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Federal
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May 15, 2026
Taxation With Representation: Cassels, Ropes & Gray
In this week's Taxation With Representation, Equinox Gold Corp. and Orla Mining Ltd. announce a merger to create a major gold producer, OpenAI plans to form a company to boost adoption of its software across enterprises and private equity firm Apollo acquires trade show operators Emerald Holding and Questex.
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May 15, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included a proposed reduction for the fee it charges people who take the exam for becoming an enrolled agent.
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May 15, 2026
IRS Sets Preapproved Plan Opinion Letter Rules For 2026
The Internal Revenue Service issued a set of changes to requirements for preapproved plan providers applying for opinion letters for the fourth remedial amendment cycle.
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May 15, 2026
OECD To List Countries Ready To Receive Global Returns
The Organization for Economic Cooperation and Development plans to publish on Monday a list of countries implementing the global minimum tax that plan to have online portals in place to receive the required information returns by May 31, the organization's top tax official said Friday.
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May 14, 2026
Ex-Newsom Aide Cops To Campaign Fund Theft, False Taxes
A former chief of staff to California Gov. Gavin Newsom pled guilty in federal court in Sacramento for her part in a scheme to divert some $225,000 from a dormant political campaign to a former Biden administration official's chief of staff, the U.S. Department of Justice announced Thursday.
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May 14, 2026
Fed. Circ. Affirms $80M Penalty For Trust Caught In Tax Fraud
A group of family trusts failed Thursday to convince the Federal Circuit to reverse a lower court ruling that held them liable for an $80 million tax bill after being conned by a fraudster who then engaged in abusive tax shelter transactions behind their backs.
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May 14, 2026
SC Co. Defends $24M Deduction For Ga. Land Donation
A partnership based in South Carolina said the IRS erred in disallowing its $24 million deduction in 2019 for 122 acres donated to a conservancy in Georgia and in assessing a 40% penalty.
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May 14, 2026
Wyden Seeks June Vote For Bipartisan IRS Reform Bill
The Senate Finance Committee's top Democrat would like his committee to vote as soon as next month on a bipartisan package that would implement several National Taxpayer Advocate-backed fixes at the Internal Revenue Service, he said Thursday.
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May 14, 2026
'Pig Butchering' Crypto Scam Victim Seeks $962K From IRS
An Ohio man told a district court that the Internal Revenue Service wrongly denied his tax deduction claim for a loss of over $800,000 from a cryptocurrency "pig butchering" scheme despite the extensive documentation of the fraud he said he provided to the agency.
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May 13, 2026
Lawmakers Float Allowing Charitable Gifts From 401(k) Plans
A bipartisan group of federal lawmakers on Wednesday introduced a bill that would allow workers to make tax-free charitable donations directly from their employer-sponsored retirement plans, building on a section of the retirement policy overhaul known as Secure 2.0.
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May 13, 2026
Tax Bill Challenge Filing Deadline Is Flexible, 4th Circ. Told
A man who missed the deadline for challenging his tax bill in the U.S. Tax Court urged the Fourth Circuit to revive his suit, saying the statutory cutoff for filing petitions does not have to be strictly followed in every case.
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May 13, 2026
DOJ Fraud Division Set To Shake Up White-Collar Enforcement
President Donald Trump's administration created the U.S. Department of Justice's National Fraud Enforcement Division with a narrow focus on combating government program fraud, but a move to retain federal prosecutors focused on other types of fraud could signal a wider scope with potential ripple effects across white-collar enforcement.
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May 13, 2026
Accendra Pays $19M To Settle IRS Transfer Pricing Matter
Accendra Health Inc. paid $19 million to the Internal Revenue Service to conclude tax matters related to international transfer pricing activity between 2015 and 2018, according to a recent earnings call with investors.
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May 13, 2026
Trump 1st-Term Tariff Hikes On China Legal, Feds Tell Justices
President Donald Trump's first administration was well within its legal authority to increase tariffs on Chinese goods under a law utilized to address unfair trading practices, and the U.S. Supreme Court doesn't need to consider a challenge to those measures, the government told the justices.
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May 13, 2026
Tax Court Won't Rethink Nix Of Russian Scientist's Exemption
The U.S. Tax Court won't rethink its decision that the U.S. Department of Energy's payments to a Russian scientist for his subatomic particle research in Virginia don't fall under a tax exemption for grants in the U.S.-Russia tax treaty.
