Federal
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February 04, 2026
Trump Bid To Move NY Appeal Faces 'Fatal' Error, Judge Says
A Manhattan federal judge on Wednesday repeatedly aired doubts that President Donald Trump can upend the pending New York state appeal of his hush-money conviction by moving the case to federal court.
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February 04, 2026
5 Takeaways From 5th Circ.'s Limited Partner Tax Decision
The Fifth Circuit has issued a long-awaited opinion holding that partners with limited liability under state law qualify for an exclusion from the self-employment tax, and the decision offers five notable takeaways that experts said may shed light on the potential fate of partnership taxation and compliance.
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February 04, 2026
Tax Group Of The Year: Davis Polk
Davis Polk & Wardwell LLP scored a significant victory for Exxon Mobil in litigation concerning the tax treatment of a major partnership with Qatar and oversaw several other complex, high-stakes transactions, earning it recognition as a 2025 Law360 Tax Practice Group of the Year.
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February 04, 2026
Tax Court Urged To Restore $43M Break For Historic Buildings
A partnership argued for restoring its $43 million tax deduction for protecting historic property in Kentucky that included a 19th century post office, telling the U.S. Tax Court that the IRS had arbitrarily rejected its claim.
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February 04, 2026
IRS Urges Tax Court To Cut $315M From Siemens Deduction
The Internal Revenue Service defended its slashing of $315 million from a tax deduction that medical giant Siemens claimed on payments from overseas, telling the U.S. Tax Court that rule writers had congressional backing to issue the regulations underpinning the adjustment.
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February 04, 2026
Walmart Wants Relief In CFC Tax Year Deferral
Walmart asked the U.S. Department of the Treasury to temporarily allow certain taxpayers to file a single 13-month return, instead of two separate returns, in the wake of filing changes regarding controlled foreign corporations, according to a letter released Wednesday.
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February 03, 2026
Goldstein Knew What Was On His Returns, Accountant Claims
The top outside accountant handling tax returns for SCOTUSblog founder Thomas Goldstein and his law firm said Tuesday that Goldstein wasn't forthcoming about his gambling records and that he firmly believed the former U.S. Supreme Court attorney knew what was in his allegedly false tax returns when they were filed.
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February 03, 2026
Tax Court Allows Some Credits For Co.'s Chicken Research
The owner of a poultry processing business is entitled to some of the tax credits he claimed for his company's chicken research, the U.S. Tax Court ruled Tuesday, disagreeing with the Internal Revenue Service's position that the work was routine and ineligible for a tax break.
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February 03, 2026
House Dems Press Bessent About IRS Retirement Pay Delays
Democrats on the House Ways and Means Committee demanded answers Tuesday about substantial delays in processing retirement applications for Internal Revenue Service employees who participated in the government's deferred resignation program.
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February 03, 2026
House Passes Funding Package With $11.2B IRS Budget
The House passed an appropriations package Tuesday that would fund several government departments and agencies, including the U.S. Department of the Treasury, and cut the Internal Revenue Service's annual budget to $11.2 billion.
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February 03, 2026
IRS Floats Clean Fuel Credit Rules With Foreign Restrictions
The Internal Revenue Service released long-awaited proposed regulations Tuesday clarifying how domestic transportation fuel producers can qualify for the clean energy fuel tax credit under changes made by Republicans' 2025 budget law, including new foreign restrictions on business owners and feedstock sources.
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February 03, 2026
Tax Court Bars Partners From $49M Easement Suit
A group of partners lost their chance to participate in a lawsuit challenging the IRS' rejection of their $49 million tax deduction for donating a conservation easement after their partnership brokered a settlement, the U.S. Tax Court said Tuesday.
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February 03, 2026
Virgin Islands Co. Wants Experts Barred In $11.5M Pricing Row
A U.S. Virgin Islands mortgage company challenging the territorial government over $11.5 million in tax bills asked a federal court Tuesday to exclude expert testimony meant to bolster the government's case that the company wrongly claimed a tax break meant to help the local economy.
