Federal
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October 22, 2026
Tax Court Scraps $75M Easement Deduction As 'Cartoonish'
The U.S. Tax Court refused to approve a partnership's $74.5 million charitable tax deduction for a Tennessee conservation easement Thursday, describing it as a "cartoonish" amount for a nearly $3 million property that sat on the market for years.
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October 22, 2026
IRS Creates New Retirement Plan Correction Program
The Internal Revenue Service issued two revenue procedures Thursday, including one creating a correction program for individual retirement accounts.
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October 22, 2026
IRS Offer In $57M Easement Case Not Binding, 11th Circ. Told
The U.S. Tax Court properly denied a partnership's request to enforce a settlement offer the IRS said it mistakenly made after rejecting the partnership's $57 million conservation easement deduction, the agency told the Eleventh Circuit, saying the parties hadn't entered into a binding agreement.
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October 22, 2026
Foreign Tax Credit Sourcing Rule Likely By Year's End
The IRS hopes to propose regulations on sourcing certain inventory sales income for the foreign tax credit limitation under Internal Revenue Code Section 904 — one of the items listed on its priority guidance plan for 2026-2027 — by the end of the year, an agency official said.
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October 22, 2026
Treasury Aiming to Float CAMT Rules by Feb., Official Says
The U.S. Treasury Department is still on track to propose revised regulations for the corporate alternative minimum tax by February, a department official said Thursday.
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October 21, 2026
IRS Sets Interim Relief For Dyed Fuel Excise Tax Reporting
The IRS will temporarily waive enforcement of the reporting and recordkeeping requirements for the retail excise tax on certain uses of dyed diesel as the agency examines a simple process to administer the compliance provisions, the agency announced Wednesday.
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October 21, 2026
IRS Says Eaton Misportrayed Intercompany Loan Example
Eaton misportrayed the IRS' argument about a regulatory example concerning the relevance of companies' relatedness when analyzing an arm's-length price of a transaction, the agency told the U.S. Tax Court, defending its denial of related-party interest and fee deductions.
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October 21, 2026
Wyden Questions Big 4 Execs On Int'l Tax Shelter Consulting
The Senate Finance Committee's top Democrat said Wednesday that he was launching an inquiry into whether the Big Four accounting firms — PwC, KPMG, Deloitte and EY — have helped large multinational corporations avoid billions in taxes by creating tax shelters in Malta.
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October 21, 2026
Beauty Co.'s $8M Refund Bid Axed For Misnomer On Returns
An Illinois federal judge dismissed a skin care corporate group's $8.3 million tax refund suit, finding she lacked jurisdiction to review its amended returns claiming business deductions because those filings did not use the company's new name after a 2018 merger.
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October 21, 2026
Squire Patton Lands Akerman's Public Finance Co-Leader
Squire Patton Boggs LLP announced Wednesday that it has added the co-chair of Akerman LLP's public finance group to bolster its capacity to handle public finance, healthcare finance and other matters.
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October 21, 2026
Mich. Staffing Biz Owner Cops To $1.7M Tax Fraud Scheme
A Michigan woman who owned a series of staffing companies pled guilty to conspiring to defraud the U.S. for more than a decade via an employment tax scheme, causing a tax loss to the IRS of roughly $1.7 million, federal prosecutors said.
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October 20, 2026
Biz Says 50% Canadian Tariff Is Yet Another Illegal Regime
President Donald Trump's retaliatory 50% tariffs against Canadian goods are the latest in a string of illegal trade actions and should be struck down, just like two previous regimes, according to a lawsuit filed Tuesday at the U.S. Court of International Trade.
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October 20, 2026
IRS Updates Corporate Bond Monthly Yield Curve For October
The IRS on Tuesday updated the corporate bond monthly yield curve used in calculations for defined benefit plans for October, as well as corresponding segment rates and the interest rate for 30-year U.S. Department of the Treasury securities.
