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Federal
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May 05, 2026
Tax Shelter Trial Defendants Claim Promoter Misled Them
More than a dozen lawyers and defendants packed a Colorado federal courtroom Tuesday to mark the first day of testimony in the trial against four individuals accused of using their businesses to help promote and sell abusive trust tax shelters.
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May 05, 2026
IRS Modifies Significant Issue Ruling Program
The IRS outlined the process for taxpayers to request rulings on one or more issues that are solely under the agency's corporate associate chief counsel's jurisdiction that involve certain tax consequences and transactions, according to guidance released Tuesday.
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May 05, 2026
Tax Court Revives Ga. Collections Case Over Notice Flaws
The U.S. Tax Court remanded a Georgia man's collections due process dispute Tuesday, saying that while he "certainly did not facilitate the consideration of his case" with the IRS Office of Appeals, the office improperly failed to consider whether he timely received notices.
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May 05, 2026
Ending Carried Interest Tax Break May Net $88B, Report Says
Ending the carried interest tax break could raise far more than previously estimated, nearly $88 billion in a decade, based on a new methodology put forward in a report by the Yale Budget Lab.
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May 05, 2026
IRS Beats Suit Claiming Secret Rule Targeted Stock Plan
A transportation company cannot pursue its claims that the IRS adopted a secret rule that targeted its stock ownership plan, a Wisconsin federal judge ruled, throwing out the company's suit.
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May 05, 2026
Limited Partners Reject Self-Employment Tax In 1st Circ.
An energy investment company told the First Circuit that its self-employment tax dispute is distinct from that of the taxpayer in a 2009 Federal Circuit ruling that barred refunds to a partnership's individual partners, saying the cases involve different subsections of U.S. income tax law.
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May 05, 2026
Wis. Village Urges 7th Circ. To Void Oneida Tribal Trust Order
A Wisconsin village is asking the Seventh Circuit to undo a U.S. Department of the Interior decision to place 500 acres of properties into trust for the Oneida Nation, arguing that a district court ignored evidence of bias and shielded the transactional record from meaningful scrutiny.
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May 05, 2026
US Ends $15M Tax Refund Fight With Gas Biz Partners
The U.S. government agreed to end litigation alleging that several Texas residents had erroneously claimed a total of about $15 million in tax refunds tied to a partnership involving gas and oil operations in Equatorial Guinea.
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May 05, 2026
IRS To Implement Digital Signatures In Penalty Approvals
The Internal Revenue Service agreed to require supervisors to use digital signatures to approve tax penalties as a way to prevent improper backdating and other edits to the approval documents, the agency watchdog said in a report released Tuesday.
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May 04, 2026
Biz Hit With Extra Penalties For Captive Insurance Deductions
A Florida business must pay additional penalties for deductions taken for microcaptive insurance expenses, the U.S. Tax Court said Monday, backing the IRS' imposition of 40% penalties for tax years 2012 through 2015.
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May 04, 2026
Ex-IRS Agent Accused Of Stealing $12M From Fuel Co.
A former Internal Revenue Service agent was arrested for allegations that he embezzled more than $12 million in his role as a chief financial officer of a New Jersey fuel company, the New Jersey U.S. Attorney's Office said.
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May 04, 2026
Ga. Partnership Defends $46M Deduction For Land Donation
A Georgia partnership defended its claimed deduction of $46 million for 235 acres donated to a land conservation group, saying the IRS wrongly disallowed the amount and determined it underpaid its 2021 taxes by $17 million.
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May 04, 2026
Tax Court Slashes $30M Deductions For Georgia Easements
The U.S. Tax Court slashed two partnerships' charitable tax deductions worth a combined $30 million for a pair of conservation easement donations, ruling Monday that the easements' outsize valuation was an attempt to make "too many fast nickels."
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May 04, 2026
Managers Of Embattled Easement Say RICO Suit Lacks Details
Investment fund managers behind a conservation easement donation whose charitable tax deduction was embroiled in litigation asked a Georgia federal court to toss a racketeering suit against them by a pair of investors, arguing the fraud claims do not match the allegations.
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May 04, 2026
IRS Issues Employer Payment Index For Coverage Penalties
The IRS provided indexing adjustments Monday for calculating penalties against large employers that don't offer health insurance to their full-time workers or whose full-time workers opt to enroll in government-subsidized health coverage using premium tax credits.
