Federal
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April 15, 2026
Cross-Border Services Taxes Are 'Quasi-Tariffs,' Report Says
The U.S. arguably has a stronger interest in challenging digital services taxes and other "quasi-tariffs" than in pursuing tariffs on physical goods, according a report Wednesday from the Tax Foundation, which contended that these overseas taxes disproportionately harm large services exporters.
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April 15, 2026
Judge Limits Evidence In Revived Deloitte Trade Secret Case
A West Virginia federal judge has narrowed the evidence prosecutors can present at trial in a revived trade secret case against two former Deloitte employees, curtailing use of an internal investigative report from the company they joined and restricting how "trade secrets" may be used to describe allegedly confidential materials.
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April 15, 2026
Eaton Says Tax Court Can't Disregard Transfer Of $14B Asset
The U.S. Tax Court can't disregard Eaton's transfer of a $14 billion asset overseas because the IRS itself didn't challenge the transaction's validity, the company argued Wednesday in defending the interest rates and guarantee fees paid to its Irish parent in 2012 and 2013.
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April 15, 2026
LLCs Fight $120M In Denied Tax Breaks For Conservation
Three Texas partnerships challenged over $120 million in denied tax deductions for donations of conservation easements across land they said could be used for solar photovoltaic power plants, telling the U.S. Tax Court that the IRS improperly claimed the donations didn't qualify for the tax break.
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April 14, 2026
Siemens Says It Met Conditions For $671M Deduction
Siemens Medical Solutions is entitled to a $670.6 million foreign-dividend tax deduction because it met the three prerequisites set forth in the statute governing the deduction, the company told the U.S. Tax Court.
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April 14, 2026
Partnerships Dispute IRS Denial Of $67M In Easement Breaks
Two partnerships challenged the IRS in the U.S. Tax Court over penalties and additional taxes tied to separate conservation easement deductions, alleging the agency had failed to explain why it denied their $33 million and $34 million tax breaks.
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April 14, 2026
Guam Extends Tax Filing, Payment Deadlines Due To Storm
Guam's governor extended tax-filing and payment deadlines in anticipation of the impacts of a typhoon, according to a representative of the governor's office and a joint information center release.
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April 14, 2026
Customs Casts Doubt On Automating Certain Tariff Refunds
U.S. Customs and Border Protection's automated tariff refund system is nearly complete, but thousands of imports may require a more cumbersome manual process that could undermine the agency's other priorities, an official told the U.S. Court of International Trade on Tuesday.
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April 14, 2026
IRS Wrongly Pulled Fuel Co.'s Tax License, Court Says
The Internal Revenue Service's revocation of a fuel distributor's designation for recovering taxes it paid on exempt sales to state and local governments was arbitrary and capricious, a Florida federal judge said in siding with the company in its $1.8 million tax refund case.
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April 14, 2026
2nd Circ. Urged To Rethink IRS Win In Foreign Reporting Case
A New York business owner asked the Second Circuit to rethink a panel's decision that held the IRS could automatically assess and administratively collect certain foreign information reporting penalties, arguing that the ruling deepens a nationwide conflict about the agency's assessment authority.
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April 13, 2026
4th Circ. Urged To Back $21M Cut To Conservation Deduction
The U.S. Tax Court considered a property's potential for mineral mining when it shaved more than $21 million from a North Carolina partnership's tax deduction for donating a conservation easement, the IRS told the Fourth Circuit on Monday, urging it to uphold the reduction.
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April 13, 2026
5th Circ. Finds Ban On Home Distilling Unconstitutional
A federal ban on home distilleries that dates to the early temperance movement violates the U.S. Constitution's limits on congressional taxing power, the Fifth Circuit said in siding with hobbyists, including one who said he wants to experiment with apple-pie vodka recipes in his garage.
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April 13, 2026
IRS Updates Corp. Bond Monthly Yield Curve For March
The IRS updated the corporate bond monthly yield curve used in calculations for defined benefit plans for March on Monday, as well as corresponding segment rates and the interest rate for 30-year U.S. Treasury Department securities.
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April 13, 2026
Weil Adds Kirkland, DLA Piper Attys To Private Funds Platform
Weil Gotshal & Manges LLP announced two additions to its private funds platform on Monday, one from Kirkland & Ellis and the other from DLA Piper.
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April 13, 2026
IRS Updates Rates For Foreign Insurance Co. Equations
The Internal Revenue Service on Monday published updated domestic asset/liability and yields percentages for 2025 that foreign life insurance companies and foreign property and liability insurance companies need to compute their minimum effectively connected net investment income.
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April 13, 2026
IRS Cancels Hearing On Tax Preparer ID User Fee
The IRS has canceled an April 24 hearing on proposed regulations that would lower the application and renewal fee for a tax return preparer identification number to $10 from $11 after receiving no requests to testify, the agency said Monday.
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April 10, 2026
Tax Deal Coverage Row Must Precede Tort Claims, Judge Says
A Georgia federal judge won't allow a conservation easement entity to litigate tort claims against its insurance broker while arbitrating a dispute with its insurer over coverage for an IRS settlement, ruling that those claims could only be sorted out after an initial coverage determination.
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April 10, 2026
Social Media Influencer Gets 6 Years For $20M Ponzi Scheme
A social media finance influencer who pled guilty to wire fraud and abetting a false tax filing tied to a $20 million real estate Ponzi scheme was sentenced Friday to six years in prison by an Ohio federal judge.
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April 10, 2026
Federal Tax Policies To Watch This Spring
As Congress returns to Washington, D.C., after a two-week Easter break, there are several areas where lawmakers might devote their attention, including legislation that would overhaul tax administration and tax proposals that could be included in budget reconciliation.
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April 10, 2026
Ohio Couple Dispute Disallowed S Corps.' Basis In Tax Court
An Ohio couple and their Minnesota corporation are disputing combined tax deficiencies of $3.9 million, most of it related to the Internal Revenue Service's determination that they lacked basis in S corporations, one of them a NASCAR Truck Series racing team.
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April 10, 2026
Dems Question Housing Director Over Tax-Exempt Payment
Two Senate Finance Committee Democrats questioned the Federal Housing and Finance Agency director Friday about a payment by a nonprofit he controlled to another tax-exempt nonprofit organization linked to President Donald Trump that was potentially misrepresented in IRS filings.
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April 10, 2026
First Phase Of Tariff Refund System To Launch April 20
The first phase of an electronic system allowing U.S. importers to claim refunds for tariffs paid under the global regime struck down by the U.S. Supreme Court will launch April 20, U.S. Customs and Border Protection said Friday.
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April 10, 2026
IRS Floats Excise Tax Regs On Overseas Money Transfers
Individuals who send funds to people abroad via a remittance transfer provider using cash, money orders, cashier's checks, traveler's checks and similar financial instruments would trigger a new 1% excise tax on the total amount remitted under proposed regulations the IRS unveiled Friday.
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April 10, 2026
IRS Releases List Of Jobs That Can Deduct Tips
The Internal Revenue Service released the final regulations Friday listing dozens of occupations that qualify for the no-tax-on-tips provision passed last summer, clarifying what counts as a tip and who can take the deduction, from Reiki teachers to app-based delivery drivers.
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April 10, 2026
Taxation With Representation: Goodwin, CMS, Wilson Sonsini
In this week's Taxation With Representation, Gilead Sciences Inc. acquires clinical-stage biotechnology company Tubulis GmbH, private equity firm Court Square Capital Partners closes a multibillion-dollar fund and Neurocrine Biosciences Inc. buys rare-disease drugmaker Soleno Therapeutics Inc.
Expert Analysis
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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.
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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.