Federal
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October 05, 2026
Novel Strategy Prompted ETF Guidance, Treasury Atty Says
The U.S. Department of the Treasury's recent revenue ruling and notice cracking down on improper arrangements using legitimate exchange-traded fund conversions was a response to a marketed transaction that was not squarely addressed by existing rules targeting abusive practices, a department official said Monday.
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October 05, 2026
Tax Pros From Brazil, Canada Highlight APA Challenges
Brazil's nascent transfer pricing system isn't yet prepared for an influx of advance pricing agreement requests, a tax specialist from that country said Monday, while a Canadian attorney said the APA process in his country increasingly resembles an in-depth audit.
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October 05, 2026
IRS Loses Bid For Tax Withholdings In Ch. 11 Camp Sales
A New Jersey bankruptcy judge determined on Monday that the buyers of seven summer camps owned by Simad Holdings Ltd. need not withhold taxes under rules governing the sale of U.S. property by foreign owners, overruling an objection by the Internal Revenue Service.
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October 05, 2026
7th Circ. Rejects Ex-Club Prez's Claim Of Fake Canceled Debt
The Seventh Circuit upheld the dismissal of a former country club president's claim that the club filed a fraudulent information return with the IRS reporting a canceled debt, saying he failed to make a case for overturning precedent that limited taxpayers' ability to seek damages for fraudulent return filings.
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October 05, 2026
Philippine Airlines Asks Tax Court To Cut $5.7M Off Tax Bill
The IRS cannot deny Philippine Airlines a tax exemption on income from passengers and excess baggage just because the Philippines taxes cargo income, the airline told the U.S. Tax Court in a bid to cut more than $5.7 million off a $7.1 million tax bill.
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October 05, 2026
Bilzin Sumberg Expands Tax Practice With Nelson Mullins Atty
Bilzin Sumberg Baena Price & Axelrod LLP has expanded its tax and private wealth practice with the addition of a Miami-based partner from Nelson Mullins Riley & Scarborough LLP.
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October 05, 2026
IRS Leaked Whistleblower's Tax Info to DOJ, Agent's Suit Says
An agent in the IRS Criminal Investigation unit has accused the agency of leaking his personal tax information to the U.S. Department of Justice in retaliation against him for blowing the whistle on what he said was mismanagement in the branch's Chicago office.
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October 05, 2026
Feds Aim To Improve Health Cost Clarity With Final Reg
The federal government unveiled a final rule Monday intended to make it easier to understand healthcare pricing information that President Donald Trump's first administration required private-sector healthcare plans to disclose, a move that agencies said was needed because previous regulations triggered a deluge of data.
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October 05, 2026
High Court Won't Consider $30M Argentine Bondholder Claim
Argentine bondholders claiming the Second Circuit wrongly upheld a block of over $30 million in contractual claims against Argentina won't get a chance to argue their stance at the U.S. Supreme Court, as the justices declined on Monday to review the case.
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October 05, 2026
Justices Won't Hear Corporate Transparency Act Challenges
The U.S. Supreme Court on Monday declined to hear two cases challenging the Corporate Transparency Act, a law designed to establish a national beneficial ownership registry for law enforcement agencies investigating shell companies that was severely curtailed by the U.S. Department of the Treasury.
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October 05, 2026
Tax Prep CEO Cops To Fraud After Feds Charge $25M IRS Con
A New York City tax preparation CEO pled guilty to defrauding the IRS on Monday, after federal prosecutors charged him and two associates with claiming $25 million of fake deductions while telling clients: "You really aren't paying my fee. The IRS is."
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October 05, 2026
Justices Decline To Weigh Travel Co.'s Challenge To Wis. Tax
The U.S. Supreme Court declined on Monday to take up a travel company's claims that its provision of travel services sold by Wisconsin-based agents through an online portal qualified for a federal law's protections against state income tax.
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October 02, 2026
Crime Fraud Exception Sought In Ex-Adams Aide's Bribe Case
Prosecutors on Friday said the crime fraud exception should greenlight access to privileged material as part of their case against former New York Mayor Eric Adams' chief of staff, who's accused of taking bribes in exchange for steering a $6.8 million migrant housing contract to a Queens hotel owner.
