State & Local

One Certainty As Tariff Refunds Start: 'There Will Be Litigation'

Chris Villani

The launch of the refund process for tariffs struck down by the U.S. Supreme Court marks the start of lengthy and multifaceted court battles as companies fight with consumers — and amongst themselves — about who gets a slice of the $166 billion pie, experts told Law360.

Spinoff Landscape Unclear In Wake Of Tossed IRS Guidance

Natalie Olivo
Senior Tax Correspondent

The Internal Revenue Service has scrapped controversial guidance that limited the types of spinoff transactions that revenue officials would approve as tax-free ahead of time, but the path to seeking the agency's blessing for certain intercompany reorganizations remains hazy.

Little-Known Gambling Tax Could Upend Boom In US Betting

Stephen K. Cooper
Editor-at-Large

After a record year for U.S. commercial gaming, a little-known tax on phantom income in last year's Republican reconciliation law has spurred bipartisan repeal efforts amid concerns it could alter betting behavior and drain state and local economies built on gambling-related tourism.

Mitigating Multistate Risks As California Expands Tax Reach

Though California's new sourcing rules and extension of the pass-through entity election have created uncertainty, practitioners should file protective returns to respect the law's ambiguity and take certain other steps to protect clients from the costs of losing a future audit, says attorney Delina Yasmeh.

E-Discovery Quarterly: Recent Rulings On ESI Control

Several recent federal court decisions have perpetuated a split over what constitutes “control” of electronically stored information — with judges divided on whether the standard should turn on a party's legal right or practical ability to obtain the information, say attorneys at Sidley.

Anticipating The Justices' Potential Ruling On Tax Takings

Recent oral arguments in the U.S. Supreme Court case Pung v. Isabella focused on rules for valuation, timing and administrability of tax auction proceeds and whichever method the court adopts for determining just compensation, it will have far-reaching impacts on tax collection, homeowners' equity and the secondary market for tax-foreclosed property, say attorneys at Holland & Knight.

2 Discovery Rulings Break With Heppner On AI Privilege Issue

While a New York federal court’s recent ruling in U.S. v. Heppner suggests that some litigants’ communications with AI tools are discoverable, two other recent federal court decisions demonstrate that such interactions generally qualify for work-product protection under the Federal Rules of Civil Procedure, says Joshua Dunn at Brown Rudnick.

What's Right Isn't Always Easy To Swallow: SALT In Review

From vodka warehoused in Maine to Nebraska's new excise on something called kratom, RSM's David Brunori offers his thoughts on noteworthy state and local tax news.

Calculating Damages In IEEPA Tariff Refund Litigation

To calculate damages in the spate of refund litigation triggered by the U.S. Supreme Court's recent decision invalidating tariffs collected under the International Emergency Economic Powers Act, the central question will be how to determine where in the supply chain their economic burden ultimately came to rest, say analysts at Charles River Associates.

Alpine Skiing Makes Me A Better Lawyer

Skiing has shaped habits I rely on daily as an attorney — focus, resilience and the ability to remain steady when circumstances shift rapidly — and influences the way I approach legal strategy, client counseling and teamwork, says Isaku Begert at Marshall Gerstein.

NY Tax Talk: Calculating Tiered Partnership Income

Attorneys at Eversheds Sutherland discuss how the potential impact recent New York City Tax Appeals Tribunal decision in Matter of Cantor Fitzgerald holding that the entity approach should be used by tiered partnerships to compute unincorporated business tax liability, why the issue of the proper approach remains unsettled and the broader implications for federal conformity and administrative agency deference.

What A Court Doc Audit Reveals About Erroneous Filings

My audit of 1,522 court documents from last month found that over 95% contained at least one verifiable error, with fewer than 1% showing clear indicators of artificial intelligence use — highlighting above all else that lawyers may want to focus most on strengthening their review processes, says Elliott Ash at ETH Zurich.

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

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.

What The Wealthy Can And Will Do: SALT In Review

From new research that undercuts state taxes on the wealthy to an Indiana law concerned with foreign affairs, RSM's David Brunori offers his thoughts on noteworthy state and local tax news.

Navigating The Perks Of Qualified Opportunity Zones 2.0

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

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.