Federal
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October 26, 2026
Former Willkie Partner, Wife Owe $14.5M Tax Debt, Gov't Says
A former Willkie Farr & Gallagher LLP partner and his wife owe the U.S. more than $14.5 million in unpaid taxes, penalties and interest, according to a complaint filed in Manhattan federal court that seeks to enforce federal tax liens against their New York home to settle the debt.
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October 26, 2026
IRS FAQs Clarify Relief From Dyed Diesel Excise Tax
The Internal Revenue Service issued 11 FAQs addressing the recent interim relief from the dyed fuel excise tax, including the use of dyed biodiesel mixtures and reporting exemptions, for businesses and organizations using the fuel for on-road vehicles.
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October 23, 2026
IRS Fights For Microcaptive Reporting Rules In 5th Circuit
The Fifth Circuit should restore a vacated regulation that required disclosure of certain microcaptive transactions due to the risk of tax avoidance and uphold another related rule that carried a lower penalty for reporting failures, the government said Friday, arguing against a plastics manufacturer fighting to eliminate both.
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October 23, 2026
Virgin Islands NIIT Exemption Should Stay Intact, Court Told
A former U.S. Virgin Islands resident urged a federal court Friday not to rethink its decision holding that locals are exempt from the net investment income tax, arguing it's too late for the territory's revenue collectors to raise new arguments.
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October 23, 2026
Tax Court Misread Easement Rules, 4th Circ. Told
The U.S. Tax Court imposed conservation easement donation requirements beyond what the law allows in evaluating a property's condition and potential mining value, a partnership told the Fourth Circuit, seeking to overturn the 2025 denial of its charitable deduction.
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October 23, 2026
TIGTA Says 2.2M Returns Prepped By Noncompliant Preparers
More than 38,000 tax preparers with a noncompliant IRS identifier status prepared more than 2.2 million returns for processing in 2025, the Treasury Inspector General for Tax Administration said in a report assessing the agency's issuing, renewing and monitoring of the identifiers.
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October 23, 2026
Wyden Floats Data Center Excise Tax, Limits On Incentives
Data centers wouldn't be eligible for opportunity zone incentives and data center operators would be subject to an excise tax on gross receipts under draft legislation released Friday by the top Democrat on the Senate Finance Committee.
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October 23, 2026
Taxation With Representation: Milbank, De Brauw, Wachtell
In this week's Taxation With Representation, EQT Private Equity announces a takeover offer for life sciences testing company Qiagen NV, Salesforce acquires customer engagement platform Braze and London Stock Exchange Group buys U.S. credit intelligence provider Octus.
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October 23, 2026
Dutch Tax Treaty Policy Should Wait For Int'l Deal, NFTC Says
The Netherlands should not unilaterally change its tax treaty policy to allow countries to collect levies from remote corporations, the National Foreign Trade Council said Friday, urging the government to wait for countries to agree on new international norms.
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October 23, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included temporary rules on how to establish the tax-advantaged brokerage accounts for children known as Trump Accounts.
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October 22, 2026
Vegas Man Gets 38 Months For $5M Tax Refund Fraud Scheme
A Las Vegas man was sentenced to more than three years in prison for his role in what the government described as a $5 million tax refund fraud scheme that also involved his mother, who owned a tax preparation business, federal prosecutors said.
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October 22, 2026
IRS Says Tax Court Lacks Jurisdiction In Late-Filed Case
The U.S. Tax Court erred by finding it has jurisdiction in a partnership case that missed the 90-day window for filing its petition, the IRS said, arguing that relevant language in 2015 legislation is identical to that in prior legislation that mandated dismissing a similar case.
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October 22, 2026
Dems Seek GAO Review Of $166B Tariff Refund Operation
Democratic lawmakers serving in the U.S. House and Senate asked for the Government Accountability Office to evaluate Customs and Border Protection's administration of a tariff refund system designed to repay importers the $166 billion in paid duties deemed unlawful earlier this year by the U.S. Supreme Court, according to a Thursday news release.
