Federal
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March 31, 2026
$50M Estate Tax Suit Is Late, Plastics Heir Tells Court
A Connecticut federal court should reject the U.S. government's request for a ruling that its $50 million estate tax suit against the heirs of a plastics company owner is timely, one of the heirs argued, saying a decades-old proof of claim didn't pause the clock on collection.
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March 31, 2026
Tariff Refunds On Liquidated Goods To Come, Customs Says
U.S. Customs and Border Protection will enable refunds for imports already liquidated that were subject to tariffs struck down by the U.S. Supreme Court, but that functionality still requires more time to develop, according to an official's declaration filed Tuesday in the U.S. Court of International Trade.
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March 31, 2026
IRS Can Collect $371M From Convicted Ex-Atty, 7th Circ. Says
The Internal Revenue Service can assess and collect restitution against a former attorney who served prison time in connection with $7 billion in tax fraud, making the amount immediately due and payable, the Seventh Circuit ruled, saying it was the first circuit court to address the issue.
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March 31, 2026
US Biz Group Asks EU To Limit Tax Abuse Rules' Application
The European Union's anti-tax abuse provisions should be limited to situations where avoidance is a genuine risk, and the 15% global minimum tax should take precedence over the tax avoidance directive when inconsistencies arise, a U.S. business lobbying group told the bloc.
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March 30, 2026
FinCEN Cautions On Benefits Fraud, Floats Tipster Award Plan
The U.S. Department of the Treasury's illicit finance watchdog called Monday for banks to step up monitoring for Medicare and Medicaid fraud, issuing new guidance on flagging suspicious activity, which came as officials also moved to incentivize financial crime reporting with new draft rules to offer tipster rewards.
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March 30, 2026
Eye Doctor Appeals Microcaptive Tax Payments At 5th Circ.
An eye doctor and his wife asked the Fifth Circuit to overturn a U.S. Tax Court decision from last year that affirmed Internal Revenue Service penalties and payments associated with their ophthalmology practice's microcaptive insurance arrangements.
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March 30, 2026
Mother And Son Tax Preparers Accused Of Fraud
A Texas mother and son were indicted for filing fraudulent tax returns through their tax preparation businesses, according to the U.S. Department of Justice, which said the pair tried to get unwarranted refunds by fabricating deductions.
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March 30, 2026
Morgan Lewis Brings On More Tax Pros From Baker McKenzie
Morgan Lewis & Bockius LLP announced Monday it has welcomed a four-member Baker McKenzie team with experience in tax and transfer pricing to the firm's New York office.
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March 30, 2026
Partnerships Fight $150M In Nixed Conservation Deductions
Three partnerships challenged the Internal Revenue Service's rejection of $150 million in tax deductions for their donations of conservation easements, telling the U.S. Tax Court that the determinations should be stricken for being arbitrary and capricious.
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March 30, 2026
Savings From Canceled IRS Contracts Limited, Report Says
The cost savings from hundreds of canceled IRS contracts has been limited or is unknown, in some cases because the money had already been spent, according to a report Monday by the Treasury Inspector General for Tax Administration.
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March 27, 2026
Lawyer Says Contract With Rivera Was For Venezuela's Oil Co.
The $50 million consulting contract that former Florida Congressman David Rivera signed with the U.S. affiliate of Venezuela's state-owned oil company was ultimately funded and controlled by the Venezuelan parent company, the attorney who drafted the document said Friday at Rivera's trial on charges of failing to register as a foreign agent.
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March 27, 2026
Atty Asks To Stay Out On Bond Amid $22M Tax Fraud Appeal
A Missouri lawyer convicted of helping perpetrate a $22 million tax scheme is asking to stay out of prison while she appeals, telling a North Carolina federal court that she believes her appeal could be successful on grounds that her indictment was obtained unconstitutionally.
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March 27, 2026
NYC Sheds FDIC's Claim For Silicon Valley Bank Tax Refund
A D.C. federal court said Friday it does not have the authority to order New York City to issue a tax refund sought by the Federal Deposit Insurance Corp. in its capacity as receiver of the failed Silicon Valley Bank.
