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Federal
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July 17, 2026
Oil Co. Asks Tax Court To Make Additional Tax Credit Claim
An energy company that the U.S. Tax Court allowed to give up the normal carryback period for its net operating losses without waiving the 10-year period for specified liability losses wants the court to amend its claim to include a higher foreign tax credit.
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July 17, 2026
Taxation With Representation: Freshfields, Slaughter And May
In this week's Taxation With Representation, Uber Technologies Inc. buys food delivery company Delivery Hero SE, engineering group ABB Ltd. acquires flow technology company Rotork PLC, and Eli Lilly and Co. buys drug developer AtaiBeckley Inc.
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July 17, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included an update to the list of Native American tribes that have settled tribal trust cases with the federal government for tax purposes.
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July 16, 2026
11th Circ. Affirms Quarry Valuation Sank $23M Easement Perk
A 103-acre tract's best alternative use is not an aggregate quarry, the 11th Circuit ruled, rejecting the valuation that supported a partnership's $23 million deduction claim for donating the Georgia property as a conservation easement.
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July 16, 2026
Tile Importer Adds To Tax Dispute Over Captive Arrangement
A New York glass tile importer that had challenged IRS income adjustments of $4.8 million for 2018 through 2020 related to its captive insurance program added a fourth year to its dispute, saying the agency erred in increasing its income by $1.2 million for 2021.
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July 16, 2026
Meta Says Altera Ruling Doesn't Control In Stock Option Fight
The Ninth Circuit's 2019 ruling against Altera, which upheld an IRS regulation requiring companies to share the cost of stock options in joint ventures with foreign affiliates, has no bearing on Meta Platforms' dispute over the same issue, the social media company told the U.S. Tax Court.
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July 16, 2026
Tax Filers Seek Class Cert. In Google Privacy Suit
Online tax return filers who alleged Google's tracking tool effectively eavesdropped on their confidential tax information asked a California federal judge to certify several classes in their suit against the search giant.
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July 16, 2026
US Needs Digital Asset Tax Framework, Treasury Picks Say
Congress needs to take steps to create a tax structure for the digital asset market, two of President Donald Trump's picks to serve in U.S. Treasury Department posts told the Senate Finance Committee during a hearing Thursday.
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July 16, 2026
Senate Democrats Revive Bill To End Federal Marijuana Ban
Senate Democrats on Thursday once again reintroduced a cannabis legalization bill that would remove the drug entirely from the ambit of the Controlled Substances Act and impose a tax-and-regulate scheme akin to what is currently in place for alcohol and tobacco.
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July 16, 2026
Nonprofit Can Proceed In $1M Employee Tax Refund Fight
A Mississippi federal judge allowed an economic development nonprofit to continue challenging the IRS' denial of more than $1 million in employee retention tax credits, while dismissing its request for a declaratory judgment that the employer is entitled to the incentives.
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July 16, 2026
Ashurst Perkins Adds Tax Pro In LA From Stradling Yocca
Ashurst Perkins Coie announced Thursday that it has bolstered its tax practice with a Los Angeles-based partner who came aboard from Stradling Yocca Carlson & Rauth PC.
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July 16, 2026
USTR Broadens Exemptions Ahead Of 25% Brazil Tariff
A 25% tariff on Brazilian goods will begin next week with an expanded exemption list following public comments on the action, U.S. Trade Representative Jamieson Greer announced.
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July 15, 2026
Circuit-By-Circuit Guide To The US Supreme Court's Term
Federal appeals courts had wide-ranging successes and struggles during the U.S. Supreme Court's recently completed term: One had its best showing in years following its worst showing in years; one felt déjà vu after recently starting to find favor with the justices; and one saw its reputation for independence occupy a rare role in the Supreme Court spotlight.
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July 15, 2026
Eaton Says IRS Position Turns 'Arm's Length' On Its Head
The IRS' argument in support of its income allocations to Eaton Corp. from an Irish affiliate effectively inverts the arm's-length standard underlying U.S. transfer pricing law, seeking to price transactions between related companies by assuming non-arm's-length behavior, the company told the U.S. Tax Court.
