legal authority to increase tariffs on Chinese goods under a law utilized to address unfair trading practices, and the U.S. Supreme Court doesn't need to consider a challenge to those measures, the government told the justices.

  • May 13, 2026

    Tax Court Won't Rethink Nix Of Russian Scientist's Exemption

    The U.S. Tax Court won't rethink its decision that the U.S. Department of Energy's payments to a Russian scientist for his subatomic particle research in Virginia don't fall under a tax exemption for grants in the U.S.-Russia tax treaty.

  • May 13, 2026

    IRS Offers Easement Deals With 10% Penalty, No Haggling

    Eligible partnerships disputing conservation or historic preservation easement charitable deductions cannot negotiate their tax benefit amounts under the Internal Revenue Service's latest settlement offer, which carries a 10% penalty, the agency announced Wednesday.

  • May 12, 2026

    SCOTUSblog Founder Can't Delay Tax Fraud Sentencing

    A Maryland federal judge has rejected SCOTUSblog founder Thomas Goldstein's request to push back sentencing for his tax evasion conviction, finding that Goldstein "has not shown good cause to continue sentencing."

  • May 12, 2026

    Ga. Partnership Defends $46M Deduction For Donated Acres

    A Georgia partnership is disputing the IRS' assessment of $17.1 million in underpaid tax and $6.8 million penalties for its 2020 tax year, saying the agency wrongly disallowed its $46.2 million deduction for a charitable contribution of over 337 acres.

  • May 12, 2026

    9th Circ. Orders New Tax Fraud Trial Over Juror's Racial Bias

    An Idaho federal court wrongly denied a man of Mexican descent a new trial after discovering a juror had made racially biased comments about people of Mexican ethnicity during deliberations on whether to convict him of preparing false tax returns, a split Ninth Circuit panel said Tuesday.

  • May 12, 2026

    US Asks Court To Reject Bright-Line IRS Political Activity Test

    A D.C. federal court should not set a bright-line test for determining whether tax-exempt social welfare organizations are engaging in improper political campaigning, the federal government said during a hearing Tuesday, in a case in which the court previously said the existing test was too vague.

  • May 12, 2026

    Ala. Partnership Says Donated Land Was Worth $21M

    An Alabama partnership defended its deduction of $21 million for land donated to a conservancy in Mobile in 2018, saying it was told by a qualified appraiser that the property's "highest and best use" would have been as a residential development.

  • May 12, 2026

    New Precedent Revives $6.6M IRS Penalty Fight, Broker Says

    An insurance broker asked a Pennsylvania federal court to consider new constitutionality arguments against the IRS penalty prepayment requirement to revive its challenge to $6.6 million in captive insurance tax penalties, arguing those claims rely on new legal precedent.

  • May 12, 2026

    Over 8 Million Imports In Line For Over $35B In Tariff Refunds

    Over 8.3 million imports are pending tariff refunds after clearing the final system processes developed by Customs and Border Protection, accounting for almost $35.5 billion in duty refunds with interest, according to the latest declaration filed Tuesday by an agency official in the U.S. Court of International Trade.

  • May 12, 2026

    Fed. Circ. Pauses Trade Court Ruling Blocking Trump Tariffs

    The Federal Circuit halted a permanent injunction issued by the U.S. Court of International Trade that was scheduled to take effect on Tuesday, which would have stopped the collection of duties under President Donald Trump's temporary global tariff from two businesses and the state of Washington.

  • May 11, 2026

    Trump Asks Federal Circuit To Pause Trade Court Tariff Ruling

    President Donald Trump on Monday asked the Federal Circuit to block the U.S. Court of International Trade's order last week deeming his temporary global 10% tariffs unlawful, arguing the trade court misinterpreted the legislative history of the Trade Act.

  • May 11, 2026

    Ex-Spouse Facing Arrest For Ghosting $2.9M Tax Refund Suit

    The ex-husband of a woman seeking a $2.9 million tax refund for carryback losses she shared with him is facing a possible arrest warrant and other penalties for repeatedly failing to comply with federal district court orders, a Texas judge said Monday.

  • May 11, 2026

    APA Results Should Make Sense Annually, IRS Official Says

    Taxpayers seeking advance pricing agreements with the Internal Revenue Service will now be expected to have the results of an agreed-upon transfer pricing method comply with the method on an annual basis rather than only over the multiple years covered by the APA, an IRS official said Monday.