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March 27, 2026
US Takes $89M Perrigo Economic Substance Fight To 6th Circ.
The U.S. government is appealing a Michigan federal court's conclusion that Perrigo overpaid $89.2 million in taxes, which was based on a finding that the company's transactions with a foreign affiliate had economic substance rather than sole tax avoidance purposes.
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March 27, 2026
Ex-CEO Sues Former NJ AG Over Tossed RICO Case
The former CEO of The Michaels Organization, who was indicted in New Jersey's now-dismissed criminal racketeering case against South Jersey power broker George E. Norcross III, has accused former New Jersey Attorney General Matthew J. Platkin and other members of his office of commencing the prosecution knowing there was no probable cause.
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March 27, 2026
Family Members Get Prison Terms For Tax Refund Scheme
Family members convicted of designing a trust scheme that tried to net $8.5 million in tax refunds were sentenced to prison by a Texas federal judge and ordered to pay back $1.7 million they spent on cryptocurrency and luxuries, according to the U.S. Department of Justice.
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March 27, 2026
IRS Has Spent $16B Of Funding Boost, TIGTA Says
The IRS had spent nearly $16 billion — or 61% — of its Inflation Reduction Act funding boost as of the end of last fiscal year, the Treasury Inspector General for Tax Administration said Friday.
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March 27, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly revenue bulletin, released Friday, included guidance on tax-exempt refunding bonds that would clarify how to request refunds for rebate overpayments.
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March 26, 2026
Venezuelan Leader Says Ex-Fla. Rep Couldn't Get US Meetings
A Venezuelan political opposition leader told jurors Thursday that he connected with former Florida congressman David Rivera to try to secure meetings with high-level U.S. officials in the first Trump administration, but Rivera — who is on trial for allegedly failing to register as a foreign agent — failed to deliver.
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March 26, 2026
Tax Court Upholds Penalty For Microcaptive Arrangement
An Oklahoma oil businessman is on the hook for an accuracy-related penalty for a microcaptive insurance arrangement that lacked economic substance, the U.S. Tax Court said Thursday, deciding an issue that it had deferred in an earlier ruling.
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March 26, 2026
Tax On Wealth Above $50M Proposed By Senate, House Dems
Net worth above $50 million would be subject to a wealth tax of up to 3% that could generate an estimated $6.2 trillion under a pair of bills introduced in the House and Senate on Thursday.
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March 26, 2026
4 Key Questions On Tariff Investigations
The U.S. announced a bevy of new trade investigations this month to underpin a tariff regime intended to replace duties struck down by the U.S. Supreme Court, but questions remain about the fate of deals struck with trading partners and whether importers will face higher tariffs. Here, Law360 examines four questions on the implications of those investigations.
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March 26, 2026
10th Circ. Should Allow Tax Petition Flexibility, Group Says
The Tenth Circuit should follow previous opinions finding that the 90-day deadline for challenging a tax bill is flexible, a taxpayer advocacy group told the circuit court Thursday, throwing its support behind a senior citizen who missed his petition filing deadline by one day.
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March 26, 2026
Fla. Partnership's Gift Of Ala. Land Worth $22M, Court Told
A Florida partnership defended its charitable deduction for a donation of land in Alabama that it said was worth in excess of $22 million, arguing the IRS erred in zeroing out the donation and assessing a deficiency of $8.3 million plus $3.3 million in penalties for 2021.
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March 26, 2026
Tax Court Slashes Deduction For Miss. Land Conservation
A partnership is only entitled to a $2.2 million tax deduction for donating a conservation easement over land in Mississippi, the U.S. Tax Court said Thursday, rejecting its claims that the value was more than 200% higher because the property could have been used for sand and gravel mining.
APAs Continue To Drop From 2023 Record, IRS Says
The Internal Revenue Service finalized fewer advance pricing agreements for U.S. multinational corporations in 2025 following peak levels seen in previous years, according to a report from the agency.
