Federal
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November 02, 2026
Eaton Atty Says Island Plants' Activities Critical To Success
The skilled manufacturing that took place at Eaton's plants in Puerto Rico and the Dominican Republic from 2011 through 2013 was the critical factor in the success of the company's electrical breaker products business, an attorney for Eaton Corp. told the U.S. Tax Court on Monday.
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November 02, 2026
Buy.com Founder On Hook For $16M Tax Bill, 10th Circ. Says
The founder of Buy.com waited too long to challenge a nearly $16 million tax bill tied to his former partnership's investments, the Tenth Circuit ruled Monday, holding that the window had closed by the time the IRS assessed partner-level liabilities.
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November 02, 2026
Tax Court Denies IRS Bid To Revisit Easement Case Ruling
The U.S. Tax Court said Monday it won't reconsider a September opinion finding a partnership's petition was filed late because of circumstances beyond its control, saying the court has already addressed the IRS' arguments that it improperly excused the lateness of the conservation easement suit.
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November 02, 2026
IRS Donor Reporting Rule Violates 1st Amendment, Court Told
The IRS' nonprofit donor disclosure rule violates organizations' and donors' First Amendment rights, a privacy group told a D.C. federal court, saying the rule is subject to a heightened level of judicial scrutiny that the government cannot overcome.
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November 02, 2026
MVP: Gibson Dunn's Michael Cannon
Michael Cannon, a partner in Gibson Dunn & Crutcher LLP's Dallas office, co-led the tax team advising SpaceX on its pivotal transactions that wrapped up this year, including the largest initial public offering and M&A of all time, earning him a spot as one of the 2026 Law360 Tax MVPs.
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November 02, 2026
Full 5th Circ. Won't Review Limited Partner Tax Ruling
The Fifth Circuit denied a Texas business consulting company's request for the full court to review a panel's revised opinion narrowing a tax break for limited partners, saying no judges sought a rehearing.
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November 02, 2026
Tax Policy To Watch After The Midterm Elections
When lawmakers return to Washington, D.C., after the midterm elections, proposals to overhaul the Internal Revenue Service's administration could be ripe for inclusion in a year-end package if the goal is to clear the decks before the next legislative session, according to tax policy observers. Here, Law360 takes a look.
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October 30, 2026
Law360 MVP Awards Go To Top Attorneys From 89 Firms
The lawyers chosen as Law360's 2026 MVPs stand out from their peers by notching significant achievements in high-stakes litigation, complex global matters and record-setting transactions.
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October 30, 2026
Key Witness May Be Out In MLB Prop Betting Trial
A Brooklyn federal judge Friday heard that prosecutors may not call a key witness at the center of a fight over exculpatory evidence disclosure to testify against two Cleveland Guardians players accused of a pitch-fixing conspiracy to profit from rigged proposition bets, and refused a government bid to use a purported $500,000 tax debt against one of the pitchers.
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October 30, 2026
Jury Rules Tax Software Co. Didn't Illegally Poach Workers
Tax software company Avalara did not illegally lure six workers away from a company acquired by rival Vertex, a Pennsylvania federal jury decided, clearing Avalara of trade secrets theft.
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October 30, 2026
Hedge Fund Exec Fights $40M In IRS Foreign Reporting Fines
A hedge fund manager is seeking to recover nearly $40 million in foreign account reporting penalties, telling the U.S. Court of Federal Claims that the IRS violated his due process rights and administrative rules in imposing fines linked to his bankrupt Texas tycoon father's international accounts.
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October 30, 2026
Racing Mogul's Estate Asks Tax Court To Ax $58M Tax Bill
An automobile racing mogul's estate asked the Tax Court to spike a $58.3 million estate tax deficiency, alleging that the IRS erred in revaluing its equity holdings.
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October 30, 2026
Brookfield Fights $4.3M Tax Bill Over Lehman Losses
Asset management giant Brookfield is challenging a $4.3 million tax bill tied to its acquisition of a defunct Lehman Brothers unit, telling the U.S. Tax Court that the IRS incorrectly denied a deduction stemming from the Lehman affiliate's losses.