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May 13, 2026
IRS Offers Easement Deals With 10% Penalty, No Haggling
Eligible partnerships disputing conservation or historic preservation easement charitable deductions cannot negotiate their tax benefit amounts under the Internal Revenue Service's latest settlement offer, which carries a 10% penalty, the agency announced Wednesday.
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May 12, 2026
SCOTUSblog Founder Can't Delay Tax Fraud Sentencing
A Maryland federal judge has rejected SCOTUSblog founder Thomas Goldstein's request to push back sentencing for his tax evasion conviction, finding that Goldstein "has not shown good cause to continue sentencing."
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May 12, 2026
Ga. Partnership Defends $46M Deduction For Donated Acres
A Georgia partnership is disputing the IRS' assessment of $17.1 million in underpaid tax and $6.8 million penalties for its 2020 tax year, saying the agency wrongly disallowed its $46.2 million deduction for a charitable contribution of over 337 acres.
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May 12, 2026
9th Circ. Orders New Tax Fraud Trial Over Juror's Racial Bias
An Idaho federal court wrongly denied a man of Mexican descent a new trial after discovering a juror had made racially biased comments about people of Mexican ethnicity during deliberations on whether to convict him of preparing false tax returns, a split Ninth Circuit panel said Tuesday.
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May 12, 2026
US Asks Court To Reject Bright-Line IRS Political Activity Test
A D.C. federal court should not set a bright-line test for determining whether tax-exempt social welfare organizations are engaging in improper political campaigning, the federal government said during a hearing Tuesday, in a case in which the court previously said the existing test was too vague.
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May 12, 2026
Ala. Partnership Says Donated Land Was Worth $21M
An Alabama partnership defended its deduction of $21 million for land donated to a conservancy in Mobile in 2018, saying it was told by a qualified appraiser that the property's "highest and best use" would have been as a residential development.
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May 12, 2026
New Precedent Revives $6.6M IRS Penalty Fight, Broker Says
An insurance broker asked a Pennsylvania federal court to consider new constitutionality arguments against the IRS penalty prepayment requirement to revive its challenge to $6.6 million in captive insurance tax penalties, arguing those claims rely on new legal precedent.
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May 12, 2026
Over 8 Million Imports In Line For Over $35B In Tariff Refunds
Over 8.3 million imports are pending tariff refunds after clearing the final system processes developed by Customs and Border Protection, accounting for almost $35.5 billion in duty refunds with interest, according to the latest declaration filed Tuesday by an agency official in the U.S. Court of International Trade.
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May 12, 2026
Fed. Circ. Pauses Trade Court Ruling Blocking Trump Tariffs
The Federal Circuit halted a permanent injunction issued by the U.S. Court of International Trade that was scheduled to take effect on Tuesday, which would have stopped the collection of duties under President Donald Trump's temporary global tariff from two businesses and the state of Washington.
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May 11, 2026
Trump Asks Federal Circuit To Pause Trade Court Tariff Ruling
President Donald Trump on Monday asked the Federal Circuit to block the U.S. Court of International Trade's order last week deeming his temporary global 10% tariffs unlawful, arguing the trade court misinterpreted the legislative history of the Trade Act.
Gov't Asks 6th Circ. To Reverse FedEx's $89M Tax Credit Win
The U.S. government urged the Sixth Circuit to reverse a Tennessee federal court's decision that invalidated foreign tax credit regulations and allowed FedEx an $89 million refund, arguing that the rules reflect Congress' intent to prevent windfalls under the 2017 tax overhaul.
Corp. AMT Proposal Coming In February, Official Says
The U.S. plans to propose its entire package of rules on the corporate alternative minimum tax — which has so far been the subject of five Internal Revenue Service notices — in February, an official from the U.S. Department of the Treasury said Thursday.
Meta Must Share Option Costs Post-Altera, IRS Says
The Ninth Circuit's 2019 ruling against Altera Corp., which upheld rules requiring companies to share the cost of employee stock options with foreign affiliates, means that Meta's income for 2017-18 should be increased by roughly $3 billion, the IRS told the U.S. Tax Court.
