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Federal
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July 09, 2026
Reclassified Debt Didn't Cause $21M Gain, Partnership Says
The IRS wrongly treated the reclassification of $21.1 million in debt to equity as a taxable event when hitting a partnership with $12.8 million in taxes, penalties and estimated interest, the partnership told the U.S. Tax Court.
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July 09, 2026
4th Circ. Rebuffs Tax Attys' Request To Rethink Convictions
The Fourth Circuit will not rethink its decision last month affirming the convictions of two St. Louis attorneys accused of engineering a $22 million tax avoidance scheme.
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July 09, 2026
5 Clifford Chance Finance And Tax Attys Join Sidley In NY, DC
Sidley Austin LLP announced Thursday that five Clifford Chance LLP attorneys have joined the firm's global finance and tax practices in New York and Washington, D.C.
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July 09, 2026
Pillar 2 Carveouts Won't Undercut Global Tax, Official Says
The integrity of the 15% global minimum tax system will not be undermined by a host of nations gaining access to provisions that exempt them from certain obligations, the tax head at the Organization for Economic Cooperation and Development said Thursday.
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July 08, 2026
Partnership Defends $55.6M Deduction For Mo. Land Gift
A partnership that donated over 73 acres in Butler County, Missouri, to a conservation group told the U.S. Tax Court it properly deducted $55.6 million for the gift, saying the value was based on the analysis of two qualified appraisers.
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July 08, 2026
IRS To Give Automatic Penalty Relief To Compliant Taxpayers
Taxpayers with a history of filing and paying on time will no longer have to request penalty relief under an automatic exemption expected to roll out this summer, the IRS announced Wednesday.
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July 08, 2026
IRS Finalizes Life Insurance Reporting Exception Regs
The Internal Revenue Service confirmed that certain tax-free transfers of life insurance contracts are exempt from the 2019 reporting rules for life settlement transactions, including policy sales and death benefit payments, under final regulations released Wednesday.
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July 08, 2026
IRS Urged To Make Digital Broker E-Statements Easier
The IRS should update regulations that would allow digital asset brokers to provide statements electronically to remove operational hurdles and designate more effective communication methods, such as in-app messaging and SMS, stakeholders told the agency Wednesday.
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July 08, 2026
Shopping Center Owner's Estate Disputes $41M Deficiency
The estate of a man who co-owned a Massachusetts shopping center challenged a $40.8 million deficiency assessment in the U.S. Tax Court, saying the IRS wrongly determined that a 2012 sale of his interest in the partnership owning the center wasn't bona fide.
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July 08, 2026
IRS Targets Certain Annuity Trusts As Potential Tax Shelters
The IRS unveiled final rules Wednesday designating certain charitable remainder annuity trusts as reportable transactions because they involve abusive tax avoidance practices, subjecting participants to potential penalties if they do not disclose such arrangements.
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July 08, 2026
Foley Adds Attys From Kirkland, Goodwin To Corporate Team
Foley & Lardner LLP has strengthened its corporate bench with a Dallas-based partner who came aboard from Kirkland & Ellis LLP and a Boston-based partner from Goodwin Procter LLP.
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July 07, 2026
2 Ex-Telehealth Execs Sentenced For $100M Adderall Scheme
A California federal judge on Tuesday sentenced two former executives of a telehealth company who were convicted of operating a $100 million scheme to illegally distribute Adderall over the internet, fining them $1 million each and giving the founder six years in prison.
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July 07, 2026
DC Circ. Backs Tax Bribery Convictions Despite Jury Error
A D.C. Circuit panel refused on Tuesday to reverse a lower court's judgments against two men in connection to a bribery scheme carried out to evade $2.3 million in business tax obligations, finding a jury instruction error "harmless," among other unsuccessful arguments.
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July 07, 2026
Dem Sens. Probe CEOs On Trump-IRS Settlement Immunity
Three senior Democratic senators are investigating whether several companies with ties to President Donald Trump are benefiting from what they alleged was immunity for him, his family and his businesses in the settlement he reached with the Internal Revenue Service.
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July 07, 2026
Exxon Seeks $324M Judgment In Dispute On Qatar Deal Tax
Exxon asked a Texas federal court to rule that it's owed a $273 million tax refund and $51 million in penalties in a dispute with the U.S. government over the tax treatment of a natural gas deal with Qatar.