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October 30, 2026
Int'l Tax In October: UK Targets Banks, US Nixes Spinoff Rule
The U.K. government issued its first budget under a new prime minister in October and is looking to the banking industry to boost revenue, while in the U.S., a dispute over a Minnesota medical device company's pricing with a Puerto Rican affiliate could require a third Tax Court trial after settlement talks failed. Here, Law360 looks at the top international tax developments from the past month.
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October 30, 2026
Buchalter Adds Tax Pro In Dallas From Jackson Walker
Buchalter PC's rapid growth in Texas continues with the addition of a Dallas-based tax partner who came aboard from Jackson Walker LLP.
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October 30, 2026
3 Ways Burgeoning AI Use Can Trip Up Benefits Providers
As the use of artificial intelligence in the employee benefits space grows, experts warn that companies need to be vigilant to guard against mishaps caused by the emerging technology. Here, Law360 looks at three areas where benefits attorneys say AI can cause legal headaches.
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October 30, 2026
Taxation With Representation: Kirkland, Gibson Dunn, Cravath
In this week's Taxation with Representation, Blackstone, Bank of America, Citi and Morgan Stanley announce a financing structure to buy Broadcom artificial intelligence chips and network components for Anthropic, EQT acquires Range Resources to create a powerhouse natural gas company, and DoorDash buys Instacart.
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October 30, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, contained final rules laying out the process for arbitrating out-of-network medical bills under the No Surprises Act.
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October 29, 2026
Union Sues IRS Over Termination Of Workers' Contract
The Internal Revenue Service violated federal law by terminating its collective bargaining agreement with a union representing the agency's employees in light of a 2025 executive order from President Donald Trump, the union has claimed in a lawsuit filed in Massachusetts federal court.
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October 29, 2026
Treasury Asked To Narrow Crackdown On Fund Strategies
The U.S. Treasury Department should develop targeted rules distinguishing abusive transactions from long-standing investment management practices in new enforcement that scrutinizes novel strategies exploiting the tax benefits of certain investment vehicles and financial products, firms and organizations told the department.
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October 29, 2026
German Co. Says $1.2M IRS Tax Bill Rests On Invalid Rule
A German manufacturer challenging a $1.2 million tax bill stemming from late information filings with the IRS told the U.S. Tax Court it should be able to claim deductions and credits despite missing the statutory due date, saying the agency applied a rule that is procedurally invalid under federal law.
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October 29, 2026
Club's Oil Profits Negated Tax-Exempt Status, Tax Court Finds
A Pennsylvania sports club deserved to have its nonprofit status revoked because the royalties it received from its leasing arrangement with an oil drilling company from 2017-2023 made up more than half its annual income, the U.S. Tax Court held Thursday.
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October 29, 2026
Tax Court Backs IRS In Whistleblower Award Denial
The Internal Revenue Service's Whistleblower Office did not abuse its discretion when it determined that a man who tried to request an award for whistleblowing on tax abuse undertaken by Target was not entitled to it, the U.S. Tax Court said in an opinion released Thursday.
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October 29, 2026
US Expatriations In Q3 Down 16% From Last Year, IRS Says
The number of people who lost or renounced their U.S. citizenship totaled more than 1,300 in the third quarter of 2026 as logged by the U.S. Department of the Treasury, down about 16% year over year and 25% from the previous quarter, the IRS said Thursday.
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October 29, 2026
Tax Consultancy Asks 5th Circ. To Kill Microcaptive Rule
The IRS never published data showing that microcaptive transactions pose a potential for tax avoidance to justify a rule making companies and advisers report them as "transactions of interest," a tax consultancy seeking the rule's demise told the Fifth Circuit.
Expert Analysis
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Planning For The Impact Of FinCEN's CTA Rollback
The Financial Crimes Enforcement Network's recent rollback of Corporate Transparency Act reporting obligations should reduce compliance costs, but its plans to revisit customer due diligence rules should prompt companies and financial institutions to reassess state beneficial ownership programs, say attorneys at Sidley.
