Federal

  • June 08, 2026

    Developers Stumped By Energy Credits' Foreign Debt Limits

    Developers seeking to finalize projects financed with clean energy tax credits and several loans are hitting a roadblock in demonstrating to the IRS that their debt has limited ties to prohibited foreign entities, a requirement for qualifying for the incentives.

  • June 08, 2026

    McKesson Can't Defeat Valid Cost-Sharing Rules, Gov't Says

    The U.S. government urged a Texas federal court to uphold transfer pricing regulations that pharmaceutical giant McKesson is challenging in its push for a nearly $10 million tax refund, arguing the rules fall "well within the bounds" of the underlying statutory text.

  • June 08, 2026

    IRS Identity Theft Partnership Designates New Work Groups

    A public-private partnership between the Internal Revenue Service and the tax community to help crack down on tax-related identity theft is restructuring and creating new work groups to improve information sharing across the U.S. tax system to help crack down on such theft, the agency announced Monday.

  • June 05, 2026

    Calif.'s Global Reporting Bill Could Embolden Other States

    A California bill that would require multinational corporations to report their global profits could spark similar legislation across the U.S. if lawmakers of revenue-hungry states perceive shortcomings in federal and international efforts to tackle profit shifting.

  • June 05, 2026

    11th Circ. Lets Man Fight $2.2M FBAR Penalties As Excessive

    A Georgia federal court correctly found that the owner of a sports equipment business willfully failed to disclose his foreign bank accounts, but it must give him a chance to challenge $2.2 million in resulting penalties as excessive under the Eighth Amendment, the Eleventh Circuit said.

  • June 05, 2026

    IRS To Release Guidance On Tax-Exempt Org. Pay Excise Tax

    The IRS is planning to issue proposed guidance on the expanded 21% excise tax on excess compensation at tax-exempt organizations, including updated definitions that align with changes passed under Republicans' 2025 tax overhaul, according to a notice released Friday.

  • June 05, 2026

    Abbott Says Timing Mismatch Lets $8B Gain Go Untaxed

    Abbott Laboratories asked the U.S. Tax Court to find that it needn't recognize an $8 billion gain in 2020 from transactions between several of its controlled foreign corporations because of a mismatch in the effective dates of different sections of the 2017 U.S. Tax Cuts and Jobs Act.

  • June 05, 2026

    Judge Asks How FCC Ruling Affects $6.6M IRS Penalty Fight

    A Pennsylvania federal judge ordered briefing on how the U.S. Supreme Court's new decision upholding agency fines without a jury trial affects a $6.6 million tax penalty dispute, signaling potential reconsideration of last year's opinion in the case.

  • June 05, 2026

    Taxation With Representation: Simpson Thacher, Fried Frank

    In this week's Taxation With Representation, Berkshire Hathaway Inc. takes Taylor Morrison Home Corp. private, global real estate investment company Kennedy Wilson forms a residential joint venture with Netherlands pension services provider APG, and Wellington Management acquires Hartford Funds from insurer The Hartford.

  • June 05, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, included an extension for sponsors of certain defined contribution retirement plans to amend the plans to allow qualified long-term care distributions.

  • June 04, 2026

    Jury Hears Closings In Trial Over Alleged Tax Shelter Scheme

    Prosecutors told a Colorado federal jury Thursday that four individuals defrauded the government by using their businesses to help promote and sell abusive and illegal trust tax shelters, while the defendants argued they lacked knowledge of the alleged scheme and can't be held responsible.

  • June 04, 2026

    Bessent Mum On Details Of Trump-IRS Settlement

    Treasury Secretary Scott Bessent gave House Democrats few answers Thursday to their questions on the scope and limitations of President Donald Trump's settlement with the IRS over the leak of his tax data that includes an exemption from tax audits for Trump and members of his family.

  • June 04, 2026

    Tax Court Confirms IRS Computations In Easement Case

    A partnership, in objecting to IRS computations, improperly raised new arguments in a case where the U.S. Tax Court reduced a conservation easement deduction by over $10 million, the tax court said in upholding the agency's calculations, which included a 40% penalty.

