Federal
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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.
-
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."
-
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.
-
March 20, 2026
Paris Firm Adds Longtime Transfer Pricing Expert
De Gaulle Fleurance, a Paris firm specializing in business law, has boosted its international tax department with the addition of a longtime expert in transfer pricing.
-
March 20, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included the proposed revocation of partnership basis-shifting regulations that were meant to curb income tax abuse but have been criticized as burdening businesses.
-
March 19, 2026
IRS Seeks To Save Increased Penalties In $43M Easement Row
The owner of a Kentucky historic property should be subject to additional penalties for improperly deducting $1.6 million in expenses associated with a $43 million tax break claim for a preservation easement that the IRS rejected for accuracy reasons, the agency told the U.S. Tax Court.
-
March 19, 2026
Meta Says IRS Defying Settled Facts In $16B Tax Fight
The IRS is refusing to agree to the truth of parts of the trial transcript and the U.S. Tax Court's opinion last year in a Facebook transfer pricing case as the social media platform's parent, Meta, disputes a $16 billion tax bill in a related case, the company told the court.
-
March 19, 2026
Partnership Can't Assert Due Process Right, Tax Court Rules
A partnership cannot assert Fifth Amendment due process claims on behalf of its individual members to challenge the Internal Revenue Service's centralized audit regime under the Bipartisan Budget Act, the U.S. Tax Court ruled Thursday.
-
March 19, 2026
IRS Broadens Exception For Unmarked Vehicles
Unmarked vehicles used by firefighters, members of a rescue squad or ambulance crew would be considered a new type of qualified nonpersonal-use vehicle that is exempted from substantiation requirements under regulations finalized by the Internal Revenue Service on Thursday.
Expert Analysis
-
Supreme Court Term Limits Would Carry Hidden Risk
While proposals for limiting the terms of U.S. Supreme Court justices are popular, a steady stream of relatively young, highly marketable ex-justices with unique knowledge and influence entering the marketplace of law and politics could create new problems, say Michael Broyde at Emory University and Hayden Hall at the U.S. Bankruptcy Court for the District of Delaware.
-
Tariffs And Trade Volatility Drove 2025 Bankruptcy Wave
The Trump administration's tariff regime has reshaped the commercial restructuring landscape this year, with an increased number of bankruptcy filings showing how tariffs are influencing first‑day narratives, debtor-in-possession terms and case strategies, say attorneys at Thompson Hine.
-
AI Evidence Rule Tweaks Encourage Judicial Guardrails
Recent additions to a committee note on proposed Rule of Evidence 707 — governing evidence generated by artificial intelligence — seek to mitigate potential dangers that may arise once machine outputs are introduced at trial, encouraging judges to perform critical gatekeeping functions, say attorneys at Lankler Siffert & Wohl.
-
The Law Firm Merger Diaries: Getting The Message Across
Communications and brand strategy during a law firm merger represent a crucial thread that runs through every stage of a combination and should include clear messaging, leverage modern marketing tools and embrace the chance to evolve, says Ashley Horne at Womble Bond.
-
Horizontal Stare Decisis Should Not Be Casually Discarded
Eliminating the so-called law of the circuit doctrine — as recently proposed by a Fifth Circuit judge, echoing Justice Neil Gorsuch’s concurrence in Loper Bright — would undermine public confidence in the judiciary’s independence and create costly uncertainty for litigants, says Lawrence Bluestone at Genova Burns.
-
10 Commandments For Agentic AI Tools In The Legal Industry
Though agentic artificial intelligence has demonstrated significant promise for optimizing legal work, it presents numerous risks, so specific ethical obligations should be built into the knowledge base of every agentic AI tool used in the legal industry, says Steven Cordero at Akerman LLP.
-
A Close Look At The Evolving Interval Fund Space
Interval funds — closed-end registered investment companies that make periodic repurchase offers — have recently moved to the center of the conversation about retail access to private markets, spurred along by President Donald Trump's August executive order incorporating alternative assets into 401(k) plans and target date strategies, say attorneys at Simpson Thacher.
-
The Law Firm Merger Diaries: How To Build On Cultural Fit
Law firm mergers should start with people, then move to strategy: A two-level screening that puts finding a cultural fit at the pinnacle of the process can unearth shared values that are instrumental to deciding to move forward with a combination, says Matthew Madsen at Harrison.
-
Rare Tariff Authority May Boost US Battery Manufacturing
Finalizing preliminary tariffs on active anode material from China — the result of a rare exercise of statutory authority finding that foreign dumping hampered the development of a nascent U.S. industry — should help domestic battery manufacturing, but potential price increases could discourage related clean-energy use, say attorneys at MoloLamken.
-
Considerations When Invoking The Common-Interest Privilege
To successfully leverage the common-interest doctrine in a multiparty transaction or complex litigation, practitioners should be able to demonstrate that the parties intended for it to apply, that an underlying privilege like attorney-client has attached, and guard against disclosures that could waive privilege and defeat its purpose, say attorneys at DLA Piper.
-
The Law Firm Merger Diaries: Making The Case To Combine
When making the decision to merge, law firm leaders must factor in strategic alignment, cultural compatibility and leadership commitment in order to build a compelling case for combining firms to achieve shared goals and long-term success, says Kevin McLaughlin at UB Greensfelder.
-
What To Watch As NY LLC Transparency Act Is Stuck In Limbo
Just about a month before it's set to take effect, the status of the New York LLC Transparency Act remains murky because of a pending amendment and the lack of recent regulatory attention in New York, but business owners should at least prepare for the possibility of having to comply, says Jonathan Wilson at Buchalter.
-
Despite Deputy AG Remarks, DOJ Can't Sideline DC Bar
Deputy Attorney General Todd Blanche’s recent suggestion that the D.C. Bar would be prevented from reviewing misconduct complaints about U.S. Department of Justice attorneys runs contrary to federal statutes, local rules and decades of case law, and sends the troubling message that federal prosecutors are subject to different rules, say attorneys at HWG.