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What DOJ Fraud Division Rule Resolves, And What It Doesn't
The U.S. Department of Justice’s recently published final rule answers many outstanding questions about the newly created National Fraud Enforcement Division, but overlapping mandates could result in parallel investigations and diverging viewpoints between multiple sets of prosecutors, say attorneys at Gibson Dunn.
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ERC Filing Deadlines Raise Tax Adviser Liability Risk
To minimize their risk, employee retention credit providers and tax advisers should understand that agreements to extend clients’ two-year deadline for challenging disallowances are not effective until the IRS countersigns, and implement an action plan to track filing deadlines and consider other proactive steps, says Michael Williams at CFOMW.
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Taekwondo Makes Me A Better Lawyer
Taekwondo has taught me to recognize when to fight for a position and when to focus on finding a solution, and that the best outcomes are often achieved by solving problems — all of which has improved my work as a bankruptcy lawyer, mediator and Subchapter V trustee, says Amy Denton Mayer at Berger Singerman.
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Where DOJ's Fraud Priorities Memo May Actually Matter
The U.S. Department of Justice’s recently released memo outlining priorities for its newly created fraud division will shape how cases are identified, staffed and sequenced, meaning white collar defense work must begin earlier, say David Tarras at Tarras Defense and Trevor Jones at Dynamis.
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Monitor Exposure, Stay Flexible Amid Tariff Uncertainty
To navigate an unstable trade environment, businesses must evaluate their exposure to new tariffs invoked under a patchwork of statutory authorities and be prepared to adapt to further changes that may be on the horizon, says Bhargav Prajapati at Capital Trade.
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Being In A Band Made Me A Better Lawyer
Playing shows in storied New York City venues and rehearsing with my bandmates in poorly ventilated rooms helped develop the professional qualities I rely on as a litigator, including an ability to collaborate with strong-minded equals and the determination to treat each client with singular focus, says Eliad Shapiro at Herrick Feinstein.
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The Divergent Approaches In US, EU Forced Labor Standards
Forced labor guidance documents recently issued by the U.S. and the European Union have meaningful differences, with the U.S. taking a documentary approach to compliance and the EU emphasizing human rights risks as a governance challenge, but one model will likely exert greater influence, say attorneys at Steptoe.
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Going To Hardcore Shows Makes Me A Better Lawyer
While government contracts law and the hardcore scene may seem entirely unrelated, in my experience, both are about community, focus, being prepared for the unexpected and managing chaos, says Isaac Natter at Fluet.
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Handling Section 301 Tariffs When CBP Detains Goods
Importers subject to Section 301 tariffs on goods under a U.S. Customs and Border Protection forced labor hold should consider three approaches when deciding whether to pay tariffs on goods that may ultimately be excluded, or wait and watch port demurrage compound daily, says James Ferry at Ferry Trade.
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Justices' FTC Ruling Weakens Qui Tam's Constitutional Base
The U.S. Supreme Court’s holding in Trump v. Slaughter, expanding presidential control over those exercising executive power, suggests that courts may be receptive to arguments challenging the constitutional foundations of the False Claims Act’s qui tam mechanism, says Daniel Passeser at Wiggin.
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5 Financial Statement Fraud Red Flags To Spot Post-Sripetch
The U.S. Supreme Court recently held in Sripetch v. U.S. Securities and Exchange Commission that disgorgement exists to strip a wrongdoer of unjust enrichment, not merely to compensate victims for what they lost, shifting the work at the center of securities fraud cases in five ways, says Rand Manasse at Green Lane Partners.
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Assessing The Benefits Of Fla.'s Newest Business Structure
As of July 1, Florida business owners can create protected series LLCs to shield assets from liability while avoiding increased costs and wasted time, but burdensome recordkeeping obligations are crucial to maintaining the very protection that makes them attractive in the first place, says Gregory Ritter at Moritt Hock.