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Federal
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April 22, 2026
7th Circ. Revives $300M Hyatt Rewards Tax Dispute
The U.S. Tax Court relied on an incomplete analysis when it sided with the IRS and held that nearly $300 million in revenue from Hyatt Hotels' loyalty rewards program fund should be treated as taxable income, the Seventh Circuit held Wednesday.
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April 22, 2026
Temp Agency Owner's Tax Convictions Upheld By 1st Circ.
The First Circuit on Wednesday affirmed the convictions of a Quincy, Massachusetts, temp agency owner who prosecutors said evaded more than $800,000 in payroll taxes by paying employees under the table.
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April 22, 2026
Spinoff Landscape Unclear In Wake Of Tossed IRS Guidance
The Internal Revenue Service has scrapped controversial guidance that limited the types of spinoff transactions that revenue officials would approve as tax-free ahead of time, but the path to seeking the agency's blessing for certain intercompany reorganizations remains hazy.
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April 22, 2026
Split 6th Circ. Lets Brewer Challenge Tax Code's Distilling Ban
An Ohio brewery owner has standing to challenge the constitutionality of the federal tax code's ban on distilling whiskey at home, but the ban is necessary for the government to collect taxes on distilled spirits, a split Sixth Circuit panel ruled.
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April 22, 2026
Tax Court Denies Boutique Owner's Biz, Rental Deductions
A Missouri boutique owner offered limited support to claim business and rental property expense deductions in her 2017 and 2019 returns, the U.S. Tax Court ruled Wednesday, siding with the IRS that she underreported her taxable income.
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April 22, 2026
Nintendo Customers Jump In On Tariff Refund Suits
Video game giant Nintendo stands to make "windfall profits" through refunds of President Donald Trump's now-invalidated global tariff regime since those costs were actually passed on to consumers, a proposed class action in Washington federal court said, joining the chorus of customers looking to secure tariff-related refunds.
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April 22, 2026
$1.4B Budget Cut Wouldn't Hinder IRS Update, Bessent Says
Treasury Secretary Scott Bessent told Senate lawmakers Wednesday that a $1.4 billion cut in the Internal Revenue Service's budget next year would still allow the agency to modernize its technology and provide better digital customer service to taxpayers.
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April 22, 2026
USTR Seeking 'Outcomes' On DSTs, Stronger USMCA Rules
U.S. Trade Representative Jamieson Greer told a U.S. House of Representatives panel Wednesday that efforts to eliminate digital service taxes implemented by jurisdictions across the world continue to be prioritized by President Donald Trump's administration, and potential tariff actions are ready in waiting.
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April 22, 2026
Liberty Global Loses $2.4B Tax Substance Fight In 10th Circ.
Telecommunications giant Liberty Global is not entitled to a $2.4 billion deduction tied to transactions with its foreign affiliates, the Tenth Circuit ruled in a long-awaited opinion, siding with the U.S. government in finding the arrangement is a tax shelter lacking economic substance.
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April 22, 2026
Gov't Settles Suit Over $28M Tax Bill, Bahamian Trusts
The U.S. government reached a settlement in federal court with a Floridian who invoked Bahamian law to avoid repatriating trust funds that had resulted in a $28 million tax bill.
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April 22, 2026
Why Insurance Capital Is Courting REITs
Private equity firms are looking to invest in joint ventures with real estate investment trusts in order to put some of their vast sum of insurance capital to work.
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April 21, 2026
House Panel Votes To Gut Corporate Transparency Act
A House finance committee advanced a bill Tuesday that would defang the Corporate Transparency Act by exempting all domestically owned companies from compliance, codifying a limitation already implemented by the U.S. Department of the Treasury.
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April 21, 2026
Atty Loses Latest Bid To Delay Prison In $22M Tax Fraud Case
The U.S. Bureau of Prisons is capable of handling a St. Louis attorney's outpatient needs, a North Carolina federal judge said, denying her request to delay her prison report date after she was convicted of helping perpetrate a $22 million tax fraud scheme.
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April 21, 2026
IRS Says Meta Pricing Adjustments Not Barred By Prior Ruling
The U.S. Tax Court's opinion on the pricing of Meta predecessor Facebook's transferred intangible assets doesn't prevent the IRS from making periodic adjustments based on transactions occurring over the life of the company's cost-sharing arrangement with an Irish subsidiary, the agency argued.
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April 21, 2026
Pot Management Co. Says It's Allowed Biz Tax Deduction
A California-based management company linked to cannabis operations is challenging the IRS over a $4.2 million tax bill, according to a U.S. Tax Court petition, arguing that the company does not traffic in controlled substances that would otherwise bar it from claiming business deductions.
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April 21, 2026
IRS Lists Over 1,400 Individuals Who Lost US Citizenship
The Internal Revenue Service on Tuesday issued a list of more than 1,400 individuals who lost U.S. citizenship during the first quarter of the year, a slight uptick from a year ago.
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April 21, 2026
GE Says IRS Is Probing Its Tax Math Under 2017 Overhaul
The Internal Revenue Service is auditing General Electric's income tax returns over computations the company made under the 2017 federal tax overhaul, according to a Tuesday filing with the U.S. Securities and Exchange Commission.
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April 20, 2026
Little-Known Gambling Tax Could Upend Boom In US Betting
After a record year for U.S. commercial gaming, a little-known tax on phantom income in last year's Republican reconciliation law has spurred bipartisan repeal efforts amid concerns it could alter betting behavior and drain state and local economies built on gambling-related tourism.
