Federal

  • June 30, 2026

    Int'l Tax In June: Tariff Refunds Challenged, EU Sets Agenda

    As U.S. Customs and Border Protection entered the second phase of its process for refunding invalidated tariffs in June, President Donald Trump's administration challenged its authority to issue those refunds. Here, Law360 examines some of the past month's biggest international tax developments.

  • June 30, 2026

    House Panel Eyes Curbs On Tax-Exempt Stadium Financing

    Congress can strengthen the tax code to crack down on professional sports teams that leverage tax incentives to construct stadiums with taxpayer dollars, House Ways and Means Committee lawmakers and sports industry stakeholders said Tuesday.

  • June 30, 2026

    Ex-Morgan Lewis Atty Not Restored Over 'Dishonest Conduct'

    A former Morgan Lewis attorney suspended for his handling of a tax case and making misrepresentations to disciplinary authorities investigating his conduct failed to prove he was morally qualified to return to the practice of law, the Pennsylvania Supreme Court agreed Tuesday.

  • June 30, 2026

    FDIC, US Aiming to Settle $1.9M First Republic Tax Bill

    The U.S. government and the Federal Deposit Insurance Corp. are working to settle the government's case against the agency in its role as receiver for the defunct First Republic Bank over taxes that the government alleges were owed by foreign individuals, a U.S. attorney said Tuesday.

  • June 30, 2026

    Tax Court Withheld Evidence In Easement Row, 10th Circ. Told

    The U.S. Tax Court's improper withholding of an appraiser report as evidence resulted in a flawed opinion last year that substantially slashed the value of a North Carolina conservation easement donation by 94%, the partnership donor told the Tenth Circuit.

  • June 29, 2026

    2nd Circ. Revives Penalty Collection Fight In $380M Tax Case

    The Second Circuit revived penalty collection challenges Monday by six companies found to owe $380 million to the IRS from participating in a tax scheme, saying an appeals officer's failure to verify that fines had been approved by a supervisor invalidated the collection process.

  • June 29, 2026

    Seattle Judge Merges Amazon IEEPA Tariff Refund Suits

    A federal judge in Seattle consolidated a pair of proposed class actions brought by Amazon customers looking to recover millions of dollars in refunds for the now-invalidated International Emergency Economic Powers Act tariffs, as the two suits made essentially identical allegations.

  • June 29, 2026

    IRS Offers Gift Tax Safe Harbor Guidance For Trump Accounts

    The Internal Revenue Service is providing a gift tax reporting safe harbor for certain contributions to the new tax-advantaged brokerage accounts for newborns known as Trump Accounts, according to guidance released Monday.

  • June 29, 2026

    Former NJ AG Pushes To End Suit Over Tossed RICO Case

    Former New Jersey Attorney General Matt Platkin asserts that a lawsuit from a former CEO indicted in New Jersey's now-dismissed criminal racketeering case against South Jersey power broker George E. Norcross III squarely implicates the protections afforded to prosecutors.

  • June 29, 2026

    IRS Hasn't Fully Met Veteran Hiring Goal, TIGTA Says

    The Internal Revenue Service didn't meet the 14% veteran hiring goal set by the U.S. Department of the Treasury, the Treasury Inspector General for Tax Administration said in a report released Monday.

  • June 29, 2026

    Partnership Asks To Restore $3.7M In Captive Deductions

    The IRS shouldn't have disallowed more than $3.7 million in deductions claimed by a partnership on premiums paid to five captive insurance companies because the transactions had economic substance, the partnership told the U.S. Tax Court.

  • June 29, 2026

    Cole Schotz Adds Tax Atty In Miami From Day Pitney

    Cole Schotz PC announced Monday that it has hired a Day Pitney LLP attorney to bolster its capacity to advise high-net-worth individuals and other clients on tax, trust and estate matters.

  • June 29, 2026

    Tax Attys Cite Justices' Venue Ruling In Seeking 4th Circ. Redo

    A father-daughter attorney duo is asking the full Fourth Circuit to rethink their convictions in a $22 million tax avoidance scheme, arguing a U.S. Supreme Court decision that came down just two days after a panel affirmed their guilty verdicts supports their argument that prosecutors pursued charges in the wrong state.

  • June 29, 2026

    Justices Strike Down Humphrey's Presidential Firing Limits

    The president has unlimited authority to fire members of independent agencies, the U.S. Supreme Court ruled Monday in a major win for President Donald Trump's campaign against officials at the Federal Trade Commission and beyond.

  • June 26, 2026

    PACER Fees Will Rise To Fund Cyber Defense Upgrades

    The federal judiciary announced Friday it will temporarily increase the fees for electronic access to court records to pay for a potential $800 million upgrade that will modernize and strengthen court records systems PACER and CM/ECF, an upgrade it previously said is needed to respond to escalating cyberattacks.

  • June 26, 2026

    Firm Can't Shoot Down IRS Microcaptive Rules, Court Says

    The IRS' reporting rules for microcaptive insurance companies aren't unreasonable, a Texas federal court said Friday, shooting down a global tax consultancy's bid to vacate them.

  • June 26, 2026

    Treasury Wary Of Challenges After Loper Bright, Official Says

    The U.S. Department of the Treasury is less likely to take regulatory positions that could be challenged partly because of the heightened litigation risk following the U.S. Supreme Court's Loper Bright ruling, a department official said Friday.  

  • June 26, 2026

    High Court Ruling Backs Broker On IRS Penalty, Court Told

    A recent U.S. Supreme Court decision upholding agency fines without a jury trial supports an insurance broker's challenge to a $6.6 million tax penalty imposed by the Internal Revenue Service, the broker told a Pennsylvania federal court.

