Federal
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January 23, 2026
Taxation With Representation: Vinge, A&O Shearman, Cassels
In this week's Taxation With Representation, Swedish private equity company EQT buys U.K. secondaries firm Coller Capital, biopharmaceutical giant GSK PLC acquires Rapt Therapeutics Inc., and fusion energy company General Fusion announces plans to go public by merging with special purpose acquisition company Spring Valley Acquisition Corp. III.
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January 23, 2026
Senate To Take Up Spending Bills With $11.2B IRS Funding
The U.S. Senate is poised to take up bills next week that would provide the IRS with an $11.2 billion budget — a 9% annual cut — and cut $11.7 billion from the IRS spending boost included in the Inflation Reduction Act.
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January 23, 2026
IRS Says Overtime Tax Break Is Pegged To FLSA
Eligibility for a new tax deduction for overtime compensation is based on definitions provided in the Fair Labor Standards Act, the IRS said Friday, spelling out who can claim the tax break and what pay qualifies.
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January 23, 2026
Tax Pros Warn Of Turbulent 2026 Filing Season Ahead
The 2026 tax filing season likely will be characterized by filing delays, processing backlogs and widespread confusion, tax experts and former IRS commissioners warn, despite promises from federal officials to smoothly deliver billions in new tax benefits with better service, updated forms and modernized systems.
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January 23, 2026
Japan Adopts Global Min. Tax Tweak Exempting US Cos.
Japan approved changes to its minimum corporate tax regime to exempt U.S. companies from key aspects of the international rules following the renegotiation of Pillar Two, the Japanese government said Friday.
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January 22, 2026
Goldstein Prosecutors Unveil Conflicting Cash Source Claims
A former lawyer at SCOTUSblog founder Thomas Goldstein's firm said Thursday that Goldstein told coworkers that the more than $960,000 in cash he brought off a flight from Hong Kong — the source of which is integral to the government's case — had come from a client.
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January 22, 2026
Facts of IRS, Couple's Agreement Differ, Tax Court Says
A dispute over the details of an agreement between the Internal Revenue Service and a couple in a collection due process case bar the U.S. Tax Court from granting summary judgment to either party, the Tax Court said Thursday.
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January 22, 2026
Man Can't Blame Tax Preparer For Failure To File, IRS Says
A man found to have received income by using his company's cash as his own can't escape penalties by blaming his tax preparer for his failure to file, the government told the U.S. Tax Court.
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January 22, 2026
Judge Severs Tax Charges From Ex-Rep's Foreign Agent Case
A former Florida congressman will get to contest tax charges against him separately from a criminal indictment alleging he and a political consultant failed to register as foreign agents while lobbying on behalf of Venezuela's state oil company, a federal judge ruled.
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January 22, 2026
Tax Court Grants Spousal Relief To Doc In Abuse-Tainted Case
The U.S. Tax Court granted full innocent spouse relief to a Massachusetts physician facing a six-figure tax bill after her husband made withdrawals from her retirement account, saying Thursday it would be inequitable for her to be liable after suffering years of abuse.
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January 21, 2026
Hospital Ineligible For $11.5M COVID Tax Credit, Gov't Says
A hospital forced to suspend its normal business as it responded to the COVID-19 pandemic isn't entitled to an $11.5 million tax refund for employee retention credits and its lawsuit should be thrown out, the U.S. government told a Washington federal court.
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January 21, 2026
3rd Circ. Questions Mushroom Farmer's Tax Bill Accounting
A Third Circuit panel appeared skeptical Wednesday of a woman's bid to reduce her prison term for tax violations connected to her family's mushroom farm, with judges suggesting that different swaths of taxes she failed to pay the government could be grouped together as "relevant conduct" under federal sentencing guidelines.
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January 21, 2026
$30M In Tax Fraud Penalties Required Juries, High Court Told
A think tank and a legal center threw their support Wednesday behind a group of taxpayers asking the U.S. Supreme Court to find that the IRS violated their rights to a jury trial when it slapped them with more than $30 million in penalties for tax fraud.
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January 21, 2026
IRS Urged To Give IP Relief For Energy Manufacturing Credit
Intellectual property licensing deals shouldn't trigger foreign-entity restrictions barring access to the advanced manufacturing tax credit for clean-energy parts when the components at issue are merely byproducts of the licensed production process, Miller & Chevalier attorneys told the U.S. Treasury Department and the IRS.
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January 21, 2026
Energy Co. Wants Tariffs Excluded From Tax Credit
A Wisconsin energy company asked the U.S. Treasury Department to exclude tariffs from a new calculation of eligibility for clean energy tax credits, saying shifting federal policy on the levies could threaten the incentive to make major investments domestically.