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October 20, 2026
Plastics Co. Asks 5th Circ. Not To Nix Captive Insurance Case
The founder of a plastic manufacturing company asked the Fifth Circuit not to dismiss his bid to restore a tax deduction the IRS denied on premiums the company paid for its captive insurance arrangement, saying the court has jurisdiction over the case despite the government's claim to the contrary.
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October 20, 2026
Ala. Partnerships Defend $95M In Deductions For Land Gifts
Two Alabama partnerships were wrongly denied deductions totaling more than $95 million for over 370 acres they donated to the same conservation group in 2020, they told the U.S. Tax Court.
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October 20, 2026
Treasury Drops Proposed 'Per Se' Test For Tax-Free Spinoffs
The U.S. Treasury Department on Tuesday scrapped regulations proposed in 2016 that would have used a "per se" test and other bright-line rules to determine whether corporate spinoff transactions qualify for tax-free status.
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October 20, 2026
OECD Updates Min. Return Guidance For Tax Authorities
The OECD on Tuesday released updated guidance for tax authorities regarding the system to exchange taxpayer returns under the 15% global minimum tax, incorporating changes related to the deal to exempt U.S. companies from its international provisions and other technical adjustments.
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October 19, 2026
How The Midterms Are Likely To Shape Tax Policy
While the outcome of the midterm elections won't change tax policy overnight, the winning party should at the very least have the chance to signal its priorities and work on bipartisan legislation that could become law even in a divided government. Here, Law360 breaks down different tax policy scenarios that could come from the elections.
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October 19, 2026
BDO $1.3B ESOP Fight Dismissed On Standing Grounds
A Massachusetts federal judge on Monday dismissed a proposed class action against BDO USA alleging the accounting and tax advisory firm's $1.3 billion deal to create an employee stock ownership plan violated federal benefits law, holding the worker who sued couldn't show that the transaction injured him.
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October 19, 2026
Whistleblower Can't Challenge Award In Tenn. Court, IRS Says
A district court doesn't have jurisdiction over an anonymous whistleblower's challenge to the $10 million cap that applies to whistleblower awards, the IRS told the Sixth Circuit on Monday, arguing that any determination regarding an award must be appealed to the U.S. Tax Court.
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October 19, 2026
Tax Court Disallows Ohio Partnerships' Easement Deductions
Two Ohio partnerships improperly claimed tens of millions of dollars in charitable contribution deductions for donations of easements placed over the facades of historic buildings, the U.S. Tax Court said Monday, finding the companies grossly overstated the easements' values.
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October 19, 2026
Tax Court Cuts Ga. Conservation Easement Deductions
Two companies are entitled to smaller charitable contribution deductions for conservation easements than what they claimed, the U.S. Tax Court said, imposing a penalty for gross valuation misstatement in each case.
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October 19, 2026
Meta Says It Didn't Concede Stock Options Issue In Facebook
Despite IRS arguments to the contrary, Meta Platforms told the U.S. Tax Court that it didn't concede that stock option costs need to be included in cost-sharing agreements between affiliates in a prior case involving its predecessor, Facebook.
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October 19, 2026
Adviser In Easement Suit Looks To Shed Malpractice Claim
A financial adviser urged a Georgia federal court to toss a professional malpractice claim in a suit alleging it referred clients to participate in an illegitimate conservation easement scheme, saying the claim is time-barred under state law.
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October 19, 2026
High Court To Mull Home Distilling Ban Following Circuit Split
The U.S. Supreme Court on Monday agreed to take up a case on the federal tax code's ban on distilling whiskey at home after the Fifth Circuit found the ban unconstitutional but the Sixth Circuit upheld the ban.
Expert Analysis
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Key Legal Considerations For Data Center Battery Storage
Battery energy storage systems have become essential infrastructure for data center development — but as trade, energy and tax policies continue to shift, companies operating in this space must understand the importance of supply chain requirements and industry-tailored contracts, says RJ Colwell at Davis Graham.