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October 02, 2026
Fed. Circ. Declines To Revisit Part Of $1.5M Tax Penalty Case
The Federal Circuit on Friday denied a Pennsylvania electrical contractor's bid for the court to revisit part of a July ruling that gave the company another chance to pursue a $1.53 million refund claim for penalties paid to the IRS after its owner pled guilty to criminal tax evasion.
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October 02, 2026
Int'l Tax In September: Facebook Ruling, BEAT Bill And More
September kicked off with the announcement of tariffs on semiconductors and ended with the U.S. Tax Court's long-awaited ruling on a computational dispute involving Facebook, with Siemens USA's trial and a bill that would change the U.S. base erosion and anti-abuse tax in the middle. Here, Law360 looks at some of the biggest international tax developments of the past month.
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October 02, 2026
DOJ Can't Reverse IRS Curtailing Of $2.4M Penalty, Court Says
The Department of Justice lacked the authority to reverse the IRS' abatement of a man's penalty of nearly $2.4 million for promoting abusive tax shelters after the agency realized a supervisor hadn't signed off on it, an Illinois federal court said.
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October 02, 2026
Dems Slam Proposed Limit On Tax Credits For Immigrants
A group of Democratic senators urged the U.S. Department of the Treasury to scrap proposed rules that would cut off refundable tax credits to certain immigrants living in the U.S. legally, arguing that the guidance oversteps regulatory authority and would create a "byzantine" system.
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October 02, 2026
2nd Circ. Forges Own Path In Limited Partner Tax Ruling
The Second Circuit's decision limiting a self-employment tax break for limited partners with significant managerial roles reached a conclusion similar to that of a recent Fifth Circuit ruling, but practitioners said notable differences between them create a split requiring resolution by the IRS, the U.S. Supreme Court or Congress.
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October 02, 2026
Former Fla. Rep. Gets 10 Years In Venezuela FARA Case
A Florida federal judge on Friday sentenced ex-Florida Rep. David Rivera to 10 years in prison for failing to register as a foreign agent and laundering the proceeds of a $50 million contract with a unit of Venezuela's state-owned oil company.
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October 02, 2026
Taxation With Representation: Hogan Lovells, Davies, Sidley
In this week's Taxation With Representation, semiconductor company Advanced Micro Devices buys AI model developer and research lab World Labs, Brixmor Property Group and private investment management firm Everview Partners acquire Slate Grocery REIT, and cyberintelligence company REDLattice merges with blank check company Bold Eagle Acquisition Corp.
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October 02, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included the release of emissions rates used to calculate the tax credit amount for the domestic production of less-carbon-intensive transportation fuel.
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October 01, 2026
Tax Court OKs Denial Of Whistleblower Award For Bond Info
The IRS properly denied a whistleblower's award claim for reporting a nonprofit correctional corporation that he said failed to meet its tax obligations related to bonds it issued, the U.S. Tax Court ruled, saying the agency didn't collect proceeds from an investigation into the matter.
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October 01, 2026
IRS Proposes Scholarship Contribution Tax Credit Rules
The IRS proposed rules for the new federal tax credit for contributions to scholarship-granting organizations ahead of its planned launch at the start of 2027, including definitions of certain terminology and reporting requirements.
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October 01, 2026
Walmart Hit With New Tariff Suit As Refund Blitz Continues
Walmart must compensate customers who "bore the economic burden" of Trump administration tariffs before the U.S. Supreme Court struck them down in February, according to a proposed class action in Connecticut federal court that claims the retail behemoth has no plans to share its $2.9 billion refund.
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October 01, 2026
Md. Cancer Research Lab Says $4.5M Tax Bill Unconstitutional
A Maryland cancer research laboratory that said it had no income in 2021 is contesting IRS tax assessments totaling $4.5 million, telling the U.S. Tax Court that the government's imputing of an underpayment violates the U.S. Constitution.
Expert Analysis
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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.
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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.
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Aligning Microsoft Tools With NYC Bar AI Recording Guidance
The New York City Bar Association’s recently issued formal opinion, providing ethical guidance on artificial intelligence-assisted recording, transcription and summarization, raises immediate questions about data governance and e-discovery for companies that use Microsoft 365 and Copilot, say Staci Kaliner, Martin Tully and John Collins at Redgrave.