Federal
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January 07, 2026
Tax Funding Oil Spill Cleanups Has Expired, IRS Clarifies
The Internal Revenue Service clarified Wednesday that the part of an added tax on crude oil and petroleum products earmarked for an oil spill cleanup fund expired at the end of 2025.
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January 07, 2026
Feds Want To Use Goldstein's Comments To NYT At Trial
Federal prosecutors preparing to try SCOTUSblog founder Tom Goldstein for tax crimes next week are looking to use his comments in a New York Times Magazine article against him, claiming that admissions and details from the article "directly prove" certain charges the government has brought.
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January 07, 2026
IRS Mulling Budget Bill's Changes To CFC Rules, Official Says
The Internal Revenue Service is weighing a balance between precision and administrability as it works on guidance for U.S. shareholders of foreign companies after the federal budget bill changed how to allocate overseas income, an agency official said Wednesday.
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January 07, 2026
IRS Outlines Process For PFICs Seeking Retroactive Elections
The Internal Revenue Service set out requirements Wednesday for passive foreign investment corporations seeking rulings to allow them to make retroactive qualified electing fund elections.
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January 06, 2026
Ex-Moving Co. Exec Denied New Trial In $8M Payroll Tax Case
A former moving company president who was convicted of scheming to defraud the Internal Revenue Service out of nearly $8 million in payroll taxes cannot get his verdict vacated, a New York federal court ruled, denying his claim of ineffective counsel as untimely.
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January 06, 2026
Tax Groups Push Supreme Court On California Tax Rule
A special income tax rule California uses along with its single-sales-factor apportionment method creates distortion and the U.S. Supreme Court should decide if it also violates the constitution, a taxpayer group said Tuesday.
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January 06, 2026
Tax Court Tosses $189K Charity Deduction For Lack of Proof
A California couple is not entitled to deduct nearly $189,000 for thousands of items they donated to a charity, the U.S. Tax Court ruled Tuesday, finding they failed to provide sufficient documentation to substantiate the value of the donated goods.
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January 06, 2026
Tax Court Strips Exempt Status From Powdered Milk Donor
An organization that sent powdered milk donations for children overseas was mostly running a commercial coffee shop and was therefore not entitled to tax-exempt status, the U.S. Tax Court said Tuesday, agreeing with the Internal Revenue Service.
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January 06, 2026
IRS Appeals Pause Of ICE Info-Sharing Agreement
The Internal Revenue Service is appealing to the D.C. Circuit a federal court order temporarily stopping the agency from sharing confidential taxpayer addresses with immigration enforcement officials, according to a filing Tuesday in D.C. federal court.
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January 06, 2026
Tax Firm Says IRS Can't Justify Microcaptive Reporting Rules
A global tax services provider urged a Texas federal court to vacate tax reporting rules for microcaptive insurance companies, arguing that the Internal Revenue Service failed to provide evidence of tax evasion that would justify the regulations.
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January 06, 2026
Paul Hastings Adds Ex-Cravath Tax Pro To Growing M&A Team
After adding 20 partners to its mergers and acquisitions platform over the past two years, Paul Hastings LLP announced on Tuesday that it has hired a former Cravath Swaine & Moore LLP partner who advises on the tax elements of mergers and acquisitions.
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January 05, 2026
Feds Fight To Keep Goldstein 'Sham Employee' Evidence
Federal prosecutors heading to trial against former SCOTUSblog publisher Tom Goldstein are urging a judge to deny his bid to prevent a jury from hearing about four love interests allegedly paid as no-show employees at his former law firm.
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January 05, 2026
'Truly Extreme': 9th Circ. Judges Decry Trump Layoffs Ruling
The Ninth Circuit on Monday refused to revisit a three-judge panel's decision rejecting the Trump administration's challenge of a lower court's ruling requiring production of its plans for large-scale layoffs and reorganizations at various federal agencies, a decision that was met with fiery dissent from several of the court's Republican-appointed judges.