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April 20, 2026
Ga. Partnership Defends $60M Deduction For Land Gift
A Georgia partnership said the IRS wrongly denied its $60.2 million deduction for land donated to a charitable organization in 2020, leading to an assessed underpayment of $22.3 million and penalties of $8.9 million for that year.
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April 20, 2026
IRS Updates FAQs For Educational Assistance Programs
The IRS updated its FAQs on Monday to clarify that an employee's gross income does not include educational assistance benefits if those benefits are provided under certain educational assistance programs and the amounts do not exceed $5,250.
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April 20, 2026
Tax Court Denies Woman COVID Credits Over Limited Proof
A Maryland woman is not entitled to $28,000 in COVID-19-related sick and family leave credits she claimed in 2021, the U.S. Tax Court said Monday, saying there was not enough proof that she was sick with the virus or was otherwise qualified for the relief.
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April 20, 2026
Justices Won't Review Doctor's Captive Insurance Tax Fight
The U.S. Supreme Court won't review the Internal Revenue Service's rejection of a Texas doctor's claim to $1 million in tax deductions linked to his urgent care network's captive insurance company, the court said Monday.
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April 20, 2026
Ineligible Firms Receiving Payroll Tax Credit, TIGTA Says
The IRS has updated its controls for a payroll tax credit available to small businesses for increasing research activities, but ineligible taxpayers continue to receive it, the Treasury Inspector General for Tax Administration said in a report released Monday.
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April 20, 2026
Ala. Partnership Defends $8.5M Deduction For Donated Land
An Alabama partnership was entitled to deduct $8.5 million for more than 126 acres it donated to a land conservancy — property that otherwise could have been developed as single-family lots, the partnership told the U.S. Tax Court.
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April 20, 2026
NY Atty Says Okla. Law Firm Misclassified, Denied Benefits
A New York attorney has filed a $3.1 million contract suit against her former employer, accusing an Oklahoma-based national litigation firm of terminating her employment after she requested an overdue invoice, following more than three years of full-time contract work without benefits.
Expert Analysis
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NYC Bar Opinion Warns Attys On Use Of AI Recording Tools
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.
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4 Quick Emotional Resets For Lawyers With Conflict Fatigue
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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Rescheduling Cannabis Marks New Tax Era For Operators
As the attorney general takes steps to move cannabis from Schedule I to Schedule III of the Controlled Substances Act, operators and advisers should prepare by considering the significant changes this will bring from tax, state, industry and market perspectives, says Michael Harlow at CohnReznick.
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Judges On AI: How Judicial Use Informs Guardrails
U.S. Magistrate Judge Maritza Dominguez Braswell at the U.S. District Court for the District of Colorado discusses why having a sense of how generative AI tools behave, where they add value, where they introduce risk and how they are reshaping the practice of law is key for today's judges.
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Presidential Pardon Brokering Can Create Risks For Attys
The emergence of an apparent “pardon shopping” marketplace, in which attorneys treat presidential pardons as a market product, may invite investigative scrutiny of counsel and potential criminal charges grounded in bribery, wire fraud and other statutes, says David Klasing at The Tax Law Offices of David W. Klasing.
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Key False Claims Act Trends From The Last Year
The False Claims Act remains a powerful enforcement tool after some record verdicts and settlements in 2025, and while traditional fraud areas remain a priority, new initiatives are raising questions about its expanding application, says Veronica Nannis at Joseph Greenwald.
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Hosting Exchange Students Makes Me A Better Lawyer
Opening my home to foreign exchange students makes me a better lawyer not just because prioritizing visiting high schoolers forces me to hone my organization and time management skills but also because sharing the study-abroad experience with newcomers and locals reconnects me to my community, says Alison Lippa at Nicolaides Fink.
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How A 1947 Tugboat Ruling May Shape Work Product In AI Era
Rapid advances in generative artificial intelligence test work-product principles first articulated in the U.S. Supreme Court’s nearly 80-year-old Hickman v. Taylor decision, as courts and ethics bodies confront whether disclosure of attorneys’ AI prompts and outputs would reveal their thought processes, say Larry Silver and Sasha Burton at Langsam Stevens.
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Navigating Privilege Law Patchwork In Dual-Purpose Comms
Three years after the U.S. Supreme Court declined to resolve a circuit split in In re: Grand Jury, federal courts remain split as to when attorney-client privilege applies to dual-purpose legal and business communications, and understanding the fragmented landscape is essential for managing risks, say attorneys at Covington.
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Cannabis Industry Faces An Inflection Point This Year
Cannabis industry developments last year — from the passage of a new wholesale tax in Michigan, to an executive order accelerating the federal rescheduling process — presage a more mature phase of legalization this year, with hardening expectations and enforcement to come, says Alex Leonowicz at Howard & Howard.
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4 Ways GCs Can Manage Growing Service Of Process Volume
As automation and arbitration increase the volume of legal filings, in-house counsel must build scalable service of process systems that strengthen corporate governance and manage risk in real time, says Paul Mathews at Corporation Service Co.
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The Law Firm Merger Diaries: Forming Measurable Ties
Relationship-building should begin as early as possible in a law firm merger, as intentional pathways to bringing people together drive collaboration, positive client response, engagements and growth, says Amie Colby at Troutman.
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3 Key Takeaways From Planned Rescheduling Of Cannabis
An executive order reviving cannabis rescheduling represents a monumental change for the industry and, while the substance will remain illegal at the federal level, introduces several benefits, including improving state-legal cannabis operators' tax treatment, lowering the industry's legal risk profile, and leaving state-regulated markets largely intact, say attorneys at Dentons.