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January 20, 2026
Goldstein Poker Pals Got Money From Firm, Witness Says
A former office manager at Thomas Goldstein's law firm Tuesday told the jury in his tax fraud trial in Maryland federal court that hundreds of thousands of dollars in wire transfers sent to the U.S. Supreme Court lawyer's poker counterparts were classified as business transactions in documents used by the firm's tax accountants.
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January 20, 2026
Law360 Names Firms Of The Year
Eight law firms have earned spots as Law360's Firms of the Year, with 48 Practice Group of the Year awards among them, achieving milestones such as high-profile litigation wins at the U.S. Supreme Court and 11-figure merger deals.
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January 20, 2026
Treasury Officials Warn Of Hurdles In 'Trump Account' Rollout
The U.S. Department of the Treasury is racing to open a new retirement savings program for children known as Trump Accounts by early July, and officials are warning that the effort will require a massive undertaking to deliver seed payments and build nationwide systems to track eligibility and contributions.
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January 20, 2026
IRS Can't Probe Partner-Tier Employment Taxes, 1st Circ. Told
The IRS is not authorized to scrutinize a partner's taxable net earnings at the business-entity level under a 1982 law governing partnership audits, an energy investment firm told the First Circuit, challenging the agency's bid to subject limited partners to the self-employment tax.
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January 20, 2026
Tax Court Wrongly Cut Conservation Gift Value, 4th Circ. Told
The U.S. Tax Court made multiple errors when it reduced the value of rock-rich land underlying a North Carolina partnership's conservation easement donation, the partnership told the Fourth Circuit, urging it to at least reverse penalties imposed by the court as a result of its findings.
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January 16, 2026
Law360 Names Practice Groups Of The Year
Law360 would like to congratulate the winners of its Practice Groups of the Year awards for 2025, which honor the attorney teams behind litigation wins and significant transaction work that resonated throughout the legal industry this past year.
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January 18, 2026
Trump Threatens 10% Tariff To Goad EU Nations On Greenland
President Donald Trump said he would impose a 10% tariff on several countries in the European Union beginning Feb. 1 as a way to build pressure toward his goal for the U.S. to purchase Greenland, according to a social media post.
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January 17, 2026
5th Circ. OKs Self-Employment Tax Break For Limited Partners
Business partners with limited liability under state law are excluded from the federal self-employment tax, a Fifth Circuit panel ruled, siding with a management consulting firm in its long-running controversy over the levy's limited-partner exception.
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January 16, 2026
DOJ Says Wife Owes FBAR Penalties On India Account
A New York federal court should find that a businessman's wife owes penalties for his failure to report his Indian bank account to the Internal Revenue Service after he deposited $1.5 million from the sale of a New York apartment complex, the U.S. Department of Justice argued Friday.
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January 16, 2026
Treasury's Rule Pace Unchanged After Loper Bright, Atty Says
The U.S. Supreme Court's 2024 landmark decision limiting federal agencies' deference in interpreting ambiguous statutes has not significantly altered the pace and volume of the U.S. Department of the Treasury's rulemaking workload, a Treasury attorney said Friday.
Digital Services Taxes May Give Leverage In US Trade Deals
As President Donald Trump and his administration continue to negotiate with trading partners seeking to lower tariff rates, countries with digital services taxes could find those measures build some leverage with U.S. negotiators aiming to eliminate them.
Trump Backs Off Tariffs Over Greenland With Deal In Works
President Donald Trump announced Wednesday he will back down from tariff threats on European countries in an effort to acquire Greenland after reaching an agreement on a framework for a deal involving U.S. security interests in the Arctic region.
IRS Funding Boost Faces $11.7B Cut In Bipartisan Package
Congress would cut $11.7 billion from the IRS spending boost included in the Inflation Reduction Act under a bipartisan, bicameral spending package released Tuesday by the House and Senate Appropriations committees.
Digital Services Taxes May Give Leverage In US Trade Deals
As President Donald Trump and his administration continue to negotiate with trading partners seeking to lower tariff rates, countries with digital services taxes could find those measures build some leverage with U.S. negotiators aiming to eliminate them.
Trump Backs Off Tariffs Over Greenland With Deal In Works
President Donald Trump announced Wednesday he will back down from tariff threats on European countries in an effort to acquire Greenland after reaching an agreement on a framework for a deal involving U.S. security interests in the Arctic region.
IRS Funding Boost Faces $11.7B Cut In Bipartisan Package
Congress would cut $11.7 billion from the IRS spending boost included in the Inflation Reduction Act under a bipartisan, bicameral spending package released Tuesday by the House and Senate Appropriations committees.
Featured Stories
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Tax Pros Warn Of Turbulent 2026 Filing Season Ahead
The 2026 tax filing season likely will be characterized by filing delays, processing backlogs and widespread confusion, tax experts and former IRS commissioners warn, despite promises from federal officials to smoothly deliver billions in new tax benefits with better service, updated forms and modernized systems.
