Federal

  • July 10, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin included a revenue procedure to provide a gift tax reporting safe harbor for certain contributions to the new tax-advantaged brokerage accounts for newborns, known as Trump Accounts.

  • July 10, 2026

    IRS Defends Tax Court's Deduction In Arrest Injury Settlement

    The U.S. Tax Court correctly ruled that part of a man's $35,000 settlement payment from a Massachusetts town is deductible as damages paid for physical injuries, the IRS told the D.C. Circuit on Friday.

  • July 10, 2026

    US-Canada Stalemate Expected To Hold Amid USMCA Review

    The trade stalemate between the U.S. and Canada is likely to continue through a drawn-out review process for the U.S.-Mexico-Canada Agreement, though companies will benefit from an underlying level of stability as the deal remains in effect, trade lawyers said.

  • July 10, 2026

    Vague IRS Rules Should Nix Foreign Gift Penalties, Court Told

    A California civil service worker asked a federal court to waive penalties imposed by the IRS over her failure to report wedding gifts received from family in China, contending the agency was unclear about filing requirements.

  • July 10, 2026

    Taxation With Representation: Cleary, Paul Weiss, Fried Frank

    In this week's Taxation With Representation, Solstice Advanced Materials Inc. acquires specialty chemicals technology company Element Solutions Inc., Vertex Pharmaceuticals Inc. buys Crinetics Pharmaceuticals Inc., and Lockheed Martin acquires naval defense company Ultra Maritime.

  • July 09, 2026

    Judge Backs Feds' Valuation Method In Windfarm Grant Fight

    A U.S. Court of Federal Claims judge ordered several California wind farm owners and the federal government to largely employ a method the government proposed to value their facilities and hash out a decade-old dispute over grants worth hundreds of millions of dollars.

  • July 09, 2026

    Okla. Tax Officials Say McGirt Can't Upend Osage Ruling

    Oklahoma tax officials say the Osage Nation can't rely on a 2020 landmark U.S. Supreme Court ruling to overturn a decision that declined to vacate a 16-year-old determination that its reservation boundaries had been disestablished, telling the Tenth Circuit that the tribe's challenge is too late.

  • July 09, 2026

    IRS Asks 7th Circ. To Rehear $300M Hyatt Perks Tax Dispute

    The IRS asked the Seventh Circuit to reconsider its decision to remand a dispute over $300 million in Hyatt Hotels' loyalty rewards program fund to the U.S. Tax Court for it to determine whether the money can be excluded from taxable income under what's known as the claim of right doctrine.

  • July 09, 2026

    IRS Updates Outdated References In Estate Tax Rules

    The Internal Revenue Service released final regulations that modify and replace outdated references in rules for deceased taxpayers who have passed their property to a noncitizen spouse in a domestic trust.

  • July 09, 2026

    Reclassified Debt Didn't Cause $21M Gain, Partnership Says

    The IRS wrongly treated the reclassification of $21.1 million in debt to equity as a taxable event when hitting a partnership with $12.8 million in taxes, penalties and estimated interest, the partnership told the U.S. Tax Court.

  • July 09, 2026

    4th Circ. Rebuffs Tax Attys' Request To Rethink Convictions

    The Fourth Circuit will not rethink its decision last month affirming the convictions of two St. Louis attorneys accused of engineering a $22 million tax avoidance scheme.

  • July 09, 2026

    5 Clifford Chance Finance And Tax Attys Join Sidley In NY, DC

    Sidley Austin LLP announced Thursday that five Clifford Chance LLP attorneys have joined the firm's global finance and tax practices in New York and Washington, D.C.

  • July 09, 2026

    Pillar 2 Carveouts Won't Undercut Global Tax, Official Says

    The integrity of the 15% global minimum tax system will not be undermined by a host of nations gaining access to provisions that exempt them from certain obligations, the tax head at the Organization for Economic Cooperation and Development said Thursday.

  • July 08, 2026

    Partnership Defends $55.6M Deduction For Mo. Land Gift

    A partnership that donated over 73 acres in Butler County, Missouri, to a conservation group told the U.S. Tax Court it properly deducted $55.6 million for the gift, saying the value was based on the analysis of two qualified appraisers.

  • July 08, 2026

    IRS To Give Automatic Penalty Relief To Compliant Taxpayers

    Taxpayers with a history of filing and paying on time will no longer have to request penalty relief under an automatic exemption expected to roll out this summer, the IRS announced Wednesday.

  • July 08, 2026

    IRS Finalizes Life Insurance Reporting Exception Regs

    The Internal Revenue Service confirmed that certain tax-free transfers of life insurance contracts are exempt from the 2019 reporting rules for life settlement transactions, including policy sales and death benefit payments, under final regulations released Wednesday.

  • July 08, 2026

    IRS Urged To Make Digital Broker E-Statements Easier

    The IRS should update regulations that would allow digital asset brokers to provide statements electronically to remove operational hurdles and designate more effective communication methods, such as in-app messaging and SMS, stakeholders told the agency Wednesday.

  • July 08, 2026

    Shopping Center Owner's Estate Disputes $41M Deficiency

    The estate of a man who co-owned a Massachusetts shopping center challenged a $40.8 million deficiency assessment in the U.S. Tax Court, saying the IRS wrongly determined that a 2012 sale of his interest in the partnership owning the center wasn't bona fide.

  • July 08, 2026

    IRS Targets Certain Annuity Trusts As Potential Tax Shelters

    The IRS unveiled final rules Wednesday designating certain charitable remainder annuity trusts as reportable transactions because they involve abusive tax avoidance practices, subjecting participants to potential penalties if they do not disclose such arrangements.