  • June 04, 2026

    Feds Appeal Trade Court's Emergency Tariff Refund Order

    The federal government has appealed the U.S. Court of International Trade's order requiring refunds on all duties paid under the International Emergency Economic Powers Act after the U.S. Supreme Court struck them down this year, according to filings in the trade court and Federal Circuit.

  • June 04, 2026

    IRS To Hold Hearing On Trump Accounts In July

    The Internal Revenue Service will hold a public hearing July 16 on proposed rules related to the new tax-advantaged brokerage accounts for newborns called Trump accounts, the agency said Thursday.

  • June 04, 2026

    Ex-Surgeon Agrees To $7.7M Tax Bill From Offshore Scheme

    A retired plastic surgeon reached a $7.7 million settlement with the federal government to resolve an Internal Revenue Service case alleging that he ran an offshore employee leasing scheme, according to an agreement filed in an Ohio federal court.

  • June 04, 2026

    Californian's Crypto Staking Rewards Taxable, Tax Court Says

    A California man's cryptocurrency staking rewards, in the form of additional tokens for supporting a blockchain platform, are taxable income, a U.S. Tax Court judge ruled Thursday, saying he could have converted the tokens into cash at any time.

  • June 04, 2026

    Goldstein Seeks Sentencing Delay, Citing New Tax Claims

    SCOTUSblog founder Thomas Goldstein renewed his push Wednesday in Maryland federal court for a delayed sentencing, saying prosecutors blindsided his defense by including additional uncharged years of alleged tax avoidance in the government's sentencing memorandum.

  • June 04, 2026

    Blanche's AG Bid Could Face Rocky Path In Senate

    Acting Attorney General Todd Blanche will be tapped for the permanent role, but he might not have a smooth path to confirmation.

  • June 04, 2026

    Tax Court Didn't Err In Voiding $713M Deduction, IRS Says

    A real estate development partnership failed to show that the U.S. Tax Court made errors that undermined its ruling eliminating a $713 million deduction to the partnership for 2012, the IRS argued, saying the court shouldn't gratuitously decide issues that don't affect a case's disposition.

  • June 03, 2026

    Dems Press Bessent On 'Weaponization' Fund, Trump Audits

    Senate Democrats questioned Treasury Secretary Scott Bessent on Wednesday about details of a settlement that included a since-dropped plan for a $1.8 billion fund that could have been used to pay off Jan. 6 defendants and an exemption from IRS audits for President Donald Trump and members of his family.

  • June 03, 2026

    Texas Instruments Defends Deductions For Exercised Options

    Texas Instruments challenged total deficiencies of $47.9 million for 2018 and 2019, much of it from the IRS' disallowance of deductions for deferred compensation, such as exercised stock options, under an approach consistent with a 2022 agency advice memorandum.

  • June 03, 2026

    Purdue Pharma Heir Sues Son Over Sackler Matriarch's Estate

    Former Purdue Pharma LP President Richard Sackler has appealed a Connecticut probate court decision favoring his son David Sackler in a dispute over his mother Beverly Sackler's estate, saying a judge ignored self-dealing rules when approving his son's request to assign trust interests to a public charity.

  • June 03, 2026

    Goldstein Cites Addiction To Avoid Time, DOJ Seeks 8 Years

    Federal prosecutors recommended a 97-month prison sentence for convicted SCOTUSblog founder Thomas Goldstein, telling a Maryland federal court he has bilked the government out of more than $9.5 million in unpaid taxes. Goldstein, meanwhile, asked for a suspended sentence and supervised release, citing a "severe and longstanding gambling addiction."

  • June 03, 2026

    Graham Pushes Federal Tort Path After DOJ Drops $1.8B Fund

    The U.S. Department of Justice seemed, at least briefly, to support a Republican senator's alternative solution to the "anti-weaponization" $1.8 billion fund that acting Attorney General Todd Blanche said Tuesday the department is abandoning.

Expert Analysis

  • Calif.'s Civility Push Shows Why Professionalism Is Vital

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    The California Bar’s campaign against discourteous behavior by attorneys, including a newly required annual civility oath, reflects a growing concern among states that professionalism in law needs shoring up — and recognizes that maintaining composure even when stressed is key to both succeeding professionally and maintaining faith in the legal system, says Lucy Wang at Hinshaw.

