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Federal
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July 09, 2026
Okla. Tax Officials Say McGirt Can't Upend Osage Ruling
Oklahoma tax officials say the Osage Nation can't rely on a 2020 landmark U.S. Supreme Court ruling to overturn a decision that declined to vacate a 16-year-old determination that its reservation boundaries had been disestablished, telling the Tenth Circuit that the tribe's challenge is too late.
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July 09, 2026
IRS Asks 7th Circ. To Rehear $300M Hyatt Perks Tax Dispute
The IRS asked the Seventh Circuit to reconsider its decision to remand a dispute over $300 million in Hyatt Hotels' loyalty rewards program fund to the U.S. Tax Court for it to determine whether the money can be excluded from taxable income under what's known as the claim of right doctrine.
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July 09, 2026
IRS Updates Outdated References In Estate Tax Rules
The Internal Revenue Service released final regulations that modify and replace outdated references in rules for deceased taxpayers who have passed their property to a noncitizen spouse in a domestic trust.
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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.
Expert Analysis
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Trivia Competition Makes Me A Better Lawyer
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.
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Judges On AI: Practical Use Cases In Chambers
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.
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What's At Stake In Possible Circuit Split On Medicaid Rule
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.
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Malpractice Claim Assignability Continues To Divide Courts
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.
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Where PCAOB Goes Next After A Year Of Uncertainty
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.
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5th Circ. Ruling Clarifies Tax Rules For Limited Partners
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.
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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.