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Federal
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June 12, 2026
Court Partly Dismisses Co.'s COVID Credit Reg Challenge
A company that provides payroll services to healthcare providers failed to prove it was entitled to injunctive relief that would bar the IRS from enforcing guidance on the employee retention tax credit, an Ohio federal court said, dismissing three of the company's claims.
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June 12, 2026
2nd Circ. Doubts Tax Plea Advice Misled Man On Deportation
A skeptical Second Circuit judge on Friday told a Connecticut attorney to stop saying his client was "affirmatively misled" while pleading guilty to tax evasion charges, hinting a written plea agreement and verbal warnings from a federal judge were probably sufficient to advise the client he could be deported.
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June 12, 2026
Global Minimum Tax Was A Bad Bargain, Tax Pros Say
The global minimum tax known as Pillar Two had the paradoxical goal of increasing countries' taxing power by having them cede some of their authority to set corporate rates — and ultimately would have hurt both wealthy and developing nations, tax specialists said at a conference Friday.
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June 12, 2026
4 Questions As Gov't Appeals Illegal Tariff Refund Suit
The government's appeal of an order requiring immediate refunds for tariffs that were deemed illegal by the U.S. Supreme Court earlier this year is the latest obstacle for importers forced to stall investments in new products and brace for a longer wait for their refunds in response.
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June 12, 2026
IRS Must Revisit Whistleblower Award Denial, DC Circ. Rules
The D.C. Circuit said Friday that the Internal Revenue Service must reconsider a whistleblower's claim that her information helped the agency collect taxes on more than $31 million in corporate income, reversing a U.S. Tax Court ruling that sided with the IRS.
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June 12, 2026
Biz Groups Back Liberty Global In $2.4B Tax Substance Fight
The Tenth Circuit should reconsider its decision denying telecommunications company Liberty Global a $2.4 billion income deduction, the U.S. Chamber of Commerce and other groups said, arguing the court excessively broadened a rule that is meant to disallow tax benefits in limited situations.
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June 12, 2026
Fox Rothschild Hires Tax Atty From McDermott In DC
Fox Rothschild LLP has hired a former tax attorney from McDermott Will & Schulte LLP who is bringing his advisory practice focused on sophisticated tax planning and structuring matters to the Washington, D.C., team, the firm announced Thursday.
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June 12, 2026
Judge Demands Proof $1.8B Trump Settlement Fund Is Dead
A Virginia federal court judge ordered the federal government Friday to submit in writing that it won't create a $1.8 billion payment fund to settle President Donald Trump's tax leak suit against the Internal Revenue Service.
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June 12, 2026
Taxation With Representation: Gibson Dunn, Davis Polk, S&C
In this week's Taxation With Representation, SpaceX prices a $75 billion initial public offering at its designated price range, Apollo Global Management leads a capital commitment for a Broadcom initiative to build artificial intelligence infrastructure for companies including Anthropic, and pharma giant GSK acquires cancer therapy specialist Nuvalent.
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June 12, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included guidance clarifying that proposed rules from 2025 regarding foreign sovereign wealth fund investment in the U.S. would not apply retroactively to the existing holdings of foreign governments.
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June 11, 2026
Revised Microcaptive Rules Still Violate APA, 6th Circ. Told
A microcaptive insurance advisory firm asked the Sixth Circuit on Thursday to overturn a Tennessee federal court's ruling that a set of revised IRS rules requiring taxpayers to disclose some microcaptive arrangements doesn't violate the Administrative Procedure Act.
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June 11, 2026
Fed. Circ. Pauses Trade Court's Limited Block Of Global Tariffs
The Federal Circuit halted a U.S. Court of International Trade ruling prohibiting the government from collecting temporary global tariffs on two retailers and the state of Washington while it considers whether those duties are lawful, according to an order Thursday.
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June 11, 2026
Investors Say Energy Co. Sold Fraudulent Tribal Tax Credits
Two investors accused an energy company of selling them fraudulent tax shelters marketed as tribal tax credits for $600,000 in a complaint filed in an Arkansas federal court.
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June 11, 2026
Auto Parts Biz Says Freight Co. Duped It Into Container Fraud
A Michigan-based importer and seller of aftermarket auto parts that was stuck with added costs from U.S. Customs and Border Protection related to empty shipping containers has sued its freight-forwarding contractor, claiming it was tricked into facilitating a fraud scheme.
