Federal

  • January 07, 2026

    Tax Funding Oil Spill Cleanups Has Expired, IRS Clarifies

    The Internal Revenue Service clarified Wednesday that the part of an added tax on crude oil and petroleum products earmarked for an oil spill cleanup fund expired at the end of 2025.

  • January 07, 2026

    Feds Want To Use Goldstein's Comments To NYT At Trial

    Federal prosecutors preparing to try SCOTUSblog founder Tom Goldstein for tax crimes next week are looking to use his comments in a New York Times Magazine article against him, claiming that admissions and details from the article "directly prove" certain charges the government has brought.

  • January 07, 2026

    IRS Mulling Budget Bill's Changes To CFC Rules, Official Says

    The Internal Revenue Service is weighing a balance between precision and administrability as it works on guidance for U.S. shareholders of foreign companies after the federal budget bill changed how to allocate overseas income, an agency official said Wednesday.

  • January 07, 2026

    IRS Outlines Process For PFICs Seeking Retroactive Elections

    The Internal Revenue Service set out requirements Wednesday for passive foreign investment corporations seeking rulings to allow them to make retroactive qualified electing fund elections.

  • January 06, 2026

    Ex-Moving Co. Exec Denied New Trial In $8M Payroll Tax Case

    A former moving company president who was convicted of scheming to defraud the Internal Revenue Service out of nearly $8 million in payroll taxes cannot get his verdict vacated, a New York federal court ruled, denying his claim of ineffective counsel as untimely.

  • January 06, 2026

    Tax Groups Push Supreme Court On California Tax Rule

    A special income tax rule California uses along with its single-sales-factor apportionment method creates distortion and the U.S. Supreme Court should decide if it also violates the constitution, a taxpayer group said Tuesday.

  • January 06, 2026

    Tax Court Tosses $189K Charity Deduction For Lack of Proof

    A California couple is not entitled to deduct nearly $189,000 for thousands of items they donated to a charity, the U.S. Tax Court ruled Tuesday, finding they failed to provide sufficient documentation to substantiate the value of the donated goods.

  • January 06, 2026

    Tax Court Strips Exempt Status From Powdered Milk Donor

    An organization that sent powdered milk donations for children overseas was mostly running a commercial coffee shop and was therefore not entitled to tax-exempt status, the U.S. Tax Court said Tuesday, agreeing with the Internal Revenue Service.

  • January 06, 2026

    IRS Appeals Pause Of ICE Info-Sharing Agreement

    The Internal Revenue Service is appealing to the D.C. Circuit a federal court order temporarily stopping the agency from sharing confidential taxpayer addresses with immigration enforcement officials, according to a filing Tuesday in D.C. federal court.

  • January 06, 2026

    Tax Firm Says IRS Can't Justify Microcaptive Reporting Rules

    A global tax services provider urged a Texas federal court to vacate tax reporting rules for microcaptive insurance companies, arguing that the Internal Revenue Service failed to provide evidence of tax evasion that would justify the regulations.  

  • January 06, 2026

    Paul Hastings Adds Ex-Cravath Tax Pro To Growing M&A Team

    After adding 20 partners to its mergers and acquisitions platform over the past two years, Paul Hastings LLP announced on Tuesday that it has hired a former Cravath Swaine & Moore LLP partner who advises on the tax elements of mergers and acquisitions.

  • January 05, 2026

    Feds Fight To Keep Goldstein 'Sham Employee' Evidence

    Federal prosecutors heading to trial against former SCOTUSblog publisher Tom Goldstein are urging a judge to deny his bid to prevent a jury from hearing about four love interests allegedly paid as no-show employees at his former law firm.

  • January 05, 2026

    ​'Truly Extreme': 9th Circ. Judges Decry Trump Layoffs Ruling

    The Ninth Circuit on Monday refused to revisit a three-judge panel's decision rejecting the Trump administration's challenge of a lower court's ruling requiring production of its plans for large-scale layoffs and reorganizations at various federal agencies, a decision that was met with fiery dissent from several of the court's Republican-appointed judges.

  • January 05, 2026

    3rd Circ. Won't Rethink Tax On Interest In $191M Pharma Deal

    The Third Circuit declined to reconsider its decision that a pharmaceutical company's $191 million payment settling a family feud was for the sale of a family trust's ownership shares and included interest that should be taxed as ordinary income.

  • January 05, 2026

    Partnership Fights Axed $60M Tax Break For Conservation Gift

    A partnership challenged the IRS' denial of its nearly $60 million tax deduction for protecting forestland and other open space in Georgia, telling the U.S. Tax Court the land could have been used for valuable granite mining before the partnership stopped it from being developed.