Featured Stories
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DOJ Fraud Division Set To Shake Up White-Collar Enforcement
President Donald Trump's administration created the U.S. Department of Justice's National Fraud Enforcement Division with a narrow focus on combating government program fraud, but a move to retain federal prosecutors focused on other types of fraud could signal a wider scope with potential ripple effects across white-collar enforcement.
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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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Meet The Attys Arguing The High Court 'Skinny Label' Case
When the U.S. Supreme Court hears arguments Wednesday in a patent case involving "skinny labels" on generic drugs, a longtime patent attorney as well as a government attorney who often handles intellectual property cases will face an appellate specialist who has argued many high court cases.
Expert Analysis
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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 general counsel to make several 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.
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Heppner Ruling Left AI Privilege Risk For Lawyers Unresolved
While a New York federal judge’s recent ruling in U.S. v. Heppner resolved a privilege question surrounding client-side artificial intelligence use, it did not address how to mitigate the risks that can arise when confidential information enters the operative context of an AI system used by an attorney, says Jianfei Chen at Quarles & Brady.
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How To Limit Accounting Fraud Risk As SEC Focus Persists
Despite the U.S. Securities and Exchange Commission's pullback on crypto, cybersecurity and recordkeeping cases, accounting fraud remains a core enforcement priority, making it important for public companies and auditors to strengthen controls, investigations and whistleblower processes, say attorneys at Pillsbury.
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Speed Jigsaw Puzzling Makes Me A Better Lawyer
My passion for speed puzzling — I can complete a 500-piece jigsaw puzzle in under 50 minutes — has sharpened my legal skills in more ways than one, with both disciplines requiring patience, precision and the ability to keep the bigger picture in mind while working through the details, says Tazia Statucki at Proskauer.
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Documenting Business Purpose After IRS' 10th Circ. Win
Following the Tenth Circuit’s recent Liberty Global v. U.S. decision, which held the economic substance doctrine does not require a threshold relevancy determination, taxpayers can prepare for potential audits by maintaining contemporaneous documentation and taking other steps that demonstrate the business purpose of transactions, say attorneys at Crowell & Moring.
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2 AI Snafus Show Why Attys Can't Outsource Judgment
The recent incident involving Sullivan & Cromwell where citations in a filed motion were fabricated by artificial intelligence, as well as a punitive ruling from the Sixth Circuit in U.S. v. Farris, demonstrate that the obligation to supervise AI has belonged and always will belong to lawyers, says John Powell at the Kentucky School Boards Association.
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How Data Center Accounting May Draw Enforcement Scrutiny
As public and media scrutiny of the data center industry intensifies, regulators, enforcement authorities and Congress will likely focus on accounting judgments that rely on aggressive assumptions, opaque financing structures or rapidly evolving collateral classes, heightening the risk of investigations and inquiries, say attorneys at King & Spalding.
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Improving Well-Being In Law, 10 Years After Landmark Study
An important 2016 study revealed significant substance abuse and mental health issues among lawyers, and while the findings helped normalize the conversation around these topics, a decade later, structural change is still needed, says Denise Robinson at PLI.
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How To Gear Up For Trump's Pharma Tariffs
President Donald Trump's proclamation establishing tariffs on certain pharmaceutical products holds a few areas of ambiguity that companies should review and prepare for before the tariffs come into effect later this year, say attorneys at Arnold & Porter.
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Steps To Consider As DOJ Launches Fraud Division
The establishment this month of the National Fraud Enforcement Division within the U.S. Department of Justice is a significant reorganization that suggests an increase in enforcement activity involving federally funded programs but leaves a number of important questions unanswered, say attorneys at Crowell & Moring.
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What To Expect From The SEC's New SOX Group
In a potential shift away from Public Company Accounting Oversight Board enforcement, the U.S. Securities and Exchange Commission's formation of a new group to investigate and litigate potential violations of the Sarbanes-Oxley Act brings both risks and benefits for auditors, say attorneys at King & Spalding.
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Hungary CPAC Funding Probe Could Implicate US Entities
A Hungarian anti-corruption investigation into claims that the former prime minister used taxpayer funds to support the Conservative Political Action Conference could include potential cross-border political and financial dimensions that create multiple touchpoints for U.S. regulatory and enforcement interest, say attorneys at Ballard Spahr.