  • June 26, 2026

    Trump Threatens 100% Tariff For EU Nations Planning DSTs

    President Donald Trump threatened to impose a 100% tariff on imports entering the U.S. from countries in the European Union planning to levy new digital service taxes, according to a social media post Friday.

  • June 26, 2026

    Tax Court Tosses Meta's Interest Claim In $16B Dispute

    The U.S. Tax Court said it has no jurisdiction to hear Meta's challenge to the IRS assessing interest on the company until it has decided whether a deficiency or overpayment exists in the company's underlying case over a $15.9 billion tax bill, according to an order.

  • June 26, 2026

    IRS Mulling Digital Asset Disclosure Program, Official Says

    The Internal Revenue Service is weighing whether to create a stand-alone voluntary disclosure practice for digital assets, the head of the agency's criminal investigation unit said Friday.

  • June 26, 2026

    Taxation With Representation: Sidley, Paul Weiss, Kirkland

    In this week's Taxation With Representation, Germany's Merck KGaA acquires life sciences tools supplier Bio-Techne Corp., drugmaker AbbVie buys clinical-stage biotechnology company Apogee Therapeutics, and building materials supplier CRH acquires infrastructure products maker Arcosa Inc.

  • June 26, 2026

    DOJ Fraud Division To Prioritize Tax Crimes, Official Says

    The new fraud enforcement division at the U.S. Department of Justice is moving to pursue tax fraud crimes aggressively, an official said Friday, saying the division is characterizing the effort as an "emergency" to maximize efforts.

  • June 26, 2026

    DOJ Tax Litigation Official Expects Appellate Cases To Rise

    More tax cases are likely to be appealed as textualist interpretations of statutes gain in suits and litigants increasingly invoke recent U.S. Supreme Court precedent, a U.S. Department of Justice official said Friday.

  • June 25, 2026

    11th Circ. Judges Question Coke's View Of IRS As Arbitrary

    Judges for the Eleventh Circuit probed attorneys for Coca-Cola and the government Thursday about whether the IRS was arbitrary in abandoning its position in a closing agreement the beverage company had relied on for decades to calculate its transfer prices with related foreign suppliers.

Expert Analysis

  • 5 Tips For Navigating Your Firm's All-Attorney Summit

    Excerpt from Practical Guidance
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    Law firm retreats should be approached strategically, as they present valuable opportunities to advance both the firm's objectives and attorneys' professional development through meaningful participation, building and strengthening internal relationships, and proactive follow-up, says James Argionis at Cozen O’Connor.

  • How Bankrupt Cos. Can Seek Refunds For Illegal Tariffs

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    In light of the U.S. Supreme Court's recent decision striking down President Donald Trump's International Emergency Economic Powers Act tariffs as illegal, some companies may have strong prospects for recovering refunds from the government, and trustees in bankruptcy may have a significant role to play in seeking such recovery, say attorneys at Stinson.

  • Legal And Industry Impacts Of America's Maritime Action Plan

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    America's Maritime Action Plan, unveiled by the White House last month, introduces changes to trade investigations, a new maritime trust fund and more — adding regulatory and compliance obligations for companies and counsel, but also new avenues for client engagement in project finance, contract negotiation and dispute resolution, say attorneys at Holland & Knight.

  • 4 Ways To Help CBP Curb Shell Co. Import Schemes

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    Shifting to a proactive rather than reactive enforcement posture in addressing shell companies set up to skirt tariffs requires equipping U.S. Customs and Border Protection with enhanced investigative authorities, better intelligence support, and mechanisms to identify and hold accountable the ultimate illicit actors, say attorneys at Kelley Drye.

  • 7 Steps For Gov't Contractors In Post-IEEPA Tariff Landscape

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    In response to U.S. Supreme Court's recent decision to strike down tariffs issued by the Trump administration under the International Emergency Economic Powers Act, there are several actions federal contractors should take to preserve their place in any refund waterfall, and to manage audit, overpayment and False Claims Act risk, say attorneys at Holland & Knight.

  • The Benefits Of Choosing A Niche Practice In The AI Age

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    As artificial intelligence becomes increasingly accessible, lawyers with a niche practice may stand out as clients seek specialized judgment that automation cannot replicate, but it is important to choose a niche that is durable, engaging and a good personal fit, says Daniel Borneman at Lowenstein Sandler.

  • Section 122 Tariffs Show Shift In Strategy, Not Trade Policy

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    By imposing temporary tariffs under Section 122 of the Trade Act as a stopgap measure while it pivots to less transitory statutory authorities, the Trump administration sent a clear message that the U.S. Supreme Court’s decision in Learning Resources v. Trump, invalidating duties imposed under the International Emergency Economic Powers Act, will not precipitate a change in policy direction, say attorneys at Snell & Wilmer.

  • Tax Court Ruling Signals Cross-Border Loan Scrutiny

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    The U.S. Tax Court’s recent decision in Aventis v. Commissioner compounds ongoing regulatory focus on debt originations and should prompt practitioners to assess their existing cross-border lending structures for potential exposure to U.S. federal income tax, say attorneys at Eversheds.

  • Lessons From Justices' Split On Major Questions Doctrine

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    The justices' varied opinions in Learning Resources v. Trump, which held the International Emergency Economy Powers Act did not confer the power to impose tariffs, offer a meaningful window into the U.S. Supreme Court's perspective on the major questions doctrine that will likely shape lower courts' approach to executive action challenges, say attorneys at Venable.

  • Resilience Planning As Nat'l Security Shifts Tech Import Policy

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    In response to a sustained reorientation of U.S. trade policy around national security considerations, businesses reliant on processed critical minerals must closely monitor diplomatic negotiations and the potential expansion of trade measures, incorporating contingency planning into procurement and long-term investment strategies, says attorney Sohan Dasgupta.

  • 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.

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