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February 02, 2026
Ex-Goldstein Employee Claims Accountants Made Mistakes
Defense attorneys for SCOTUSblog founder Thomas Goldstein presented evidence Monday that his firm's tax accountants made serious mistakes in tax filings for Goldstein's wife, Amy Howe, in 2021.
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February 02, 2026
DC Leaders Warn Against Congress' Nix Of Tax Decoupling
Officials in Washington, D.C., reacted with alarm Monday to a pair of congressional joint resolutions that would repeal a district law that uncouples elements of the city's tax code from federal tax law, saying the repeal would be harmful and intrusive.
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February 02, 2026
Int'l Tax In January: Global Min. Reached, Trade Deals Abound
January was a busy month in international tax, starting with an agreement by nearly 150 countries on a global minimum tax that effectively exempts U.S. companies and culminating with trade deals between Canada and China as well as India and the European Union. Here, Law360 looks at the biggest developments in international tax over the last month.
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February 02, 2026
Trump, Modi Say US-India Trade Deal Reached
President Donald Trump said Monday he reached a trade deal with India following a call with Prime Minister Narendra Modi that includes lowering the tariff rate on Indian goods entering the U.S. from 50% to 18%.
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February 02, 2026
Spencer Fane Expands To New Orleans With Litigation Hire
Spencer Fane LLP announced that an experienced Louisiana-based attorney from Phelps Dunbar LLP has joined the firm's litigation and dispute resolution team as a partner, marking the fast-growing firm's initial foray into the New Orleans market.
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February 02, 2026
US Drops $185K FBAR Case Amid State Dept. Silence
The U.S. Department of Justice dropped its case Monday accusing a U.S. citizen living in Switzerland of hiding bank accounts from the IRS, telling a D.C. federal court that the U.S. Department of State fell silent on a request for help from Swiss authorities.
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February 02, 2026
OECD Amends Tax Treaty Manual To Up Dispute Resolution
The Organization for Economic Cooperation and Development is updating guidance for tax treaties to strengthen tax treaty mechanisms for preventing cross-border tax disputes, according to a statement Monday.
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February 02, 2026
Norton Rose Grows In Key Cities By Adding 5 Polsinelli Attys
Norton Rose Fulbright announced Monday that it has added five former Polsinelli PC shareholders as partners to grow its transactional and healthcare capabilities in two key U.S. markets.
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January 30, 2026
Senate Sends Package With $11.2B IRS Budget To House
The Senate passed an appropriations package Friday that would fund several government departments and agencies, including the U.S. Department of the Treasury, and provide the Internal Revenue Service with an $11.2 billion budget.
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January 30, 2026
The Tax Angle: Congressional Taxwriters Head For The Exits
This edition of The Tax Angle examines upcoming retirements among members of the Senate Finance and House Ways and Means committees ahead of the midterm elections this November.
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January 30, 2026
3 Things To Keep In Mind About IRS' Corporate Audit Changes
The IRS' revamped audit process for corporate taxpayers will likely streamline examinations, but companies may now shoulder new responsibilities when presenting facts and face lingering uncertainties when weighing whether to participate in a broadened settlement program. Here, Law360 examines three key issues for companies to consider under the new audit process.
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January 30, 2026
Ex-Fla. Rep. Says Prosecutor Has 'Personal Animus' In DQ Bid
A former Florida congressman and a lobbyist charged with failing to register as foreign agents for Venezuela urged a federal court to disqualify an assistant U.S. attorney in the case, saying Friday that the prosecutor has a conflict of interest and "personal animus" toward defense counsel.
Expert Analysis
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Reform Partly Modernizes Small Biz Stock Gains Exclusion
Changes to the Internal Revenue Code in the One Big Beautiful Bill Act update the qualified small business stock gains exclusion to reflect inflation, but the regime would be more in line with current business realities if Congress had also made the exemption available to additional business structures, says Mark Parthemer at Glenmede.