Expert Analysis

  • Hungary CPAC Funding Probe Could Implicate US Entities

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    A Hungarian anti-corruption investigation into claims that the former prime minister used taxpayer funds to support the Conservative Political Action Conference could include potential cross-border political and financial dimensions that create multiple touchpoints for U.S. regulatory and enforcement interest, say attorneys at Ballard Spahr.

  • Mitigating Multistate Risks As California Expands Tax Reach

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    Though California's new sourcing rules and extension of the pass-through entity election have created uncertainty, practitioners should file protective returns to respect the law's ambiguity and take certain other steps to protect clients from the costs of losing a future audit, says attorney Delina Yasmeh.

  • E-Discovery Quarterly: Recent Rulings On ESI Control

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    Several recent federal court decisions have perpetuated a split over what constitutes “control” of electronically stored information — with judges divided on whether the standard should turn on a party's legal right or practical ability to obtain the information, say attorneys at Sidley.

  • Anticipating The Justices' Potential Ruling On Tax Takings

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    Recent oral arguments in the U.S. Supreme Court case Pung v. Isabella focused on rules for valuation, timing and administrability of tax auction proceeds and whichever method the court adopts for determining just compensation, it will have far-reaching impacts on tax collection, homeowners' equity and the secondary market for tax-foreclosed property, say attorneys at Holland & Knight.

  • 2 Discovery Rulings Break With Heppner On AI Privilege Issue

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    While a New York federal court’s recent ruling in U.S. v. Heppner suggests that some litigants’ communications with AI tools are discoverable, two other recent federal court decisions demonstrate that such interactions generally qualify for work-product protection under the Federal Rules of Civil Procedure, says Joshua Dunn at Brown Rudnick.

  • CBP's $166B Tariff Refund Portal Needs 4 Safeguards

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    Before launching its automated web portal to process tariff-refund disbursements on April 20, U.S. Customs and Border Protection should apply the expensive lessons learned from the pandemic-era employee retention credit, says Peter Gariepy at RubinBrown.

  • How Developers Can Leverage The New Markets Tax Credit

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    An increased regulatory focus on affordable housing raises important legal considerations for structuring transactions using the oft overlooked New Markets Tax Credit, which can fill a gap in affordable for-sale housing financing by lowering community developer costs but comes with unique compliance, structuring and documentation demands, say attorneys at Stinson.

  • Calculating Damages In IEEPA Tariff Refund Litigation

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    To calculate damages in the spate of refund litigation triggered by the U.S. Supreme Court's recent decision invalidating tariffs collected under the International Emergency Economic Powers Act, the central question will be how to determine where in the supply chain their economic burden ultimately came to rest, say analysts at Charles River Associates.

  • Alpine Skiing Makes Me A Better Lawyer

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    Skiing has shaped habits I rely on daily as an attorney — focus, resilience and the ability to remain steady when circumstances shift rapidly — and influences the way I approach legal strategy, client counseling and teamwork, says Isaku Begert at Marshall Gerstein.

  • What A Court Doc Audit Reveals About Erroneous Filings

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    My audit of 1,522 court documents from last month found that over 95% contained at least one verifiable error, with fewer than 1% showing clear indicators of artificial intelligence use — highlighting above all else that lawyers may want to focus most on strengthening their review processes, says Elliott Ash at ETH Zurich.

  • Mich. Banking Brief: All The Notable Legal Updates In Q1

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    Michigan's financial services sector saw several significant developments in 2026's first quarter, including the state Department of Insurance and Financial Services' issuance of a bulletin on the use of artificial intelligence and the Michigan House's introduction of a bill based on the Model Money Transmission Modernization Act, say attorneys at Dykema.

  • Navigating The Perks Of Qualified Opportunity Zones 2.0

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    The second iteration of the qualified opportunity zone program, effective Jan. 1, 2027, will introduce new tax incentives for rural real estate development, but these benefits can only be realized if proper governance is a priority, including clear documentation and securities law compliance, says Coni Rathbone at VF Law.

  • Getting The Most Out Of Learning And Development Programs

    Excerpt from Practical Guidance
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    Junior associates can better develop the legal, business and interpersonal skills they need for long-term success by approaching their firms’ learning and development programs armed with five tips for getting the most out of these resources, says Lauren Hakala at Reed Smith.

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