Deloitte Must Face Suit Over Philanthropists' Tax Bill
Deloitte lost its bid to avoid a June trial in a dispute over the accounting firm's handling of a $77 million share repurchase and planned charitable transfer that allegedly led to an unexpected tax bill for Boston-area developers and philanthropists William and Joyce Cummings.
$70M Easement Tax Break Sticks After IRS Concedes Lateness
A partnership is entitled to all of its claimed $70 million tax deduction for donating a conservation easement in Louisiana, as the IRS stipulated to missing a notification deadline for disallowing the tax break, according to a decision entered Friday in the U.S. Tax Court.
APAs Continue To Drop From 2023 Record, IRS Says
The Internal Revenue Service finalized fewer advance pricing agreements for U.S. multinational corporations in 2025 following peak levels seen in previous years, according to a report from the agency.
Deloitte Must Face Suit Over Philanthropists' Tax Bill
Deloitte lost its bid to avoid a June trial in a dispute over the accounting firm's handling of a $77 million share repurchase and planned charitable transfer that allegedly led to an unexpected tax bill for Boston-area developers and philanthropists William and Joyce Cummings.
$70M Easement Tax Break Sticks After IRS Concedes Lateness
A partnership is entitled to all of its claimed $70 million tax deduction for donating a conservation easement in Louisiana, as the IRS stipulated to missing a notification deadline for disallowing the tax break, according to a decision entered Friday in the U.S. Tax Court.
Featured Stories
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4 Key Questions On Tariff Investigations
The U.S. announced a bevy of new trade investigations this month to underpin a tariff regime intended to replace duties struck down by the U.S. Supreme Court, but questions remain about the fate of deals struck with trading partners and whether importers will face higher tariffs. Here, Law360 examines four questions on the implications of those investigations.
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Tax-Credit Cliff Sparks M&A Rush For Clean Energy
The looming July cutoff to maintain eligibility for clean electricity investment and production tax credits is sparking a dealmaking spree as smaller developers who are unable to meet the deadline begin looking to sell projects to deeper-pocketed players who can.
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4 Open Questions On Tariff Refund System Development
U.S. Customs and Border Protection is developing a system to refund tariffs struck down by the U.S. Supreme Court, but it remains unclear whether it will cover the entire gamut of duties President Donald Trump imposed under the International Emergency Economic Powers Act. Here, Law360 examines four open questions surrounding the IEEPA tariff refund system being developed by Customs.
Expert Analysis
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Getting The Most Out Of Learning And Development Programs
Excerpt from Practical Guidance
Junior associates can better develop the legal, business and interpersonal skills they need for long-term success by approaching their firms’ learning and development programs armed with five tips for getting the most out of these resources, says Lauren Hakala at Reed Smith.
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AI Presents A Make-Or-Break Moment For Outside Counsel
The rapid adoption of artificial intelligence by corporate legal departments is forcing a long-overdue reset of the relationship between inside and outside counsel, and introducing a significant opportunity to shed frustrating inefficiencies and strengthen collaboration for firms willing to embrace the shift, says Intel Chief Legal Officer April Miller Boise.
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8 Tariff Refund Questions For Restructuring Professionals
For restructuring and turnaround professionals, seeking refunds following the U.S. Supreme Court's recent decision invalidating tariffs imposed under the International Emergency Economic Powers Act raises several questions about how to capture legitimate recoveries while protecting an enterprise from the consequences of its own history, says Jonny Frank and Laura Greenman at StoneTurn, and Andrew Popescu at Province.
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5 Tips For Navigating Your Firm's All-Attorney Summit
Excerpt from Practical Guidance
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Law firm retreats should be approached strategically, as they present valuable opportunities to advance both the firm's objectives and attorneys' professional development through meaningful participation, building and strengthening internal relationships, and proactive follow-up, says James Argionis at Cozen O’Connor.
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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
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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.