Federal
-
September 10, 2026
Tax Court Nod To Income Approach Props Easement Valuation
The IRS has been adversarial toward taxpayers using what is known as the income approach to value conservation easements, but the method's legitimacy was significantly reinforced by the U.S. Tax Court in a recent decision that endorsed the use of the method to value a Los Angeles-area donated property.
-
September 10, 2026
US Asks 1st Circ. To Back $3.3M Tax Bill For 'Survivor' Winner
A Rhode Island federal court correctly entered a $3.3 million tax judgment against the first "Survivor" winner, the government told the First Circuit, saying the former contestant failed to refute the tax assessments and had agreed to a U.S. Tax Court decision that determined his liability and penalties.
-
September 09, 2026
Defunct Tax Startup CEO Charged In $13.3M Investor Fraud
The CEO of a defunct tax-compliance startup has been arrested on fraud charges based on allegations she defrauded investors out of more than $13 million by lying about her credentials and her company's revenues, the U.S. Department of Justice said Wednesday.
-
September 09, 2026
Tax Pros Recall Wrangling Over Siemens' Restructuring
Tax professionals from Siemens and Deloitte described for the U.S. Tax Court on Tuesday and Wednesday the wrangling that went on between the German company and its advisers over the 2018 restructuring plan that led to a $3.5 billion tax deduction in the U.S.
-
September 09, 2026
11th. Circ. Upholds Ga. Tax Fraudster's 12½-Year Sentence
The Eleventh Circuit affirmed on Wednesday a12½-year prison sentence for an Atlanta man who was convicted of masterminding a fraudulent tax return scheme that brought in millions of dollars.
-
September 09, 2026
Tax Court Backs IRS On Partnership Adjustment Deadline
An Internal Revenue Service notice disallowing a charitable deduction claimed by a Louisiana business partnership was issued in a timely fashion because both sides agreed to an extension that applied to the entire process, the U.S. Tax Court ruled Wednesday.
-
September 09, 2026
Economists Tell Fed. Circ. Float Rates Bar Temporary Tariff
President Donald Trump's temporary global tariff lacked legal justification in the current international monetary system, a group of economists, including former U.S. Treasury secretary and Federal Reserve Chair Janet Yellen, told the Federal Circuit on Wednesday in a brief supporting challenges to the duties.
-
September 09, 2026
10th Circ. Sets Redo Of Tax Fraud Case To Study Legal Advice
The Tenth Circuit ordered a Kansas federal court to revisit a woman's assertions that ineffective counsel led her to plead guilty to bank and tax fraud charges, saying the trial court needs to further examine whether she indeed received insufficient legal advice.
-
September 09, 2026
US Bans Canadian Alcohol, Motorcycles After Tariff Retaliation
President Donald Trump continued the U.S. trade offensive against Canada after its northern neighbor's retaliatory tariffs went into effect, announcing a ban on Canadian imports of certain alcohol, dairy products and motorcycles starting this month.
-
September 08, 2026
Judge Nixes Atty's Bid For More Depositions In $12M Tax Suit
A Colorado federal judge denied a request for additional depositions from counsel of an attorney and others accused of siphoning $12 million while advocating an illegal tax fee after determining the request for the depositions was untimely and made outside the discovery window.
-
September 08, 2026
Tax Court Adds Five New Trial Locations, Expands Roles
The U.S. Tax Court's chief judge announced that the court will hear cases in five new cities starting Tuesday, bringing the total to 79, while allowing all types of cases to be heard at each location.
-
September 08, 2026
Eaton Challenges IRS Example On Intercompany Loans
The IRS is misusing a regulatory example that is unrelated to its argument that Eaton cannot pay foreign affiliates for support that a lender would assume exists in the agency's bid to reduce related-party interest rates and fees, the company told the U.S. Tax Court.
-
September 08, 2026
Senate Panel Sets Hearing On IRS Chief Counsel Pick
The Senate Finance Committee will hold a hearing to consider four of President Donald Trump's nominees for various positions, including chief counsel at the Internal Revenue Service, the panel announced Tuesday.