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May 04, 2026
IRS Approves Co.'s Retroactive Transfer Pricing Changes
The IRS Office of Chief Counsel has endorsed a company's proposal to reduce certain transfer pricing adjustments through a setoff after retroactively changing how it allocated costs between related companies, according to a memorandum.
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May 04, 2026
Partnership Defends $3M Deduction For Yacht Purchase
A partnership said the IRS wrongly disallowed expenses associated with its boat chartering and fishing tournament activities, including the purchase of a $3 million yacht, during 2020 and 2021, when the COVID-19 pandemic severely disrupted its business.
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May 01, 2026
Biz Group Slams IRS' 'Implicit Support' Argument In Eaton
An international business group urged the U.S. Tax Court to reject IRS arguments that Eaton Corp. deserved a higher credit rating due to its foreign parent's "implicit support," saying the case could significantly affect its members' U.S. tax liabilities.
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May 01, 2026
Int'l Tax In April: Progress On Tariff Refunds, New Tax Cuts
U.S. Customs and Border Protection continued to make progress in April on its system for paying back the tariffs that President Donald Trump imposed under the International Emergency Economic Powers Act. Meanwhile, several countries and one U.S. state cut fuel taxes in response to the U.S. and Israel's war with Iran. Here, Law360 looks at those and other international tax developments from the past month.
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May 01, 2026
Tax Shelter Defendant Says Discovery Errors Allow Dismissal
A man charged with promoting abusive and illegal tax shelters for decades asked a Colorado federal judge just days before trial to throw out the indictment against him, contending the government withheld material exculpatory evidence for more than a year.
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May 01, 2026
Kostelanetz Adds Ex-IRS Criminal Investigation Chief In NY
Kostelanetz LLP has hired a former chief of the U.S. Internal Revenue Service's law enforcement branch who spent more than 30 years there investigating tax and financial crime, domestically and abroad, the firm announced Friday.
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May 01, 2026
Texas Plastics Co. Seeks To Nix Full Captive Rules In 5th Circ.
A plastics company is appealing a Texas district court's decision to partially vacate IRS regulations that listed captive insurance as potentially abusive tax avoidance schemes and will ask the Fifth Circuit to strike down the entire set of regulations, according to a notice.
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May 01, 2026
IRS Failed To Vet GILTI Regs For Small Biz, Court Told
The Internal Revenue Service failed to assess how final regulations implementing the 2017 tax law's global intangible low-taxed income regime would affect small businesses, an Israeli law firm told the D.C. federal court Friday, arguing the rules violate administrative law.
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May 01, 2026
IRS Says Tribal Fishing Income Counts Toward Retirement
Income earned by citizens of Native American tribes as payment for services related to fishing rights activities qualifies as compensation for purposes of limits on qualified retirement plan benefits and contributions, the Internal Revenue Service said Friday.
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May 01, 2026
Ex-Fla. Rep. Guilty Of FARA Violations For Venezuela Work
A Florida federal jury on Friday found former Florida congressman David Rivera guilty of failing to register as a foreign agent after signing a $50 million contract with a unit of Venezuela's state-owned oil company.
Expert Analysis
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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.
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4 Quick Emotional Resets For Lawyers With Conflict Fatigue
Though the emotional wear and tear of legal work can trap attorneys in conflict fatigue — leaving them unable to shake off tense interactions or return to a calm baseline — simple therapeutic techniques for resetting the nervous system can help break the cycle, says Chantel Cohen at CWC Coaching & Therapy.
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Rescheduling Cannabis Marks New Tax Era For Operators
As the attorney general takes steps to move cannabis from Schedule I to Schedule III of the Controlled Substances Act, operators and advisers should prepare by considering the significant changes this will bring from tax, state, industry and market perspectives, says Michael Harlow at CohnReznick.
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Judges On AI: How Judicial Use Informs Guardrails
U.S. Magistrate Judge Maritza Dominguez Braswell at the U.S. District Court for the District of Colorado discusses why having a sense of how generative AI tools behave, where they add value, where they introduce risk and how they are reshaping the practice of law is key for today's judges.
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Presidential Pardon Brokering Can Create Risks For Attys
The emergence of an apparent “pardon shopping” marketplace, in which attorneys treat presidential pardons as a market product, may invite investigative scrutiny of counsel and potential criminal charges grounded in bribery, wire fraud and other statutes, says David Klasing at The Tax Law Offices of David W. Klasing.
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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.