Federal
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January 20, 2026
Law360 Names Firms Of The Year
Eight law firms have earned spots as Law360's Firms of the Year, with 48 Practice Group of the Year awards among them, achieving milestones such as high-profile litigation wins at the U.S. Supreme Court and 11-figure merger deals.
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January 20, 2026
Treasury Officials Warn Of Hurdles In 'Trump Account' Rollout
The U.S. Department of the Treasury is racing to open a new retirement savings program for children known as Trump Accounts by early July, and officials are warning that the effort will require a massive undertaking to deliver seed payments and build nationwide systems to track eligibility and contributions.
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January 20, 2026
IRS Can't Probe Partner-Tier Employment Taxes, 1st Circ. Told
The IRS is not authorized to scrutinize a partner's taxable net earnings at the business-entity level under a 1982 law governing partnership audits, an energy investment firm told the First Circuit, challenging the agency's bid to subject limited partners to the self-employment tax.
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January 20, 2026
IRS Funding Boost Faces $11.7B Cut In Bipartisan Package
Congress would cut $11.7 billion from the IRS spending boost included in the Inflation Reduction Act under a bipartisan, bicameral spending package released Tuesday by the House and Senate Appropriations committees.
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January 20, 2026
Tax Court Wrongly Cut Conservation Gift Value, 4th Circ. Told
The U.S. Tax Court made multiple errors when it reduced the value of rock-rich land underlying a North Carolina partnership's conservation easement donation, the partnership told the Fourth Circuit, urging it to at least reverse penalties imposed by the court as a result of its findings.
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January 16, 2026
Law360 Names Practice Groups Of The Year
Law360 would like to congratulate the winners of its Practice Groups of the Year awards for 2025, which honor the attorney teams behind litigation wins and significant transaction work that resonated throughout the legal industry this past year.
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January 18, 2026
Trump Threatens 10% Tariff To Goad EU Nations On Greenland
President Donald Trump said he would impose a 10% tariff on several countries in the European Union beginning Feb. 1 as a way to build pressure toward his goal for the U.S. to purchase Greenland, according to a social media post.
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January 17, 2026
5th Circ. OKs Self-Employment Tax Break For Limited Partners
Business partners with limited liability under state law are excluded from the federal self-employment tax, a Fifth Circuit panel ruled, siding with a management consulting firm in its long-running controversy over the levy's limited-partner exception.
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January 16, 2026
DOJ Says Wife Owes FBAR Penalties On India Account
A New York federal court should find that a businessman's wife owes penalties for his failure to report his Indian bank account to the Internal Revenue Service after he deposited $1.5 million from the sale of a New York apartment complex, the U.S. Department of Justice argued Friday.
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January 16, 2026
Treasury's Rule Pace Unchanged After Loper Bright, Atty Says
The U.S. Supreme Court's 2024 landmark decision limiting federal agencies' deference in interpreting ambiguous statutes has not significantly altered the pace and volume of the U.S. Department of the Treasury's rulemaking workload, a Treasury attorney said Friday.
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January 16, 2026
IRS Rightly Withheld Worker Tax Credit FOIA Docs, Court Says
The Internal Revenue Service properly invoked two Freedom of Information Act exemptions to withhold portions of internal directives about the employee retention tax credit requested by an attorney who represents taxpayers in disputes with the agency, an Alabama federal court said.
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January 16, 2026
IRS Boosts Mediation Training In Appeals, Official Says
The IRS has ramped up its training of appeals officers to perform mediation work to account for the recent reduction of staff as part of the agency's ongoing emphasis to quickly resolve taxpayer issues through the alternative dispute resolution process, an official said Friday.
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January 16, 2026
Taxation With Representation: Stibbe, A&O Shearman, Latham
In this week's Taxation With Representation, Keurig Dr Pepper Inc. plans to complete its deal to snap up coffee company JDE Peet's NV, Boston Scientific Corp. acquires medical device company Penumbra Inc., and fitness and wellness platform parent Playlist merges with fitness technology company EGYM.
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January 16, 2026
Paramount Signs 1st Lease At New Manhattan Studio
Realty Trust, Hudson Pacific Properties Inc. and Blackstone Real Estate announced that the joint venture partners behind a Manhattan studio still under construction have signed the property's first lease with Paramount Television Studios.
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January 16, 2026
State Rules Add Wrinkle To Scholarship Tax Break's Rollout
The U.S. Treasury Department is grappling with how to balance federal and state rules to implement a new tax credit for contributions to eligible scholarship programs, an official said Friday, describing states as "gatekeepers" in determining eligibility.
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January 16, 2026
German Co. Cites Good Faith In Disputing $1.2M Tax Bill
A German manufacturer is challenging a $1.2 million tax bill stemming from late information filings, telling the U.S. Tax Court it relied in good faith on its domestic partnership's manager and other qualified professionals.
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January 16, 2026
Spain, US Spell Out Tax Treaty Arbitration Process
Spain and the United States signed an agreement spelling out the process for binding arbitration under their tax treaty, which requires an independent panel to resolve disputes by selecting only one side's position, according to an IRS announcement Friday.
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January 16, 2026
Conservation Easement Was $2.7M 'Swindle,' Investors Say
Two investors have hit the Georgia-based managers of a syndicated conservation easement with a racketeering lawsuit, accusing the managers of lining their own pockets with nearly all the proceeds of a 2024 real estate sale to liquidate the fund.
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January 16, 2026
Tax Court Won't Rethink Late Challenge In $46M Case
The U.S. Tax Court won't reconsider its rejection of a late-filed bid by a partnership seeking to restore its $46 million tax deduction for donating to charity, saying the Alabama company failed to raise a newly available legal argument as required for the second chance.