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January 05, 2026
3rd Circ. Won't Rethink Tax On Interest In $191M Pharma Deal
The Third Circuit declined to reconsider its decision that a pharmaceutical company's $191 million payment settling a family feud was for the sale of a family trust's ownership shares and included interest that should be taxed as ordinary income.
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January 05, 2026
Partnership Fights Axed $60M Tax Break For Conservation Gift
A partnership challenged the IRS' denial of its nearly $60 million tax deduction for protecting forestland and other open space in Georgia, telling the U.S. Tax Court the land could have been used for valuable granite mining before the partnership stopped it from being developed.
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January 05, 2026
Countries Reach Deal To Exempt US From Pillar 2 Tax
Nearly 150 countries finalized the details Monday of a safe harbor that would effectively exempt U.S. companies from a 15% global minimum tax known as Pillar Two, following months of international negotiations and retaliatory tax threats from the U.S.
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January 05, 2026
Gibson Dunn Adds Sidley Tax Pro In Silicon Valley
Gibson Dunn & Crutcher LLP announced Monday that it has bulked up its tax practice group with a partner in Palo Alto, California, who previously co-led the global tax practice and headed up the West Coast tax group at Sidley Austin LLP.
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January 05, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, dated Monday, included guidance for new tax relief for farmers who pay capital gains tax on a farmland property sale to another farmer.
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January 02, 2026
Ga. Partnership Contests Denial Of $15.7M Property Donation
A Georgia partnership invoked the Fifth Amendment in defending its $15.7 million conservation easement tax deduction in the U.S. Tax Court, arguing that the IRS in denying the deduction effectively is taking private property for public use without just compensation.
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January 02, 2026
Busy DOJ Tax Atty Seeks More Time In 7th Circ. AbbVie Case
A U.S. Department of Justice tax attorney asked the Seventh Circuit on Friday for another extension to file an opening brief in a dispute over AbbVie's $1.6 billion payment to an Irish biotechnology company, citing staffing shortages and internal procedural requirements.
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January 02, 2026
IRS Floats 50% Personal-Use Test For Car-Loan Tax Break
Individuals, trusts and estates could claim up to $10,000 for the new auto-loan interest deduction only if the vehicle was used more than 50% of the time for personal purposes under proposed regulations published Friday by the IRS.
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January 02, 2026
IRS Floats Updates To Fee Paid By Brand Drugmakers
The Internal Revenue Service floated updates to regulations governing how branded prescription drug manufacturers or importers should calculate an annual fee established by the Affordable Care Act, a move the agency said aims to incorporate changes in drug discount programs and clarify tax reporting.
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January 02, 2026
Guns, Taxes & Labor: Cannabis Litigation Trends To Watch
In 2026, courts throughout the U.S. will consider cases weighing Second Amendment rights of cannabis users, a punitive federal tax policy that affects state-legal marijuana businesses, labor peace requirements in the cannabis space, and whether a constitutional doctrine bars states from preferencing their residents in doling out marijuana licenses.
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January 02, 2026
Federal Tax Policy To Watch In 2026
Changes to federal tax policy are relatively uncommon in midterm election years as lawmakers, many of whom prioritize political positioning over major tax overhauls, show little appetite for sweeping legislation or even narrower fixes that could attract bipartisan support. Here, Law360 examines federal tax policy to watch in 2026.
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January 02, 2026
Top Federal Tax Cases To Watch In 2026
The application of self-employment taxes to limited partners, the economic substance doctrine's threshold and the question of whether IRS penalties need a jury's deliberation are topics federal courts likely will examine in coming decisions. Here, Law360 reviews the top federal tax cases to watch in the coming year.
Expert Analysis
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What To Watch As NY LLC Transparency Act Is Stuck In Limbo
Just about a month before it's set to take effect, the status of the New York LLC Transparency Act remains murky because of a pending amendment and the lack of recent regulatory attention in New York, but business owners should at least prepare for the possibility of having to comply, says Jonathan Wilson at Buchalter.