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Your Next Litigation Hold Should Cover AI Chat Logs
The Delaware Chancery Court’s recent decision in Fortis Advisors v. Krafton to treat a CEO’s artificial intelligence chats as substantive evidence is being read as a discovery warning to litigators, but there is a second duty-to-preserve lesson that is especially pertinent to in-house counsel, say attorneys at Faegre Drinker.
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Cannabis Policy Shift May Reshape Banking, Insolvency Risks
The Trump administration's cannabis rescheduling initiative aims to correct classification that had rendered federal banking, tax administration and insolvency law incoherent, and will begin to restore some alignment between federal law and the economic reality of the marijuana industry, says Richard Ormond at Buchalter.
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Studying Foreign Languages Makes Me A Better Lawyer
Studying Italian and Japanese has shown me that learning a new language can benefit a legal career in several ways, including by demonstrating the importance of approaching problems from a fresh perspective and the value of practicing patience with colleagues and clients, says Anna King at Genworth Financial.
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Sold Inventory May Drive Tax Treatment Of Tariff Refunds
Companies determining the tax treatment of refunds expected following the U.S. Supreme Court's February decision invalidating tariffs imposed under the International Emergency Economic Powers Act should consider whether the tariff costs have already reduced their income considering the cost of goods sold, say attorneys at McDermott.
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Adapting To AI-Driven Scrutiny Of Foreign Asset Disclosures
As the government expands AI-driven, cross-agency fraud detection, foreign asset disclosure should be viewed as part of a broader, data‑driven enforcement ecosystem that prioritizes consistency, documentation and proactive governance, says Logan Koehring at FBT Gibbons.
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Sizing Up The Rescheduling Hurdles Medical Pot Cos. Face
The Justice Department’s recent lowering of certain medical marijuana products to Schedule III means operators — particularly those simultaneously offering federally illegal adult-use cannabis — must implement greater structural discipline to navigate an increasingly fragmented legal landscape if they hope to benefit from new tax deductions and access to capital, say attorneys at Akerman.
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Tax Teams Get No Bright-Line Rule From AI Privilege Cases
Three recent appellate decisions that considered artificial intelligence in the context of attorney-client privilege protections illustrate that taxpayers and tax practitioners alike must consider the pertinent facts on a case-by-case basis, with particular attention to confidentiality, disclosure risk and system design, say attorneys at Morgan Lewis.
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NY Times Word Puzzles Make Me A Better Lawyer
Every morning I let The New York Times humble me with word games, which offer a chance to recalibrate my brain before the day's chaos arrives and remind me that a solution — whether to a puzzle or employment law issue — almost always exists once I find the right angle, says Amy Epstein Gluck at Pierson Ferdinand.
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Law School's Missed Lesson: Diagnose Before Arguing
Law school often skips over explicitly teaching students how to determine what kind of problem a case presents before they commit to a particular doctrinal path, which risks building arguments that are internally coherent but externally misaligned, says Melanie Oxhorn at Kobre & Kim.
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Judges On AI: How Courts Can Survive The Tech Revolution
Colorado Supreme Court Justice Maria Berkenkotter and Colorado Court of Appeals Judge Lino Lipinsky de Orlov discuss how artificial intelligence has already fundamentally altered the legal system and offer tips for courts navigating deepfakes, hallucinations and a gap in access to AI tools.
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3 AI Adoption Mistakes GCs Should Avoid
The pressure in-house legal teams face to quickly adopt artificial intelligence tools, combined with budget constraints and the need to evaluate a crowded market of options, sets the stage for implementation mistakes that are often difficult to undo, says former 23andMe general counsel Guy Chayoun.
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4 Emerging Approaches To AI Protective Order Language
Over the last year, at least five federal district courts have issued or analyzed specific protective order provisions restricting the use of generative artificial intelligence platforms with protected materials, establishing that proactive AI-specific provisions are now standard practice and demonstrating that no single model works for every case, says Joel Bush at Kilpatrick.