  • US-Ukraine Reconstruction Fund Tax Exemptions Uncertain

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    Tax provisions in the bilateral agreement to establish the U.S.-Ukraine Reconstruction Investment Fund, which recently announced it is accepting applications, are so broad and imprecise as to leave uncertainty regarding whether and when tax exemptions will apply to investors' income, say attorneys at Avellum and Debevoise.

  • Trivia Competition Makes Me A Better Lawyer

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    Playing trivia taught me to quickly absorb information and recognize when I've learned what I'm expected to know, training me in the crucial skills needed to be a good attorney, and reminding me to be gracious in defeat, says Jonah Knobler at Patterson Belknap.

  • Judges On AI: Practical Use Cases In Chambers

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    U.S. Magistrate Judge Allison Goddard in the Southern District of California discusses how she uses generative artificial intelligence tools in chambers to make work more efficient and effective — from editing jury instructions for clarity to summarizing key documents.

  • What's At Stake In Possible Circuit Split On Medicaid Rule

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    A recent Eleventh Circuit decision, reviving Florida's lawsuit against a federal rule that reduces Medicaid funding based on agreements between hospitals, sets up a potential circuit split with the Fifth Circuit, with important ramifications for states looking to private administrators to run provider tax programs, say Liz Goodman, Karuna Seshasai and Rebecca Pitt at FTI Consulting.

  • Malpractice Claim Assignability Continues To Divide Courts

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    Recent decisions from courts across the country demonstrate how different jurisdictions balance competing policy interests in determining whether legal malpractice claims can be assigned, providing a framework to identify when and how to challenge any attempted assignment, says Christopher Blazejewski at Sherin & Lodgen.

  • Where PCAOB Goes Next After A Year Of Uncertainty

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    The Public Company Accounting Oversight Board will likely bring fewer enforcement matters in 2026, reflecting a notable change in board priorities following the change in administrations, say Robert Cox and Nicole Byrd at Whiteford Taylor and Matthew Rogers at Bridgehaven Consulting.

  • 5th Circ. Ruling Clarifies Tax Rules For Limited Partners

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    The Fifth Circuit’s Jan. 16 decision in Sirius Solutions v. Commissioner provides greater tax planning certainty by adopting a bright-line test for determining when partners in limited liability companies are exempt from self-employment tax, say attorneys at K&L Gates.

  • NYC Bar Opinion Warns Attys On Use Of AI Recording Tools

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    Attorneys who use artificial intelligence tools to record, transcribe and summarize conversations with clients should heed the New York City Bar Association’s recent opinion addressing the legal and ethical risks posed by such tools, and follow several best practices to avoid violating the Rules of Professional Conduct, say attorneys at Smith Gambrell.

  • 4 Quick Emotional Resets For Lawyers With Conflict Fatigue

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    Though the emotional wear and tear of legal work can trap attorneys in conflict fatigue — leaving them unable to shake off tense interactions or return to a calm baseline — simple therapeutic techniques for resetting the nervous system can help break the cycle, says Chantel Cohen at CWC Coaching & Therapy.

  • Rescheduling Cannabis Marks New Tax Era For Operators

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    As the attorney general takes steps to move cannabis from Schedule I to Schedule III of the Controlled Substances Act, operators and advisers should prepare by considering the significant changes this will bring from tax, state, industry and market perspectives, says Michael Harlow at CohnReznick.

  • Judges On AI: How Judicial Use Informs Guardrails

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    U.S. Magistrate Judge Maritza Dominguez Braswell at the U.S. District Court for the District of Colorado discusses why having a sense of how generative AI tools behave, where they add value, where they introduce risk and how they are reshaping the practice of law is key for today's judges.

  • Presidential Pardon Brokering Can Create Risks For Attys

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    The emergence of an apparent “pardon shopping” marketplace, in which attorneys treat presidential pardons as a market product, may invite investigative scrutiny of counsel and potential criminal charges grounded in bribery, wire fraud and other statutes, says David Klasing at The Tax Law Offices of David W. Klasing.

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