Federal

  • June 08, 2026

    Developers Stumped By Energy Credits' Foreign Debt Limits

    Developers seeking to finalize projects financed with clean energy tax credits and several loans are hitting a roadblock in demonstrating to the IRS that their debt has limited ties to prohibited foreign entities, a requirement for qualifying for the incentives.

  • June 08, 2026

    McKesson Can't Defeat Valid Cost-Sharing Rules, Gov't Says

    The U.S. government urged a Texas federal court to uphold transfer pricing regulations that pharmaceutical giant McKesson is challenging in its push for a nearly $10 million tax refund, arguing the rules fall "well within the bounds" of the underlying statutory text.

  • June 08, 2026

    IRS Identity Theft Partnership Designates New Work Groups

    A public-private partnership between the Internal Revenue Service and the tax community to help crack down on tax-related identity theft is restructuring and creating new work groups to improve information sharing across the U.S. tax system to help crack down on such theft, the agency announced Monday.

  • June 05, 2026

    Calif.'s Global Reporting Bill Could Embolden Other States

    A California bill that would require multinational corporations to report their global profits could spark similar legislation across the U.S. if lawmakers of revenue-hungry states perceive shortcomings in federal and international efforts to tackle profit shifting.

  • June 05, 2026

    11th Circ. Lets Man Fight $2.2M FBAR Penalties As Excessive

    A Georgia federal court correctly found that the owner of a sports equipment business willfully failed to disclose his foreign bank accounts, but it must give him a chance to challenge $2.2 million in resulting penalties as excessive under the Eighth Amendment, the Eleventh Circuit said.

  • June 05, 2026

    IRS To Release Guidance On Tax-Exempt Org. Pay Excise Tax

    The IRS is planning to issue proposed guidance on the expanded 21% excise tax on excess compensation at tax-exempt organizations, including updated definitions that align with changes passed under Republicans' 2025 tax overhaul, according to a notice released Friday.

  • June 05, 2026

    Abbott Says Timing Mismatch Lets $8B Gain Go Untaxed

    Abbott Laboratories asked the U.S. Tax Court to find that it needn't recognize an $8 billion gain in 2020 from transactions between several of its controlled foreign corporations because of a mismatch in the effective dates of different sections of the 2017 U.S. Tax Cuts and Jobs Act.

  • June 05, 2026

    Judge Asks How FCC Ruling Affects $6.6M IRS Penalty Fight

    A Pennsylvania federal judge ordered briefing on how the U.S. Supreme Court's new decision upholding agency fines without a jury trial affects a $6.6 million tax penalty dispute, signaling potential reconsideration of last year's opinion in the case.

  • June 05, 2026

    Taxation With Representation: Simpson Thacher, Fried Frank

    In this week's Taxation With Representation, Berkshire Hathaway Inc. takes Taylor Morrison Home Corp. private, global real estate investment company Kennedy Wilson forms a residential joint venture with Netherlands pension services provider APG, and Wellington Management acquires Hartford Funds from insurer The Hartford.

  • June 05, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, included an extension for sponsors of certain defined contribution retirement plans to amend the plans to allow qualified long-term care distributions.

  • June 04, 2026

    Jury Hears Closings In Trial Over Alleged Tax Shelter Scheme

    Prosecutors told a Colorado federal jury Thursday that four individuals defrauded the government by using their businesses to help promote and sell abusive and illegal trust tax shelters, while the defendants argued they lacked knowledge of the alleged scheme and can't be held responsible.

  • June 04, 2026

    Bessent Mum On Details Of Trump-IRS Settlement

    Treasury Secretary Scott Bessent gave House Democrats few answers Thursday to their questions on the scope and limitations of President Donald Trump's settlement with the IRS over the leak of his tax data that includes an exemption from tax audits for Trump and members of his family.

  • June 04, 2026

    Tax Court Confirms IRS Computations In Easement Case

    A partnership, in objecting to IRS computations, improperly raised new arguments in a case where the U.S. Tax Court reduced a conservation easement deduction by over $10 million, the tax court said in upholding the agency's calculations, which included a 40% penalty.

  • June 04, 2026

    Feds Appeal Trade Court's Emergency Tariff Refund Order

    The federal government has appealed the U.S. Court of International Trade's order requiring refunds on all duties paid under the International Emergency Economic Powers Act after the U.S. Supreme Court struck them down this year, according to filings in the trade court and Federal Circuit.

  • June 04, 2026

    IRS To Hold Hearing On Trump Accounts In July

    The Internal Revenue Service will hold a public hearing July 16 on proposed rules related to the new tax-advantaged brokerage accounts for newborns called Trump accounts, the agency said Thursday.