  • July 08, 2026

    Foley Adds Attys From Kirkland, Goodwin To Corporate Team

    Foley & Lardner LLP has strengthened its corporate bench with a Dallas-based partner who came aboard from Kirkland & Ellis LLP and a Boston-based partner from Goodwin Procter LLP.

  • July 07, 2026

    2 Ex-Telehealth Execs Sentenced For $100M Adderall Scheme

    A California federal judge on Tuesday sentenced two former executives of a telehealth company who were convicted of operating a $100 million scheme to illegally distribute Adderall over the internet, fining them $1 million each and giving the founder six years in prison.

  • July 07, 2026

    DC Circ. Backs Tax Bribery Convictions Despite Jury Error

    A D.C. Circuit panel refused on Tuesday to reverse a lower court's judgments against two men in connection to a bribery scheme carried out to evade $2.3 million in business tax obligations, finding a jury instruction error "harmless," among other unsuccessful arguments.

  • July 07, 2026

    Dem Sens. Probe CEOs On Trump-IRS Settlement Immunity

    Three senior Democratic senators are investigating whether several companies with ties to President Donald Trump are benefiting from what they alleged was immunity for him, his family and his businesses in the settlement he reached with the Internal Revenue Service. 

  • July 07, 2026

    Exxon Seeks $324M Judgment In Dispute On Qatar Deal Tax

    Exxon asked a Texas federal court to rule that it's owed a $273 million tax refund and $51 million in penalties in a dispute with the U.S. government over the tax treatment of a natural gas deal with Qatar.

  • July 07, 2026

    IRS Denies Blowing Deadline In $34M Easement Dispute

    The IRS timely issued a notice of adjustment to a partnership claiming a $34 million easement deduction for its donation to a Cleveland historic preservation group, the agency told the U.S. Tax Court, arguing that the partnership is raising a frivolous contention in seeking to throw out the adjustment and penalties.

Expert Analysis

  • How The New Tariff Landscape May Unfold

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    To replace tariffs formerly imposed under the International Emergency Economic Powers Act, the administration will rely on a patchwork of statutes, potentially leading to procedural challenges and a complex tariff landscape with varying levels, durations and applicability, says Joseph Grossman-Trawick at King & Spalding.

  • What Orgs. Should Note In IRS Group Tax Exemption Overhaul

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    In a significant update, the IRS Revenue Procedure 2026-8 shows that the group exemption program is moving into a new regulatory era involving more uniformity, oversight and compliance obligations, and early action is key to preserve group exemption status and avoid disruption for subordinate organizations, says Ravi Sundara at Spencer Fane.

  • How Banks Can Apply FinCEN Beneficial Ownership Relief

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    A recent Financial Crimes Enforcement Unit order limiting the circumstances under which banks should identify and verify beneficial owners may allow banks to tailor their approach to verification compliance, but only after reviewing customer due diligence policies and evaluating alignment with their risk profiles, say attorneys at Cleary.

  • Parsing Clarifications On Foreign Entity Rules For Tax Credits

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    Recent U.S. Internal Revenue Service and Treasury Department guidance answers taxpayer questions on several key foreign entity rules under the One Big Beautiful Bill Act, but questions remain over transactions with companies that have ties to covered nations such as Iran, say attorneys at Cleary.

  • Aligning Microsoft Tools With NYC Bar AI Recording Guidance

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    The New York City Bar Association’s recently issued formal opinion, providing ethical guidance on artificial intelligence-assisted recording, transcription and summarization, raises immediate questions about data governance and e-discovery for companies that use Microsoft 365 and Copilot, say Staci Kaliner, Martin Tully and John Collins at Redgrave.

  • Preferred Equity Monetizations Unlock Energy Tax Credits

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    As private capital funds more energy and infrastructure projects, preferred equity monetization structures — combining elements of tax credit transfers and tax equity partnership-flip transactions with hybrid capital structures — can help project sponsors monetize federal tax credits, access private capital markets and gain structuring flexibility, say attorneys at Willkie.

  • 5 Different AI Systems Raise Distinct Privilege Issues

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    A New York federal court’s recent U.S. v. Heppner decision, holding that a defendant’s use of Claude was not privileged, only addressed one narrow artificial intelligence system, but lawyers must recognize that the spectrum of AI tools raises different confidentiality and privilege questions, says Heidi Nadel at HP.

  • After Learning Resources: A Practical Guide For US Importers

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    Following the U.S. Supreme Court's Feb. 20 decision in Learning Resources v. Trump, U.S. importers and consumers on whom tariffs were imposed under the International Emergency Economic Powers Act can seek relief through existing administrative procedures or a yet-to-be-determined bespoke refund mechanism, and should plan for more changes in the tariff landscape, say attorneys at Baker Botts.

  • AI-Assisted Arbitration Needs Safeguards To Ensure Fairness

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    As tribunals and arbitral institutions increasingly use artificial intelligence tools in their decision-making processes, ​​​​​​​clear disclosure standards and procedural safeguards are necessary to ensure that efficiency gains do not erode the fairness principles on which arbitration depends, says Alexander Lima at Wesco International.

  • AI-Generated Doc Ruling Guides Attys On Privilege Risks

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    A New York federal court's ruling, in U.S. v. Heppner, that documents created by a defendant using an artificial intelligence tool were not privileged, can serve as a guide to attorneys for retaining attorney-client or work-product privilege over client documents created with AI, say attorneys at Sher Tremonte.

  • The Law Firm Merger Diaries: Leadership Strategy After Day 1

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    For law firm leaders, ensuring a newly combined law firm lives up to its promise, both in its first days of operation and well after, includes tough decisions, clear and specific communication, and cheerleading, says Peter Michaud at Ballard Spahr.

  • 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.

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