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October 22, 2026
GOP Reps. Seek Probe Of Fla. Judge's Sanctions Order
Top Republicans on the House Judiciary Committee asked the Judicial Conference Thursday to investigate a Florida federal judge for potential misconduct with an order she issued in the case involving the leak of President Donald Trump's tax returns.
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October 22, 2026
5th Circ. Orders New Look At IRS' Loss On FBAR Jury Rights
A Texas federal court must revisit its 2025 ruling that the IRS violated a woman's jury-trial rights by imposing a $1 million civil penalty for failing to report foreign bank accounts, the Fifth Circuit said, ordering another review in light of a U.S. Supreme Court decision.
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October 22, 2026
UPS Waiting On Feds To Refund Tariff Costs, Court Told
An Atlanta federal court should, at minimum, pause a proposed class action looking to force UPS to reimburse customers for costs they incurred as the result of struck-down reciprocal tariffs, the shipping giant said, as the company itself is still waiting on refunds.
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October 22, 2026
Tax Court Scraps $75M Easement Deduction As 'Cartoonish'
The U.S. Tax Court refused to approve a partnership's $74.5 million charitable tax deduction for a Tennessee conservation easement Thursday, describing it as a "cartoonish" amount for a nearly $3 million property that sat on the market for years.
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October 22, 2026
IRS Creates New Retirement Plan Correction Program
The Internal Revenue Service issued two revenue procedures Thursday, including one creating a correction program for individual retirement accounts.
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October 22, 2026
IRS Offer In $57M Easement Case Not Binding, 11th Circ. Told
The U.S. Tax Court properly denied a partnership's request to enforce a settlement offer the IRS said it mistakenly made after rejecting the partnership's $57 million conservation easement deduction, the agency told the Eleventh Circuit, saying the parties hadn't entered into a binding agreement.
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October 22, 2026
Foreign Tax Credit Sourcing Rule Likely By Year's End
The IRS hopes to propose regulations on sourcing certain inventory sales income for the foreign tax credit limitation under Internal Revenue Code Section 904 — one of the items listed on its priority guidance plan for 2026-2027 — by the end of the year, an agency official said.
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October 22, 2026
Treasury Aiming to Float CAMT Rules by Feb., Official Says
The U.S. Treasury Department is still on track to propose revised regulations for the corporate alternative minimum tax by February, a department official said Thursday.
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October 21, 2026
IRS Sets Interim Relief For Dyed Fuel Excise Tax Reporting
The IRS will temporarily waive enforcement of the reporting and recordkeeping requirements for the retail excise tax on certain uses of dyed diesel as the agency examines a simple process to administer the compliance provisions, the agency announced Wednesday.
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October 21, 2026
IRS Says Eaton Misportrayed Intercompany Loan Example
Eaton misportrayed the IRS' argument about a regulatory example concerning the relevance of companies' relatedness when analyzing an arm's-length price of a transaction, the agency told the U.S. Tax Court, defending its denial of related-party interest and fee deductions.
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October 21, 2026
Wyden Questions Big 4 Execs On Int'l Tax Shelter Consulting
The Senate Finance Committee's top Democrat said Wednesday that he was launching an inquiry into whether the Big Four accounting firms — PwC, KPMG, Deloitte and EY — have helped large multinational corporations avoid billions in taxes by creating tax shelters in Malta.
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October 21, 2026
Beauty Co.'s $8M Refund Bid Axed For Misnomer On Returns
An Illinois federal judge dismissed a skin care corporate group's $8.3 million tax refund suit, finding she lacked jurisdiction to review its amended returns claiming business deductions because those filings did not use the company's new name after a 2018 merger.
Expert Analysis
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Checking For AI Errors Is Now A Two-Way Street
A handful of recent federal and state cases demonstrate the importance of checking for errors generated by artificial intelligence not only in your own court submissions, but also your opponent's, as well as when catching opposing counsel's AI mistakes could result in an award for attorney fees, says Tamara Barago at Hollingsworth.