-
September 08, 2026
IRS Sets Emission Guidance For Biofuel Tax Credit Eligibility
The IRS released Tuesday the emissions rates use to calculate the tax credit amount for the domestic production of less carbon intensive transportation fuel, including those made primarily of organic materials and other compounds derived from livestock manure.
-
September 08, 2026
With New Tax Partner, Simpson Thacher Boosts Sports Focus
Jonathan Westreich joined Simpson Thacher & Bartlett LLP as a tax partner in its Los Angeles office, the firm announced Tuesday, deepening the firm's sports, media and entertainment bench.
-
September 08, 2026
IRS Accepting Applications To 2027 Real-Time Audit Program
The Internal Revenue Service is accepting applications for its compliance assurance process real-time audit program for 2027, the agency announced Tuesday.
-
September 08, 2026
Canada Defends Retaliatory Tariffs Against US As Necessary
Canadian Prime Minister Mark Carney defended Canada's retaliatory tariffs against the U.S. as they went into effect Tuesday, saying they are needed to protect Canadian workers and industries from President Donald Trump's latest trade war action.
-
September 08, 2026
DC Circ. Affirms Injunction Against IRS-ICE Data Sharing
The D.C. Circuit affirmed a lower court's preliminary injunction Tuesday barring the IRS from sharing taxpayer data with immigration authorities, finding that the coalition challenging the deal has standing and that the arrangement likely violates the law.
-
September 04, 2026
DOJ Ordered To Turn Over 'Weaponization' Fund Discovery
A Virginia federal magistrate judge ordered the Trump administration Friday to move quickly in turning over documents connected to its proposed "Anti-Weaponization Fund," including the names of those who structured it before the idea was shot down in several federal courts and withdrawn by the U.S. Department of Justice.
-
September 04, 2026
4 Books Transfer Pricing Economists Think You Should Read
What do transfer pricing experts — economists, specifically — do in the summer? In July, many of them attend the National Association for Business Economics' annual transfer pricing symposium and discuss their favorite books with Law360 during the coffee breaks. Others were kind enough to do it during their regular work hours. Here, Law360 looks at four of their picks.
-
September 04, 2026
IRS Finalizes 50% Personal-Use Test For Car Loan Tax Break
A vehicle's amount of personal use would be based on the buyer's expected use over the period of ownership for purposes of determining eligibility for the tax break on car loan interest enacted in last summer's budget law, according to final regulations released Friday.
-
September 04, 2026
ERISA Recap: 5 Appellate Rulings To Know From August
The Seventh Circuit kept an Arkansas pharmacy benefit manager rule in place as not preempted by federal benefits law, the Fourth Circuit revived an Altria ex-worker's dispute over benefit plan documents, and the Eleventh Circuit reversed a pretrial win for Royal Caribbean in cruise workers' suit challenging 401(k) funds. Here, Law360 looks at those and two other major appellate decisions from August involving ERISA that benefits attorneys may want to know.
-
September 04, 2026
Chrisleys Fight Balch & Bingham's Bid To Ax Malpractice Suit
Reality television stars Todd and Julie Chrisley asked a Georgia federal judge on Friday to reject an attempt by their former attorneys to dismiss a legal malpractice lawsuit that claims a critical pretrial mistake allowed evidence obtained through an unlawful search to be used against them at their criminal trial.
-
September 04, 2026
4th Circ. Affirms $2.9M IRS Fine For Unreported Accounts
The Fourth Circuit affirmed a $2.9 million fine Friday against a Hong Kong-based U.S. businessman, holding that he should have known there was a "grave risk" of inaccurate tax filings when he failed to disclose offshore accounts to the IRS.
-
September 04, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included proposed rules addressing the 2025 federal budget bill's changes to how U.S. corporations account for the earnings of their offshore affiliates when calculating their taxable income.
Expert Analysis
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
Parsing Clarifications On Foreign Entity Rules For Tax Credits
Recent U.S. Internal Revenue Service and Treasury Department guidance answers taxpayer questions on several key foreign entity rules under the One Big Beautiful Bill Act, but questions remain over transactions with companies that have ties to covered nations such as Iran, say attorneys at Cleary.