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Despite Deputy AG Remarks, DOJ Can't Sideline DC Bar
Deputy Attorney General Todd Blanche’s recent suggestion that the D.C. Bar would be prevented from reviewing misconduct complaints about U.S. Department of Justice attorneys runs contrary to federal statutes, local rules and decades of case law, and sends the troubling message that federal prosecutors are subject to different rules, say attorneys at HWG.
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8th Circ. Decision Shipwrecks IRS On Shoals Of Loper Bright
The Eighth Circuit’s recent decision invalidating transfer pricing regulations in 3M Co. v. Commissioner may be the most significant tax case implementing Loper Bright's rejection of agency deference as a judicial tool in statutory construction, says Edward Froelich at McDermott.
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Rule Amendments Pave Path For A Privilege Claim 'Offensive'
Litigators should consider leveraging forthcoming amendments to the Federal Rules of Civil Procedure, which will require early negotiations of privilege-related discovery claims, by taking an offensive posture toward privilege logs at the outset of discovery, says David Ben-Meir at Ben-Meir Law.
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Litigation Funding Could Create Ethics Issues For Attorneys
A litigation investor’s recent complaint claiming a New York mass torts lawyer effectively ran a Ponzi scheme illustrates how litigation funding arrangements can subject attorneys to legal ethics dilemmas and potential liability, so engagement letters must have very clear terms, says Matthew Feinberg at Goldberg Segalla.
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SEC's Dual Share Class Approval Signals New Era For ETFs
The U.S. Securities and Exchange Commission's recent approval of the dual share class structure marks a landmark moment for the U.S. fund industry, opening the door for asset managers to benefit from combining mutual fund and exchange-traded fund share classes under a single portfolio, say Ilan Guedj at Bates White and Brian Henderson at George Washington University.
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E-Discovery Quarterly: Recent Rulings On Dynamic Databases
Several recent federal court decisions illustrate how parties continue to grapple with the discovery of data in dynamic databases, so counsel involved in these disputes must consider how structured data should be produced consistent with the requirements of the Federal Rules of Civil Procedure, say attorneys at Sidley.
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What To Do If A Retirement Plan Participant Is Deported
Given recent immigration policy changes in the U.S., many businesses are experiencing employee deportations, but retirement plan administrators should still pay and report benefits to avoid violating the plan, the Employee Retirement Income Security Act or tax reporting requirements, says Teri King at Smith Gambrell.
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Defeating Estoppel-Based Claims In Legal Malpractice Actions
State supreme court cases from recent years have addressed whether positions taken by attorneys in an underlying lawsuit can be used against them in a subsequent legal malpractice action, providing a foundation to defeat ex-clients’ estoppel claims, says Christopher Blazejewski at Sherin and Lodgen.
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The Biz Court Digest: How It Works In Massachusetts
Since its founding in 2000, the Massachusetts Business Litigation Session's expertise, procedural flexibility and litigant-friendly case management practices have contributed to the development of a robust body of commercial jurisprudence, say James Donnelly at Mirick O’Connell, Felicia Ellsworth at WilmerHale and Lisa Wood at Foley Hoag.
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Why Appellees Should Write Their Answering Brief First
Though counterintuitive, appellees should consider writing their answering briefs before they’ve ever seen their opponent’s opening brief, as this practice confers numerous benefits related to argument structure, time pressures and workflow, says Joshua Sohn at the U.S. Department of Justice.
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Attys Beware: Generative AI Can Also Hallucinate Metadata
In addition to the well-known problem of AI-generated hallucinations in legal documents, AI tools can also hallucinate metadata — threatening the integrity of discovery, the reliability of evidence and the ability to definitively identify the provenance of electronic documents, say attorneys at Law & Forensics.
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When Atty Ethics Violations Give Rise To Causes Of Action
Though the Model Rules of Professional Conduct make clear that a violation of the rules does not automatically create a cause of action, attorneys should beware of a few scenarios in which they could face lawsuits for ethical lapses, says Brian Faughnan at Faughnan Law.