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January 16, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included final rules for the inclusion of certain qualified derivative payments linked to securities-lending transactions when calculating payments covered by the base erosion and anti-abuse tax.
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January 16, 2026
Basic Allowance For Military Housing Isn't Taxable, IRS Says
The supplemental basic allowance for housing payments made to uniformed military personnel in December are not to be included in income and are not taxable, the Internal Revenue Service and U.S. Department of the Treasury said Friday.
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January 15, 2026
As Goldstein Trial Begins, Gov't Points To 'Lavish' Lifestyle
An accountant for billionaire investor Alec Gores said that Thomas Goldstein had suggested he open a foreign account for Gores' poker-related transactions or even classify him as a professional player for tax purposes, although Gores was just getting started in the high-stakes poker world.
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January 15, 2026
Businesses Seek Clarity On R&D Credit Post-GOP Tax Law
Businesses that use the federal research credit are reexamining how to apply expense reduction rules after last year's GOP tax law changes, but Treasury officials and tax experts said Thursday that revisions, although complex, were intended to coordinate with existing capitalization rules.
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January 15, 2026
US Pillar 2 Deal May Spur Other Nations To Seek Exemptions
International negotiators designed a 15% corporate minimum tax known as Pillar Two to apply worldwide, but a recently agreed-to carveout for the U.S. may prompt other countries with qualifying alternative regimes to seek similar exemptions that ultimately strain the global system.
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January 15, 2026
Private Activity Rules Don't Apply To Tax-Exempt Train Bonds
Private activity bond rules do not apply to certain tax-exempt bonds issued by the Alaska Railroad Corp. to finance certain property, the Internal Revenue Service said Thursday.
Expert Analysis
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The Ins And Outs Of Consensual Judicial References
As parties consider the possibility of judicial reference to resolve complex disputes, it is critical to understand how the process works, why it's gaining traction, and why carefully crafted agreements make all the difference, say attorneys at Pillsbury.
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The BigLaw Settlements Are About Risk, Not Profit
The nine Am Law 100 firms that settled with the Trump administration likely did so because of the personal risk faced by equity partners in today's billion‑dollar national practices, enabled by an ethics rule primed for modernization, says Adam Forest at Scale.
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House Bill Tax Tweaks Would Hinder Renewable Projects
Provisions in the budget reconciliation bill recently passed by the U.S. House of Representatives would rapidly phase out clean energy tax credits, constrain renewable energy financing arrangements and impose sweeping restrictions on projects with foreign ties, which may create compliance and supply chain issues for many developers, say attorneys at Paul Hastings.
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Power To The Paralegals: An Untapped Source For Biz Roles
Law firms looking to recruit legal business talent should consider turning to paralegals, who practice several key skills every day that prepare them to thrive in marketing and client development roles, says Vanessa Torres at Lowenstein Sandler.
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How Trucking Cos. Can Keep Rolling Under Tariff Burdens
Recent Trump administration tariffs present major challenges for the transportation and logistics sector — and, in particular, trucking — but providers who focus on operational efficiency, cost control, customer relationships, creative contract structures and unique offerings will stand out from the competition, say attorneys at Benesch.
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Tariff Strategies For The US Renewable Energy Sector
The Trump administration's tariff actions over the last few months are challenging for the renewable energy industry — but there are strategies for contending with the uncertainty, including diversifying supply chains, seeking certification about equipment origins, and adding tariff-related language to supply contracts and offtake agreements, say attorneys at Sheppard Mullin.
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Ch. 7 Marshaling Ruling Rests On Shaky Legal Grounds
In its recent holding in a Chapter 7 bankruptcy case that marshaling may not be applied against the IRS, a Texas federal court misapplied a bankruptcy code section and case law, leaving a draconian decision that could limit the scope of a powerful equitable estate tool, says Brian Shaw at Cozen O'Connor.
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3 Tax Issues Manufacturers Should Watch In 2025 Budget Bill
As Congress works toward a budget reconciliation bill, manufacturing companies should keep a keen eye on proposals to change bonus depreciation, the qualified business income deduction and energy tax credits, which could have a significant impact on capital-intensive industries, say attorneys at Frost Brown Todd.
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$38M Law Firm Settlement Highlights 'Unworthy Client' Perils
A recent settlement of claims against law firm Eckert Seamans for allegedly abetting a Ponzi scheme underscores the continuing threat of clients who seek to exploit their lawyers in perpetrating fraud, and the critical importance of preemptive measures to avoid these clients, say attorneys at Lockton Companies.
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Jurisdictional Issues At Play In 9th Circ.'s FCA Trade Case
A decision by the Ninth Circuit in Island Industries v. Sigma Corp. could result in the U.S. Court of International Trade’s exclusive jurisdiction over trade-related FCA cases, a big shift in the enforcement landscape just as tariffs take center stage in trade policy, say attorneys at Haynes Boone.
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Evolving Federal Rules Pose Further Obstacles To NY LLC Act
Following the Financial Crimes Enforcement Network's recent changes to beneficial ownership information reporting under the federal Corporate Transparency Act — dramatically reducing the number of companies required to make disclosures — the utility of New York's LLC Transparency Act becomes less apparent, say attorneys at Pillsbury.
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Alternative Business Structures Raise Ethics Questions
The new KPMG law firm, launched in Arizona following that state's repeal of the prohibition on fee sharing with nonlawyers, raises a number of important practice questions, both for the firm and those law firms seeking to partner with it, says Deborah Winokur at Cozen O’Connor.
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The IRS Shouldn't Go To War Over Harvard's Tax Exemption
If the Internal Revenue Service revokes Harvard's tax-exempt status for violating established public policy — a position unsupported by currently available information — the precedent set by surviving the inevitable court challenge could undercut the autonomy and distinctiveness of the charitable sector, says Johnny Rex Buckles at Houston Law Center.