  • January 05, 2026

    Countries Reach Deal To Exempt US From Pillar 2 Tax

    Nearly 150 countries finalized the details Monday of a safe harbor that would effectively exempt U.S. companies from a 15% global minimum tax known as Pillar Two, following months of international negotiations and retaliatory tax threats from the U.S.

  • January 05, 2026

    Gibson Dunn Adds Sidley Tax Pro In Silicon Valley

    Gibson Dunn & Crutcher LLP announced Monday that it has bulked up its tax practice group with a partner in Palo Alto, California, who previously co-led the global tax practice and headed up the West Coast tax group at Sidley Austin LLP.

  • January 05, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, dated Monday, included guidance for new tax relief for farmers who pay capital gains tax on a farmland property sale to another farmer.

  • January 02, 2026

    Ga. Partnership Contests Denial Of $15.7M Property Donation

    A Georgia partnership invoked the Fifth Amendment in defending its $15.7 million conservation easement tax deduction in the U.S. Tax Court, arguing that the IRS in denying the deduction effectively is taking private property for public use without just compensation.

  • January 02, 2026

    Busy DOJ Tax Atty Seeks More Time In 7th Circ. AbbVie Case

    A U.S. Department of Justice tax attorney asked the Seventh Circuit on Friday for another extension to file an opening brief in a dispute over AbbVie's $1.6 billion payment to an Irish biotechnology company, citing staffing shortages and internal procedural requirements.

  • January 02, 2026

    IRS Floats 50% Personal-Use Test For Car-Loan Tax Break

    Individuals, trusts and estates could claim up to $10,000 for the new auto-loan interest deduction only if the vehicle was used more than 50% of the time for personal purposes under proposed regulations published Friday by the IRS.

  • January 02, 2026

    IRS Floats Updates To Fee Paid By Brand Drugmakers

    The Internal Revenue Service floated updates to regulations governing how branded prescription drug manufacturers or importers should calculate an annual fee established by the Affordable Care Act, a move the agency said aims to incorporate changes in drug discount programs and clarify tax reporting.

  • January 02, 2026

    Guns, Taxes & Labor: Cannabis Litigation Trends To Watch

    In 2026, courts throughout the U.S. will consider cases weighing Second Amendment rights of cannabis users, a punitive federal tax policy that affects state-legal marijuana businesses, labor peace requirements in the cannabis space, and whether a constitutional doctrine bars states from preferencing their residents in doling out marijuana licenses.

  • January 02, 2026

    Federal Tax Policy To Watch In 2026

    Changes to federal tax policy are relatively uncommon in midterm election years as lawmakers, many of whom prioritize political positioning over major tax overhauls, show little appetite for sweeping legislation or even narrower fixes that could attract bipartisan support. Here, Law360 examines federal tax policy to watch in 2026.

  • January 02, 2026

    Top Federal Tax Cases To Watch In 2026

    The application of self-employment taxes to limited partners, the economic substance doctrine's threshold and the question of whether IRS penalties need a jury's deliberation are topics federal courts likely will examine in coming decisions. Here, Law360 reviews the top federal tax cases to watch in the coming year.

Expert Analysis

  • How Attys Can Use A Therapy Model To Help Triggered Clients

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    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.

  • 3 Steps For In-House Counsel To Assess Litigation Claims

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    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.

  • IRS And ICE Info Sharing Could Drive Payroll Tax Enforcement

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    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.

  • Adapting To Private Practice: From DOJ Enviro To Mid-Law

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    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.

  • Legal Ethics Considerations For Law Firm Pro Bono Deals

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    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.

  • 10 Arbitrations And A 5th Circ. Ruling Flag Arb. Clause Risks

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    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.

  • Notable Q1 Updates In Insurance Class Actions

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    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.

  • Power To The Paralegals: The Value Of Unified State Licensing

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    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.

  • 10 Soft Skills Every GC Should Master

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    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.

  • An Unrestrained, Bright-Eyed View Of Legal AI's Future

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    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.

  • Tracking The Evolution In Litigation Finance

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    Despite continued innovation, litigation finance remains an immature market with borrowers recieving significantly different terms as lenders learn to value cases, which firms need a strong handle on to ensure lending terms do not overwhelm collateral value, says Robert Wilkins at Lightfoot Franklin.

  • E-Discovery Quarterly: The Perils Of Digital Data Protocols

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    Though stipulated protocols governing the treatment of electronically stored information in litigation are meant to streamline discovery, recent disputes demonstrate that certain missteps in the process can lead to significant inefficiencies, say attorneys at Sidley.

  • Maximizing Exemptions Before TCJA Rides Into The Sunset

    Excerpt from Practical Guidance
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    Individuals with taxable estates can optimize the benefits of estate planning strategies like spousal lifetime access trusts by setting them up before increases in estate and gift tax exemptions under the 2017 Tax Cuts and Jobs Act sunset in January, say attorneys at Katten.

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