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Federal
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March 25, 2026
ABA Urges Flexibility In IRS Voluntary Disclosure Practice
Participation in the IRS' voluntary disclosure practice would likely increase if the agency rethinks its proposed three-month deadline for individuals to file returns and pay liabilities, the American Bar Association's tax section said in a letter publicly released Wednesday.
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March 24, 2026
Rubio Says He Didn't Know Of Friend's Venezuelan Oil Deal
U.S. Secretary of State Marco Rubio would not have met with an old friend, former Rep. David Rivera, to discuss a government transition in Venezuela had he known Rivera's company had a contract with a subsidiary of Venezuela's state-owned oil company, Rubio told jurors Monday.
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March 24, 2026
Goldstein Seeks New Trial, Citing 'A Series Of Legal Errors'
SCOTUSblog founder and appellate icon Thomas Goldstein has filed a lengthy motion for a new trial or acquittal after his conviction on a dozen criminal charges related to tax evasion, alleging his trial was marred by improper jury instructions, improper exclusion of evidence and inadequate evidence, among other things.
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March 24, 2026
IRS Must Address AI Skills Gaps, GAO Says
The Internal Revenue Service has rapidly increased its artificial intelligence use since August 2022, but major staffing reductions at the agency could have a significant impact on its ability to use AI, the U.S. Government Accountability Office said in a report released Tuesday.
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March 24, 2026
FedEx Asks 6th Circ. To Uphold $89M Foreign Tax Credit
FedEx is entitled to an $89 million tax refund because the U.S. Department of the Treasury lacked the authority to issue regulations disallowing foreign tax credits for offset earnings, the company told the Sixth Circuit, asking the court to uphold a lower court ruling.
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March 24, 2026
Tax Penalties Didn't Need Early Approval, Justices Told
A lower-ranking IRS agent was allowed to tell a couple, before getting her supervisor's approval, that she recommended they pay tax penalties, the federal government told the U.S. Supreme Court in urging it to uphold the Eleventh Circuit's reading of a supervisor sign-off requirement.
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March 24, 2026
Tax Agencies Using AI Mainly To Flag Fraud, OECD Says
Tax administrations in member countries of the Organization for Economic Cooperation and Development are using artificial intelligence mainly to detect tax evasion and fraud, the OECD reported Tuesday, saying this is because of the technology's ability to identify patterns and outliers.
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March 24, 2026
Buying Energy Tax Credits Likely A Corp. Norm, Report Says
Around 80% of the largest U.S. corporations that began buying clean energy tax credits three years ago remained active buyers in 2025, signaling the practice becoming standard in corporate tax planning, according to a Tuesday report by a clean energy capital platform.
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March 23, 2026
IRS Concedes To Partnership's $48M Easement Deduction
A partnership will be entitled to all of a $48.3 million tax deduction for donating a Louisiana conservation easement amid allegations that the IRS improperly backdated documents to impose civil fraud penalties and circumvent the statute of limitations, according to a decision entered Monday in the U.S. Tax Court.
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March 23, 2026
Tax Court Filing Deadline Is Not Flexible, 4th Circ. Told
A man who missed the deadline for challenging his tax bill in the U.S. Tax Court should not be allowed extra time to make his case, the government told the Fourth Circuit on Monday, saying the deadline, despite conflicting views among the circuits, is not flexible.
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March 23, 2026
IRS Direct File Had Low Participation, TIGTA Says
Participation in the Internal Revenue Service's shuttered Direct File pilot program was lower than the agency expected, but there were many opportunities for the agency to improve the user experience, the Treasury Inspector General for Tax Administration said in a report.
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March 23, 2026
ND Law Firm Can't Justify Equitable Tolling, IRS Tells 8th Circ.
A North Dakota law firm that got the U.S. Supreme Court to revive its day-late levy challenge has failed to prove that it deserved equitable tolling of its statute of limitations, the IRS told the Eighth Circuit on Monday.
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March 23, 2026
Wyden Questions Leon Black On Epstein Financial Dealings
The Senate Finance Committee's top Democrat pressed Apollo Global Management co-founder Leon Black in a letter released Monday to provide more information about his financial dealings with Jeffrey Epstein, including why he agreed to pay Epstein $170 million for supposed tax and estate planning services.
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March 23, 2026
IRS Lacks Solid Plan To Audit Large Partnerships, TIGTA Says
The IRS has no solid strategy for auditing large partnerships, resulting in markedly fewer audits as partnerships proliferate and compliance efforts that go nowhere, the Treasury Inspector General for Tax Administration said in a report.
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March 23, 2026
Bahamian Law Can't Shield Trusts In $28M Tax Suit, DOJ Says
A Floridian facing a $28 million tax bill cannot invoke Bahamian law to avoid repatriating funds held in two Bahamian trusts, the U.S. government told a federal court, contending he is "cherry-picking" which jurisdiction's law applies in different situations.
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March 23, 2026
Democratic AGs Demand IEEPA Tariff Refund Legislation
A group of Democratic state attorneys general pushed congressional leaders to enact legislation that would require timely refunds of all duties levied under the now-invalidated International Emergency Economic Powers Act tariffs, including interest.