  • June 04, 2026

    Ex-Surgeon Agrees To $7.7M Tax Bill From Offshore Scheme

    A retired plastic surgeon reached a $7.7 million settlement with the federal government to resolve an Internal Revenue Service case alleging that he ran an offshore employee leasing scheme, according to an agreement filed in an Ohio federal court.

  • June 04, 2026

    Californian's Crypto Staking Rewards Taxable, Tax Court Says

    A California man's cryptocurrency staking rewards, in the form of additional tokens for supporting a blockchain platform, are taxable income, a U.S. Tax Court judge ruled Thursday, saying he could have converted the tokens into cash at any time.

  • June 04, 2026

    Goldstein Seeks Sentencing Delay, Citing New Tax Claims

    SCOTUSblog founder Thomas Goldstein renewed his push Wednesday in Maryland federal court for a delayed sentencing, saying prosecutors blindsided his defense by including additional uncharged years of alleged tax avoidance in the government's sentencing memorandum.

  • June 04, 2026

    Blanche's AG Bid Could Face Rocky Path In Senate

    Acting Attorney General Todd Blanche will be tapped for the permanent role, but he might not have a smooth path to confirmation.

  • June 04, 2026

    Tax Court Didn't Err In Voiding $713M Deduction, IRS Says

    A real estate development partnership failed to show that the U.S. Tax Court made errors that undermined its ruling eliminating a $713 million deduction to the partnership for 2012, the IRS argued, saying the court shouldn't gratuitously decide issues that don't affect a case's disposition.

  • June 03, 2026

    Dems Press Bessent On 'Weaponization' Fund, Trump Audits

    Senate Democrats questioned Treasury Secretary Scott Bessent on Wednesday about details of a settlement that included a since-dropped plan for a $1.8 billion fund that could have been used to pay off Jan. 6 defendants and an exemption from IRS audits for President Donald Trump and members of his family.

  • June 03, 2026

    Texas Instruments Defends Deductions For Exercised Options

    Texas Instruments challenged total deficiencies of $47.9 million for 2018 and 2019, much of it from the IRS' disallowance of deductions for deferred compensation, such as exercised stock options, under an approach consistent with a 2022 agency advice memorandum.

  • June 03, 2026

    Purdue Pharma Heir Sues Son Over Sackler Matriarch's Estate

    Former Purdue Pharma LP President Richard Sackler has appealed a Connecticut probate court decision favoring his son David Sackler in a dispute over his mother Beverly Sackler's estate, saying a judge ignored self-dealing rules when approving his son's request to assign trust interests to a public charity.

  • June 03, 2026

    Goldstein Cites Addiction To Avoid Time, DOJ Seeks 8 Years

    Federal prosecutors recommended a 97-month prison sentence for convicted SCOTUSblog founder Thomas Goldstein, telling a Maryland federal court he has bilked the government out of more than $9.5 million in unpaid taxes. Goldstein, meanwhile, asked for a suspended sentence and supervised release, citing a "severe and longstanding gambling addiction."

  • June 03, 2026

    Graham Pushes Federal Tort Path After DOJ Drops $1.8B Fund

    The U.S. Department of Justice seemed, at least briefly, to support a Republican senator's alternative solution to the "anti-weaponization" $1.8 billion fund that acting Attorney General Todd Blanche said Tuesday the department is abandoning.

Expert Analysis

  • Mich. Banking Brief: All The Notable Legal Updates In Q1

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    Michigan's financial services sector saw several significant developments in 2026's first quarter, including the state Department of Insurance and Financial Services' issuance of a bulletin on the use of artificial intelligence and the Michigan House's introduction of a bill based on the Model Money Transmission Modernization Act, say attorneys at Dykema.

  • Navigating The Perks Of Qualified Opportunity Zones 2.0

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    The second iteration of the qualified opportunity zone program, effective Jan. 1, 2027, will introduce new tax incentives for rural real estate development, but these benefits can only be realized if proper governance is a priority, including clear documentation and securities law compliance, says Coni Rathbone at VF Law.

  • Getting The Most Out Of Learning And Development Programs

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    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.

  • AI Presents A Make-Or-Break Moment For Outside Counsel

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    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.

  • 8 Tariff Refund Questions For Restructuring Professionals

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    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.

  • 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.

  • How Bankrupt Cos. Can Seek Refunds For Illegal Tariffs

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    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.

  • Legal And Industry Impacts Of America's Maritime Action Plan

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    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.

  • 4 Ways To Help CBP Curb Shell Co. Import Schemes

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    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.

  • 7 Steps For Gov't Contractors In Post-IEEPA Tariff Landscape

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    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.

  • The Benefits Of Choosing A Niche Practice In The AI Age

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    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.

  • Section 122 Tariffs Show Shift In Strategy, Not Trade Policy

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    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.

  • Tax Court Ruling Signals Cross-Border Loan Scrutiny

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    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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