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Digital Services Taxes May Give Leverage In US Trade Deals
As President Donald Trump and his administration continue to negotiate with trading partners seeking to lower tariff rates, countries with digital services taxes could find those measures build some leverage with U.S. negotiators aiming to eliminate them.
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US Pillar 2 Deal May Spur Other Nations To Seek Exemptions
International negotiators designed a 15% corporate minimum tax known as Pillar Two to apply worldwide, but a recently agreed-to carveout for the U.S. may prompt other countries with qualifying alternative regimes to seek similar exemptions that ultimately strain the global system.
Expert Analysis
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Key False Claims Act Trends From The Last Year
The False Claims Act remains a powerful enforcement tool after some record verdicts and settlements in 2025, and while traditional fraud areas remain a priority, new initiatives are raising questions about its expanding application, says Veronica Nannis at Joseph Greenwald.
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Hosting Exchange Students Makes Me A Better Lawyer
Opening my home to foreign exchange students makes me a better lawyer not just because prioritizing visiting high schoolers forces me to hone my organization and time management skills but also because sharing the study-abroad experience with newcomers and locals reconnects me to my community, says Alison Lippa at Nicolaides Fink.
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How A 1947 Tugboat Ruling May Shape Work Product In AI Era
Rapid advances in generative artificial intelligence test work-product principles first articulated in the U.S. Supreme Court’s nearly 80-year-old Hickman v. Taylor decision, as courts and ethics bodies confront whether disclosure of attorneys’ AI prompts and outputs would reveal their thought processes, say Larry Silver and Sasha Burton at Langsam Stevens.
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Navigating Privilege Law Patchwork In Dual-Purpose Comms
Three years after the U.S. Supreme Court declined to resolve a circuit split in In re: Grand Jury, federal courts remain split as to when attorney-client privilege applies to dual-purpose legal and business communications, and understanding the fragmented landscape is essential for managing risks, say attorneys at Covington.
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Cannabis Industry Faces An Inflection Point This Year
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Cannabis industry developments last year — from the passage of a new wholesale tax in Michigan, to an executive order accelerating the federal rescheduling process — presage a more mature phase of legalization this year, with hardening expectations and enforcement to come, says Alex Leonowicz at Howard & Howard.
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4 Ways GCs Can Manage Growing Service Of Process Volume
As automation and arbitration increase the volume of legal filings, in-house counsel must build scalable service of process systems that strengthen corporate governance and manage risk in real time, says Paul Mathews at Corporation Service Co.
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The Law Firm Merger Diaries: Forming Measurable Ties
Relationship-building should begin as early as possible in a law firm merger, as intentional pathways to bringing people together drive collaboration, positive client response, engagements and growth, says Amie Colby at Troutman.
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3 Key Takeaways From Planned Rescheduling Of Cannabis
An executive order reviving cannabis rescheduling represents a monumental change for the industry and, while the substance will remain illegal at the federal level, introduces several benefits, including improving state-legal cannabis operators' tax treatment, lowering the industry's legal risk profile, and leaving state-regulated markets largely intact, say attorneys at Dentons.
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OFAC Sanctions Will Intensify Amid Global Tensions In 2026
The Office of Foreign Assets Control will ramp up its targeting of companies in the private equity, venture capital, real estate and legal markets in 2026, in keeping with the aggressive foreign policy approach embraced by the Trump administration in 2025, say attorneys at Holland & Knight.
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5 E-Discovery Predictions For 2026 And Beyond
2026 will likely be shaped by issues ranging from artificial intelligence regulatory turbulence to potential evidence rule changes, and e-discovery professionals will need to understand how to effectively guide the responsible and defensible adoption of emerging tools, while also ensuring effective safeguards, say attorneys at Littler.
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Judges On AI: How Courts Can Boost Access To Justice
Arizona Court of Appeals Judge Samuel A. Thumma writes that generative artificial intelligence tools offer a profound opportunity to enhance access to justice and engender public confidence in courts’ use of technology, and judges can seize this opportunity in five key ways.
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Examining Privilege In Dual-Purpose Workplace Investigations
The Sixth Circuit's recent holding in FirstEnergy's bribery probe ruling that attorney-client privilege applied to a dual-purpose workplace investigation because its primary purpose was obtaining legal advice highlights the uncertainty companies face as federal circuit courts remain split on the appropriate test, say attorneys at Proskauer.
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Hot Topics For Family Offices In 2026
For family offices, the throughline of 2026 is disciplined readiness, as navigating impact from the One Big Beautiful Bill Act and platform maturation will be necessary to preserve flexibility and enhance client outcomes, say attorneys at Morgan Lewis.