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July 07, 2026
IRS Denies Blowing Deadline In $34M Easement Dispute
The IRS timely issued a notice of adjustment to a partnership claiming a $34 million easement deduction for its donation to a Cleveland historic preservation group, the agency told the U.S. Tax Court, arguing that the partnership is raising a frivolous contention in seeking to throw out the adjustment and penalties.
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July 07, 2026
Consultant Says FARA Verdict Should Be Erased
A political consultant convicted of knowingly failing to register as a foreign agent as she helped draft a $50 million contract involving a former congressman and Venezuela's state-owned oil enterprise continues to argue she should be acquitted or given a new trial, saying the verdict was "against the great weight of the evidence."
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July 07, 2026
Claims Court Nixes GILTI Tax Rules Under Loper Bright
The U.S. Court of Federal Claims invalidated corporate tax regulations that deny amortization deductions tied to certain overseas intangible asset transfers, holding that the rules are the kind of "agency overreach" foreclosed by the U.S. Supreme Court's Loper Bright ruling.
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July 07, 2026
Grocers' Microcaptive Not Valid For Tax Benefit, 7th Circ. Told
Chicagoland grocery chain owners were not entitled to microcaptive tax benefits because they failed to establish a bona fide in-house insurance arrangement, the government told the Seventh Circuit, saying the U.S. Tax Court correctly held that state law does not control the federal tax definition of insurance.
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July 07, 2026
Simpson Thacher Adds Energy Tax Partner From Weil In NY
Simpson Thacher & Bartlett LLP announced Tuesday that a former Weil Gotshal & Manges LLP partner has joined the firm's New York office to advise clients on the U.S. tax aspects of energy and infrastructure transactions.
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July 06, 2026
4 Benefits And Exec Comp Policy Moves From 2026's 1st Half
The U.S. Department of Labor's proposal for a 401(k) fund safe harbor and the U.S. Securities and Exchange Commission's proposal to change the reporting framework for public companies are among the top policy developments from the first half of 2026 that drew benefits and executive compensation attorneys' attention. Here, Law360 looks at four recent developments that attorneys may want to know about.
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July 06, 2026
Partnership Agrees To Nix Tenn. Land Gift Deduction
A partnership agreed with the IRS that its claimed $4.5 million deduction for over 50 acres in Tennessee donated in 2017 should be zero but that it is entitled to a separate deduction of $967,000.
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July 06, 2026
The Moments That Shaped The Monsanto Decision
U.S. Supreme Court justices forged unusual alliances when they ruled a federal statute preempts claims Monsanto failed to warn consumers its Roundup weed killer may cause cancer. Oral arguments provided insights on the 7-2 outcome, highlighting issues the jurists were grappling with and showcasing rationales that found their way into the opinion.
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July 06, 2026
After Tense Terms, Hints Of High Court Harmony With Circuits
Following several U.S. Supreme Court terms teeming with reversals and rebukes of lower appeals courts, the justices this term found fault less often with rulings by circuit judges, who are likely becoming better attuned to the conservative supermajority, attorneys say.
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July 06, 2026
The Funniest Moments Of The Supreme Court's Term
When one of the U.S. Supreme Court's most talkative members suddenly struggled to speak, the atmosphere at oral arguments grew increasingly anxious — until the justice deadpanned that it was an advocate's golden opportunity to avoid a grilling.
Expert Analysis
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5 Tips For Navigating Your Firm's All-Attorney Summit
Excerpt from Practical Guidance
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.
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How Bankrupt Cos. Can Seek Refunds For Illegal Tariffs
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.
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Legal And Industry Impacts Of America's Maritime Action Plan
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.
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4 Ways To Help CBP Curb Shell Co. Import Schemes
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.
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7 Steps For Gov't Contractors In Post-IEEPA Tariff Landscape
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.
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The Benefits Of Choosing A Niche Practice In The AI Age
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.
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Section 122 Tariffs Show Shift In Strategy, Not Trade Policy
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.
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Tax Court Ruling Signals Cross-Border Loan Scrutiny
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.
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Lessons From Justices' Split On Major Questions Doctrine
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.
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Resilience Planning As Nat'l Security Shifts Tech Import Policy
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.
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How The New Tariff Landscape May Unfold
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.
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What Orgs. Should Note In IRS Group Tax Exemption Overhaul
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.
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How Banks Can Apply FinCEN Beneficial Ownership Relief
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.