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Federal
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April 24, 2026
Grocers' Microcaptive Tax Breaks Wrongly Axed, 7th Circ. Told
Chicagoland grocery chain owners asked the Seventh Circuit to restore the tax benefits tied to their business' microcaptive insurance, arguing that the U.S. Tax Court's decision to disallow those deductions violated a 1945 federal law authorizing state regulation of insurers.
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April 24, 2026
Taxation With Representation: Gibson Dunn, Paul Weiss
In this week's Taxation With Representation, Elon Musk's SpaceX strikes a deal with Cursor that could lead to an acquisition of the artificial intelligence startup, building products distributor QXO Inc. buys TopBuild Corp., and Eli Lilly & Co. acquires clinical-stage biotechnology company Kelonia Therapeutics.
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April 24, 2026
Trump Makes Fresh US Tariff Threat Over UK Digital Tax
President Donald Trump warned that his administration will impose new tariffs on the U.K. unless the British government dismantles its digital services tax targeting tech giants.
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April 24, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included the list of the dozens of occupations that qualify for the no-tax-on-tips provision passed in summer 2025, clarifying what counts as a tip and who can take the deduction.
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April 24, 2026
Barnes & Thornburg Lands 6 Bradley Arant Attys In Southeast
Barnes & Thornburg LLP announced Thursday that the firm has hired six attorneys from Bradley Arant Boult Cummings LLP for its Atlanta and Palm Beach Gardens, Florida, offices, increasing its capabilities in the tax and insurance recovery practice groups.
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April 23, 2026
BofA, EY Strike $2.5M Deal To Settle MOVEit Breach Claims
Bank of America and EY have agreed to pay $2.5 million to nearly 200,000 people to settle claims in multidistrict litigation over the May 2023 breach of file transfer application MOVEit, according to a motion for settlement.
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April 23, 2026
Pair Accused Of Scheming To Dodge $2.5M IRS Tax Debt
A Connecticut grand jury has charged an in-state businessman allegedly $2.5 million in debt to the Internal Revenue Service and a North Carolina man with engineering a series of financial transactions to keep tax authorities from collecting the debt, according to federal prosecutors.
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April 23, 2026
IRS' $15M Valuation Of Estate An Issue For Trial
The IRS' failure to provide a statement explaining its $15.1 million valuation of an estate doesn't require that the valuation and resulting deficiency assessment should be thrown out, the U.S. Tax Court held Thursday, saying the issue is one for trial.
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April 23, 2026
IRS Plans To Update Tax-Exempt Org Reporting Form
The Internal Revenue Service will revise its form for tax-exempt organizations to report information under an initiative announced by the U.S. Department of the Treasury on Thursday.
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April 23, 2026
Lender's COVID Boom Bars $5M Worker Credit Claim, US Says
A mortgage lender isn't entitled to a $5 million refund for denied COVID-19 worker tax credits because the company's true business was never halted by a government order, the U.S. government told a California federal court, noting that the company's revenue actually increased by 600%.
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April 23, 2026
AI Missteps Could Prompt Tax Court To Adopt Misuse Rules
As the U.S. Tax Court continues to encounter false information generated by artificial intelligence, practitioners are urging the court to set some guidance to curb misuse of the technology and reduce the burden on judicial reviewers to catch those errors.
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April 23, 2026
IRS Defends Ranch's Easement Deduction Disallowance
The Internal Revenue Service properly disallowed a partnership's nearly $26 million charitable deduction for a donated easement on a 110-acre pasture, the agency told the Eleventh Circuit, urging it to affirm the lower court's decision.
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April 23, 2026
Plastics Heirs Settle $50M Estate Tax Suit
The family of the late owner of a plastics company settled a dispute with the U.S. Department of Justice over more than $50 million in estate taxes the agency alleged went unpaid, a Connecticut federal court announced Thursday.
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April 23, 2026
DOJ Final Order Loosens Rules For State-Legal Medical Pot
The U.S. Department of Justice published a final order Thursday loosening federal restrictions on medical marijuana products that fall within the ambit of state-regulated programs or have approval from the U.S. Food and Drug Administration.
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April 22, 2026
House Appropriations Committee OKs $1B IRS Funding Cut
The House Appropriations Committee passed legislation Wednesday that would cut the Internal Revenue Service's funding by $1 billion for the 2027 fiscal year.
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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.
Expert Analysis
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After Learning Resources: A Practical Guide For US Importers
Following the U.S. Supreme Court's Feb. 20 decision in Learning Resources v. Trump, U.S. importers and consumers on whom tariffs were imposed under the International Emergency Economic Powers Act can seek relief through existing administrative procedures or a yet-to-be-determined bespoke refund mechanism, and should plan for more changes in the tariff landscape, say attorneys at Baker Botts.
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AI-Assisted Arbitration Needs Safeguards To Ensure Fairness
As tribunals and arbitral institutions increasingly use artificial intelligence tools in their decision-making processes, clear disclosure standards and procedural safeguards are necessary to ensure that efficiency gains do not erode the fairness principles on which arbitration depends, says Alexander Lima at Wesco International.
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AI-Generated Doc Ruling Guides Attys On Privilege Risks
A New York federal court's ruling, in U.S. v. Heppner, that documents created by a defendant using an artificial intelligence tool were not privileged, can serve as a guide to attorneys for retaining attorney-client or work-product privilege over client documents created with AI, say attorneys at Sher Tremonte.
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The Law Firm Merger Diaries: Leadership Strategy After Day 1
For law firm leaders, ensuring a newly combined law firm lives up to its promise, both in its first days of operation and well after, includes tough decisions, clear and specific communication, and cheerleading, says Peter Michaud at Ballard Spahr.
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Calif.'s Civility Push Shows Why Professionalism Is Vital
The California Bar’s campaign against discourteous behavior by attorneys, including a newly required annual civility oath, reflects a growing concern among states that professionalism in law needs shoring up — and recognizes that maintaining composure even when stressed is key to both succeeding professionally and maintaining faith in the legal system, says Lucy Wang at Hinshaw.
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US-Ukraine Reconstruction Fund Tax Exemptions Uncertain
Tax provisions in the bilateral agreement to establish the U.S.-Ukraine Reconstruction Investment Fund, which recently announced it is accepting applications, are so broad and imprecise as to leave uncertainty regarding whether and when tax exemptions will apply to investors' income, say attorneys at Avellum and Debevoise.
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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.