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March 23, 2026
Tax-Evading Farm Biz Owner Hospitalized On Way To Prison
The owner of a vertical farming business whom federal authorities sought to arrest after he failed to report to prison for tax evasion was hospitalized for a medical emergency on his way to surrender, his wife told a Pennsylvania federal court Monday.
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March 23, 2026
IRS Seeks Input On 2025 Law, Deregulation For Guidance Plan
The U.S. Treasury Department and IRS asked for suggestions Monday on what to prioritize in an upcoming guidance plan, seeking input on tax issues related to the 2025 budget reconciliation law and on opportunities for deregulation.
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March 20, 2026
5th Circ. Wipes Out FTC's TurboTax 'Deceptive' Ad Ruling
The Fifth Circuit on Friday vacated the Federal Trade Commission's cease-and-desist order imposed on Intuit Inc. for its TurboTax advertising that regulators say duped customers into thinking they could file their tax returns for free, saying the agency's in-house decision is unconstitutional, and the dispute must go to federal court.
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March 20, 2026
4 Open Questions On Tariff Refund System Development
U.S. Customs and Border Protection is developing a system to refund tariffs struck down by the U.S. Supreme Court, but it remains unclear whether it will cover the entire gamut of duties President Donald Trump imposed under the International Emergency Economic Powers Act. Here, Law360 examines four open questions surrounding the IEEPA tariff refund system being developed by Customs.
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March 20, 2026
DC Circ. Urged To Maintain Block On IRS-ICE Data Sharing
The D.C. Circuit should keep in place a block on the IRS' policy of sharing data with immigration authorities because the policy is unlawful and a lower court properly weighed the matter, a coalition of nonprofits and labor unions said.
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March 20, 2026
$22M Easement With Viable Mine Not 'Abusive,' 11th Circ. Told
A Georgia conservation easement donor asked the Eleventh Circuit to resurrect a nearly $22 million deduction associated with the land donation, saying the U.S. Tax Court admitted that there was no abuse in the donated transaction.
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March 20, 2026
Duane Morris Bolsters SF Team With Hanson Bridgett Hire
Duane Morris LLP is growing its West Coast team, bringing in a Hanson Bridgett LLP transactions attorney as a partner in its San Francisco office.
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March 20, 2026
4th Circ. Dubious Of Undoing Execs' Payroll Tax Convictions
Two former software executives in North Carolina challenging their conviction for failing to pay employment taxes seemed unlikely to get a reversal in the Fourth Circuit on Friday, with at least one judge hearkening back to his days as a prosecutor as he opined that the pair had essentially been "stealing."
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March 20, 2026
Taxation With Representation: Clifford Chance, Davis Polk
In this Week's Taxation With Representation, Public Storage acquires National Storage Affiliates Trust, 3M teams up with Bain Capital to buy Madison Fire & Rescue, and Mastercard acquires stablecoin infrastructure firm BVNK.
Expert Analysis
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Trump Tax Law's Most Consequential International Changes
The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.
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Associates Can Earn Credibility By Investing In Relationships
As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.
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Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling
The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.
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What 2 Profs Noticed As Transactional Law Students Used AI
After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.
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BigLaw Settlements Should Not Spur Ethics Deregulation
A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.
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5 Ways Lawyers Can Earn Back The Public's Trust
Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.
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Legal Jeopardy Looms Over Trump's Trade Negotiation Plans
Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.
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Opportunity Zone Overhaul Is Good News For Investors
Recently enacted reforms making the qualified opportunity zone program permanent, restoring the basis step-up for capital gains and adding flexibility to the zone designation process enhance the program’s appeal for long-term investment, says Steven Hadjilogiou at McDermott.
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White House Report Strikes An Optimistic Note On Crypto
Taking seriously President Donald Trump's pledge to adopt a pro-innovation mindset toward digital assets and blockchain technologies, a recent benchmark White House report on crypto provides a comprehensive regulatory framework that takes into account the products' novel characteristics within the high-tech ecosystem, say attorneys at Davis Wright.
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Bipartisan Bill Could Aid ESOP Formation, Valuation Clarity
The proposed Retire through Ownership Act represents a meaningful first step toward clarifying whether transactions qualify under the adequate consideration exemption in the Employee Retirement Income Security Act, potentially eliminating the litigation risk that has chilled employee stock ownership plan formation, say attorneys at Moore & Van Allen.
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Bar Exam Reform Must Expand Beyond A Single Updated Test
Recently released information about the National Conference of Bar Examiners’ new NextGen Uniform Bar Exam highlights why a single test is not ideal for measuring newly licensed lawyers’ competency, demonstrating the need for collaborative development, implementation and reform processes, says Gregory Bordelon at Suffolk University.
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A Simple Way Courts Can Help Attys Avoid AI Hallucinations
As attorneys increasingly rely on generative artificial intelligence for legal research, courts should consider expanding online quality control programs to flag potential hallucinations — permitting counsel to correct mistakes and sparing judges the burden of imposing sanctions, say attorneys at Lankler Siffert & Wohl and Connors.
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Supreme Court's Criminal Law Decisions: The Term In Review
Though the U.S. Supreme Court’s criminal law decisions in its recently concluded term proved underwhelming by many measures, their opinions revealed trends in how the justices approach criminal cases and offered reminders for practitioners, says Kenneth Notter at MoloLamken.