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5 Things Associates Must Ask About Their Firm's Merger Plan
The associates who navigate law firm mergers best ask the right questions early, such as inquiring about partners' plans, to assess how the merger could affect their workflow and career path, says Jackie Bokser-LeFebvre at Major Lindsey.
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2 'Rocket Dockets' And The Rules That Propel Them
The fastest civil trial courts in the country are currently in the Eastern District of Virginia and the Southern District of Florida, and their chief judges provide insights into the court rules that keep them ahead, says Robert Tata at Hunton.
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Key Legal Considerations For Data Center Battery Storage
Battery energy storage systems have become essential infrastructure for data center development — but as trade, energy and tax policies continue to shift, companies operating in this space must understand the importance of supply chain requirements and industry-tailored contracts, says RJ Colwell at Davis Graham.
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Your Next Litigation Hold Should Cover AI Chat Logs
The Delaware Chancery Court’s recent decision in Fortis Advisors v. Krafton to treat a CEO’s artificial intelligence chats as substantive evidence is being read as a discovery warning to litigators, but there is a second duty-to-preserve lesson that is especially pertinent to in-house counsel, say attorneys at Faegre Drinker.
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Cannabis Policy Shift May Reshape Banking, Insolvency Risks
The Trump administration's cannabis rescheduling initiative aims to correct classification that had rendered federal banking, tax administration and insolvency law incoherent, and will begin to restore some alignment between federal law and the economic reality of the marijuana industry, says Richard Ormond at Buchalter.
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Studying Foreign Languages Makes Me A Better Lawyer
Studying Italian and Japanese has shown me that learning a new language can benefit a legal career in several ways, including by demonstrating the importance of approaching problems from a fresh perspective and the value of practicing patience with colleagues and clients, says Anna King at Genworth Financial.
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Sold Inventory May Drive Tax Treatment Of Tariff Refunds
Companies determining the tax treatment of refunds expected following the U.S. Supreme Court's February decision invalidating tariffs imposed under the International Emergency Economic Powers Act should consider whether the tariff costs have already reduced their income considering the cost of goods sold, say attorneys at McDermott.
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Adapting To AI-Driven Scrutiny Of Foreign Asset Disclosures
As the government expands AI-driven, cross-agency fraud detection, foreign asset disclosure should be viewed as part of a broader, data‑driven enforcement ecosystem that prioritizes consistency, documentation and proactive governance, says Logan Koehring at FBT Gibbons.
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Sizing Up The Rescheduling Hurdles Medical Pot Cos. Face
The Justice Department’s recent lowering of certain medical marijuana products to Schedule III means operators — particularly those simultaneously offering federally illegal adult-use cannabis — must implement greater structural discipline to navigate an increasingly fragmented legal landscape if they hope to benefit from new tax deductions and access to capital, say attorneys at Akerman.
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Tax Teams Get No Bright-Line Rule From AI Privilege Cases
Three recent appellate decisions that considered artificial intelligence in the context of attorney-client privilege protections illustrate that taxpayers and tax practitioners alike must consider the pertinent facts on a case-by-case basis, with particular attention to confidentiality, disclosure risk and system design, say attorneys at Morgan Lewis.
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NY Times Word Puzzles Make Me A Better Lawyer
Every morning I let The New York Times humble me with word games, which offer a chance to recalibrate my brain before the day's chaos arrives and remind me that a solution — whether to a puzzle or employment law issue — almost always exists once I find the right angle, says Amy Epstein Gluck at Pierson Ferdinand.
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Law School's Missed Lesson: Diagnose Before Arguing
Law school often skips over explicitly teaching students how to determine what kind of problem a case presents before they commit to a particular doctrinal path, which risks building arguments that are internally coherent but externally misaligned, says Melanie Oxhorn at Kobre & Kim.