Federal

  • May 11, 2026

    APA Results Should Make Sense Annually, IRS Official Says

    Taxpayers seeking advance pricing agreements with the Internal Revenue Service will now be expected to have the results of an agreed-upon transfer pricing method comply with the method on an annual basis rather than only over the multiple years covered by the APA, an IRS official said Monday.

  • May 11, 2026

    Amgen Late To Raise Double-Taxation Claim, Tax Court Told

    Biotechnology giant Amgen is making a "futile" attempt to raise a purported double-taxation issue for tax years 2016 through 2018 in a pair of transfer pricing cases before the U.S. Tax Court, the federal government said, arguing the disputed years fall outside the court's jurisdiction.

  • May 11, 2026

    IRS To Automatically Waive Some Tax Penalties

    The IRS will begin automatically waiving certain penalties for eligible taxpayers starting with the current filing season, said National Taxpayer Advocate Erin Collins, announcing a shift from the agency's long-standing policy requiring taxpayers to request first-time penalty relief.

  • May 11, 2026

    Federal Workers' Tax Noncompliance Has Risen, TIGTA Says

    About 50,000 federal civilian employees failed to file tax returns for multiple years, the Treasury Inspector General for Tax Administration said in a report released Monday, finding noncompliance among civilian government workers has been steadily rising.

  • May 11, 2026

    Trump Floats Gas Tax Suspension Amid Rising Fuel Costs

    President Donald Trump said Monday that he wants to temporarily pause the 18-cent-per-gallon federal gas tax amid rising fuel prices caused by the war with Iran.

  • May 11, 2026

    IRS Taking Too Long Solving Unneeded Tickets, TIGTA Says

    The Internal Revenue Service had to handle a glut of unnecessary incident tickets due to faulty processes while also taking too long to resolve these incidents, the Treasury Inspector General for Tax Administration said.

  • May 11, 2026

    McKesson Says Loper Bright Sinks IRS Cost-Sharing Rules

    Pharmaceutical giant McKesson asked a Texas federal court to strike down cost-sharing transfer pricing regulations that underpin the company's $10 million tax refund bid, arguing the U.S. Supreme Court's Loper Bright ruling forecloses previous deference to rule writers.

  • May 11, 2026

    AI Startup Misclassified 30K Workers, Suit Says

    A hiring startup that supplies workers to train artificial intelligence models for OpenAI, Anthropic and Meta has misclassified more than 30,000 workers as independent contractors to avoid paying payroll taxes and benefits, according to a proposed class action in Texas federal court.

  • May 11, 2026

    Agencies Pitch Employers Offering Voluntary Fertility Benefits

    Federal agencies overseeing employer-provided health coverage proposed new rules aimed at expanding workers' access to coverage for infertility treatments and related health conditions by letting employers offer voluntary fertility health benefit policies for procedures such as in vitro fertilization.

  • May 09, 2026

    IRS Scrutiny Of Immigrant Employment Tax Fraud To Continue

    Scrutinizing businesses with potential employment tax fraud issues related to undocumented immigrants will remain among the Internal Revenue Service Criminal Investigation division's top priorities, a senior division executive said Saturday.

  • May 09, 2026

    Spinoff Letter Rulings Valuable For IRS Too, Agency Atty Says

    The Internal Revenue Service has resumed issuing letter rulings on significant issues in tax-free spinoffs, and an IRS attorney on Saturday encouraged companies to use the program, as it provides the agency with valuable information on the transactions.

  • May 09, 2026

    Admin Cost Of Tax Presence Shouldn't Top Profit, Pros Say

    The administrative costs for a company or individual triggering a taxable presence, or permanent establishment, in a jurisdiction shouldn't exceed the profit allocable to the entity, transfer pricing specialists said Friday.

  • May 08, 2026

    AI's Use In Transfer Pricing Still Evolving, Tax Pros Say

    The use of artificial intelligence in transfer pricing is expected to ease compliance and reduce costs for clients, but multiple questions remain about the technology's potential and how it should be applied, a panel of tax experts said Friday.

  • May 08, 2026

    Pro Energy Granted $1.85M Refunds Over Pulled Tax License

    A Florida federal judge on Friday ruled Pro Energy LLC can recover $1.85 million in refunds from fuel excise taxes it paid despite being registered as an ultimate vendor, which should have allowed it to make tax-free fuel and gas sales to state and local governments.

  • May 08, 2026

    Disbarred Atty Can't Escape Tax Evasion Case, 2nd Circ. Says

    A disbarred English attorney who assisted the heirs of an American businessman in evading taxation on their inheritance cannot use an "extraordinary" post-conviction remedy to overturn part of the verdict and a $4 million restitution bill, the Second Circuit ruled Friday.

  • May 08, 2026

    Nike Customers Join Tariff Refund Class Action Trend

    A group of Nike customers on Friday joined the growing number of proposed class actions looking to secure legal rights to refunds of costs tied to President Donald Trump's now-invalidated global tariff regime, saying they were the ones who actually bore the costs.

  • May 08, 2026

    Why Trump's 2nd Global Tariff May Fare Better On Appeal

    President Donald Trump's administration on Friday appealed the U.S. Court of International Trade's ruling deeming his temporary global tariff unlawful to the Federal Circuit, where judges may view the executive action with more deference than the measures it immediately replaced.

  • May 08, 2026

    Clarity Sought On Energy Tax Credits And Foreign Debt

    The IRS should issue more guidance on what kind of debt arrangements can limit a development project's access to clean energy tax credits under new prohibited foreign entity requirements as uncertainty over financial liability and ownership becomes a major market concern, practitioners said Friday.

  • May 08, 2026

    US, Romania Have Wrapped Up Tax Treaty Talks, Official Says

    The U.S. and Romania recently completed negotiations on their double-tax treaty and are conducting reviews of the changes, an official with the U.S. Department of the Treasury said Friday.

  • May 08, 2026

    3rd Circ. Rejects NJ Man's Bid To Revisit $40M Tax Conviction

    The Third Circuit has declined to reconsider upholding the conviction of a man who raked in $40 million from filing false tax returns.

  • May 08, 2026

    Prosecutors Oppose Move To Put Off Goldstein Sentencing

    Federal prosecutors are claiming that SCOTUSblog founder Thomas Goldstein may have violated his pretrial release conditions when he racked up over $1.7 million in gambling income last year, telling a federal judge not to delay sentencing for the famed U.S. Supreme Court lawyer.

  • May 08, 2026

    Taxation With Representation: Corrs, Kirkland, Linklaters

    In this week's Taxation With Representation, gold companies Regis Resources and Vault Minerals combine, Long Lake Management acquires American Express Global Business Travel and Vodafone buys out CK Hutchison Holdings to become the sole owner of their telecommunications joint venture.

  • May 08, 2026

    DOL Benefits Chief Warns Of 'Bad Faith' Focus On ESG, DEI

    The top official for the U.S. Department of Labor's employee benefits subagency said at a trade association conference Friday that agency investigations will focus on benefit plan managers' loyalty conflicts, including disloyal pursuits of socially conscious investing or diversity goals.

  • May 08, 2026

    Liberty Global Easy Case For 10th Circ., IRS Atty Says

    The Internal Revenue Service's recent win against telecommunications giant Liberty Global, whose complex transactions were held to be a tax shelter lacking economic substance, was an "easy affirmance" for the Tenth Circuit and an easy decision for the district court, an agency official said Friday.

  • May 08, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, included the nomination process and eligibility requirements for designated qualified opportunity zones and identifying a list of qualifying areas.

Expert Analysis

  • 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.

  • 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.

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