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June 11, 2026
Senate Bill Would Increase Stock Buyback Tax
A 4% excise tax would be imposed on stock buybacks under legislation introduced by several high-ranking Senate Democrats, including Senate Minority Leader Chuck Schumer, on Thursday.
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June 11, 2026
FedEx Tells 6th Circ. Recent Rulings Back $89M Tax Refund
FedEx's case for an $89 million tax refund is supported by a decision in the U.S. Tax Court that outlined a formula for disallowing foreign tax credits and a Sixth Circuit decision about how to view the purpose of tax legislation, the company told the Sixth Circuit.
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June 11, 2026
Man Agrees To $10M Tax Bill Over Unreported Biz Income
A man found to have received income by using his company's cash as his own is on the hook for approximately $10.4 million in taxes and penalties, according to agreed-upon computations the taxpayer and the U.S. government filed in the U.S. Tax Court.
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June 10, 2026
4 Key Questions Surrounding US Forced Labor Tariff Rates
New proposed U.S. tariffs meant to address goods tied to forced labor are likely to create new administrative burdens for importers, from new compliance hurdles domestically to the potential for retaliatory measures by trading partners on U.S. goods shipped abroad, attorneys told Law360.
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June 10, 2026
Income Tax Underpayment Due To Fraud, Tax Court Rules
A couple's income tax underpayment stemmed from fraud, the U.S. Tax Court said in an order Wednesday, affirming the Internal Revenue Service's income tax deficiencies and civil fraud penalties.
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June 10, 2026
Treasury Previews Guidance For Scholarship Tax Credit
Guidance is coming soon on a new federal scholarship tax credit to help prepare for its planned launch at the start of 2027, including definitions of certain terminology and certain reporting requirements, the U.S. Department of the Treasury said Wednesday.
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June 10, 2026
IRS Lists Counties Eligible For Energy Community Credit
The Internal Revenue Service on Wednesday provided a list of eligible energy communities that can claim the Inflation Reduction Act's energy community bonus credit.
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June 10, 2026
Amgen Can't Amend Petition To Address Potential Double Tax
Drugmaker Amgen isn't entitled to amend its petition to protect against possible double taxation after an eight-week trial and briefing in its income-allocation case already have been completed, the U.S. Tax Court said, noting that the trial concluded in January 2025.
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June 10, 2026
Former Sen. Tim Scott Staffer Joins K&L Gates In DC
A former committee staff director for U.S. Sen. Tim Scott, R-S.C., has been hired at K&L Gates LLP, the firm announced Wednesday, following her time as a senior vice president with a bipartisan government relations and lobbying firm.
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June 10, 2026
AI Startup Says Worker Must Arbitrate Misclassification Suit
A hiring startup that supplies workers to train artificial intelligence models for OpenAI, Anthropic and Meta urged a Texas federal judge to send a proposed class action alleging worker misclassification to individual arbitration, arguing the named plaintiff signed seven agreements requiring it.
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June 10, 2026
Perkins Coie Atty Talks Tax Law 'Tension' In Data Center REITs
A real estate investment trust can be an attractive business model for data centers, but complying with federal REIT rules is tricky for properties with digital infrastructure, given their unique needs, according to a Perkins Coie LLP partner.
Expert Analysis
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After Learning Resources: A Practical Guide For US Importers
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.
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AI-Assisted Arbitration Needs Safeguards To Ensure Fairness
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.
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AI-Generated Doc Ruling Guides Attys On Privilege Risks
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.
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The Law Firm Merger Diaries: Leadership Strategy After Day 1
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.
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Calif.'s Civility Push Shows Why Professionalism Is Vital
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.
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US-Ukraine Reconstruction Fund Tax Exemptions Uncertain
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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Trivia Competition Makes Me A Better Lawyer
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.
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Judges On AI: Practical Use Cases In Chambers
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.
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What's At Stake In Possible Circuit Split On Medicaid Rule
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.
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Malpractice Claim Assignability Continues To Divide Courts
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.
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Where PCAOB Goes Next After A Year Of Uncertainty
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.
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5th Circ. Ruling Clarifies Tax Rules For Limited Partners
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.
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NYC Bar Opinion Warns Attys On Use Of AI Recording Tools
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.