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July 15, 2026
CIT Judge Says Order Incoming For Next Tariff Refund Phase
The U.S. Court of International Trade judge overseeing U.S. Customs and Border Protection's development of a duty refund system for tariffs struck down by the U.S. Supreme Court forecast new directions for the government as it prepares another phase of its tariff refund system, according to an order published Wednesday.
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July 15, 2026
Siemens Wins Tax Deduction In IRS Rules Mismatch Case
Siemens Medical Solutions is allowed the full dividends-received deduction it claimed for 2019, the U.S. Tax Court held Wednesday, throwing out an IRS regulation that attempted to reduce the deduction by aligning the effective date of different provisions under 2017 tax legislation.
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July 15, 2026
Judge Won't Revive Feds' $24M Tax Case Against NC Couple
A North Carolina federal judge refused to reconsider his decision that the federal government's bid to collect on what it claimed was a couple's $24 million tax bill came too late, saying the government failed to show that the ruling should be changed.
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July 15, 2026
Tax Court Slashes Ala. Easement Writeoff By Tens Of Millions
An Alabama partnership massively overstated the value of a claimed conservation easement deduction, the U.S. Tax Court found Wednesday, cutting the claimed $42.2 million deduction to $800,000 when properly considering the use of the property.
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July 15, 2026
Fed. Circ. Gives Pa. Biz A 2nd Go At $1.5M Tax Penalty Refund
The Federal Circuit gave a Pennsylvania electrical contractor another chance to pursue a $1.53 million refund claim for penalties paid to the Internal Revenue Service after its owner pled guilty to criminal tax evasion, according to an opinion published Wednesday.
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July 15, 2026
Tax Code Allows Political Speech By Churches, 5th Circ. Told
A Texas federal court wrongly rejected the IRS' proposed settlement that would allow churches to engage in political speech without jeopardizing their tax-exempt status, conservative groups told the Fifth Circuit, arguing that federal tax assessment protections do not bar the court from implementing the deal.
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July 15, 2026
Cornyn, Tillis Still Waver On Blanche AG Bid After Hearing
Todd Blanche had his nomination hearing to be attorney general on Wednesday and two key Republican senators still have yet to say if they will support him.
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July 15, 2026
TIGTA Worried About IRS Zero Paper Push Security Breaches
Unauthorized employees have accessed restricted areas because of physical security gaps at two sites where contractors are supporting the Internal Revenue Service's push to eliminate paper processing of tax returns, the Treasury Inspector General for Tax Administration said in a management alert released Wednesday.
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July 15, 2026
Russia Sanctions Bill Goes Too Far On Tariff Power, Dems Say
A reworked version of a bipartisan bill aimed at sanctioning Russia over the war in Ukraine wrongly places too much tariff power in the hands of President Donald Trump, some leading congressional Democrats said.
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July 15, 2026
Pillar 2 Revenue Intake Falls Short Of Predictions, OECD Says
The worldwide corporate 15% minimum tax agreement known as Pillar Two has so far brought in less revenue than expected, the Organization for Economic Cooperation and Development said Wednesday.
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July 15, 2026
Mich. Tax Biz Barred From Preparing Federal Returns By Court
A federal judge granted the federal government's bid to bar a Michigan-based tax and accounting business from preparing federal tax returns over allegations it prepared fraudulent returns that cost the government a tax revenue loss estimated at over $2 million.
Expert Analysis
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Hungary CPAC Funding Probe Could Implicate US Entities
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.
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Mitigating Multistate Risks As California Expands Tax Reach
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.
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E-Discovery Quarterly: Recent Rulings On ESI Control
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.
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Anticipating The Justices' Potential Ruling On Tax Takings
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.
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2 Discovery Rulings Break With Heppner On AI Privilege Issue
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.
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CBP's $166B Tariff Refund Portal Needs 4 Safeguards
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.
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How Developers Can Leverage The New Markets Tax Credit
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.
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Calculating Damages In IEEPA Tariff Refund Litigation
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.
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Alpine Skiing Makes Me A Better Lawyer
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.
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What A Court Doc Audit Reveals About Erroneous Filings
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.
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Mich. Banking Brief: All The Notable Legal Updates In Q1
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.
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Navigating The Perks Of Qualified Opportunity Zones 2.0
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.
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Getting The Most Out Of Learning And Development Programs
Excerpt from Practical Guidance
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.