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How Real Estate Funds Can Leverage Del. Statutory Trusts
Over the last two years, traditional real estate fund sponsors have begun to more frequently adopt Delaware Statutory Trust programs, which can help diversify capital-raising strategies and access to new sources of capital, among other benefits, say attorneys at Polsinelli.
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DOJ Crypto Enforcement Is Shifting To Target Willfulness
Three pending criminal prosecutions could be an indication of how the U.S. Department of Justice's recent digital assets memo is shaping enforcement of the area, and show a growing focus on executives who knowingly allow their platforms to be used for criminal conduct involving sanctions offenses, say attorneys at Gibson Dunn.
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4 Former Justices Would Likely Frown On Litigation Funding
As courts increasingly confront cases involving hidden litigation finance contracts, the jurisprudence of four former U.S. Supreme Court justices establishes a constitutional framework that risks erosion by undisclosed financial interests, says Roland Eisenhuth at the American Property Casualty Insurance Association.
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Practical Implications Of SEC's New Crypto Staking Guidance
The U.S. Securities and Exchange Commission's recent staff guidance that protocol staking does not constitute securities offerings provides a workable compliance blueprint for crypto developers, validators and custodial platforms willing to keep staking strictly limited to protocol-driven rewards, say attorneys at Cahill.
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How Attys Can Use AI To Surface Narratives In E-Discovery
E-discovery has reached a turning point where document review is no longer just about procedural tasks like identifying relevance and redacting privilege — rather, generative artificial intelligence tools now allow attorneys to draw connections, extract meaning and tell a coherent story, says Rose Jones at Hilgers Graben.
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AbbVie Frees Taxpayers From M&A Capital Loss Limitations
The U.S. Tax Court’s June 17 opinion in AbbVie v. Commissioner, finding that a $1.6 billion break fee was an ordinary and necessary business expense, marks a pivotal rejection of the Internal Revenue Service’s position on the tax treatment of termination fees related to failed mergers or acquisitions, say attorneys at Holland & Knight.
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ABA Opinion Makes It A Bit Easier To Drop A 'Hot Potato'
The American Bar Association's recent ethics opinion clarifies when attorneys may terminate clients without good cause, though courts may still disqualify a lawyer who drops a client like a hot potato, so sending a closeout letter is always a best practice, say attorneys at Thompson Hine.
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Federal Construction Considerations Amid Policy Overhaul
The rapid overhaul of federal procurement, heightened domestic sourcing rules and aggressive immigration enforcement are reshaping U.S. construction, but several pragmatic considerations can help federal contractors engaged in infrastructure and public construction avoid the legal, financial and operational fallout, say attorneys at Cozen O'Connor.
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Can Companies Add Tariffs Back To Earnings Calculations?
With the recent and continually evolving tariffs announced by the Trump administration, John Ryan at King & Spalding takes a detailed look at whether those new tariffs can be added back in calculating earnings before interest, taxes, depreciation and amortization — an important question that may greatly affect a company's compliance with its financial covenants.
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A Look At DOJ's Dropped Case Against Early Crypto Operator
The prosecution of an early crypto exchange operator over alleged unlicensed money transmission was recently dropped in Indiana federal court, showcasing that the U.S. Justice Department may be limiting the types of enforcement cases it will bring against digital asset firms, say attorneys at Greenberg Traurig.
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8 Ways Lawyers Can Protect The Rule Of Law In Their Work
Whether they are concerned with judicial independence, regulatory predictability or client confidence, lawyers can take specific meaningful actions on their own when traditional structures are too slow or too compromised to respond, says Angeli Patel at the Berkeley Center of Law and Business.
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Despite Dark Clouds, Outlook For US Solar Has Bright Spots
While tariff, tax policy and bankruptcy news seemingly portends unending challenges for the U.S. solar energy industry, signs of continued growth in solar generating capacity and domestic solar manufacturing suggest that there is a path forward, say attorneys at Beveridge & Diamond.