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April 24, 2026
One Certainty As Tariff Refunds Start: 'There Will Be Litigation'
The launch of the refund process for tariffs struck down by the U.S. Supreme Court marks the start of lengthy and multifaceted court battles as companies fight with consumers — and amongst themselves — about who gets a slice of the $166 billion pie, experts told Law360.
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April 24, 2026
Insurer Says IRS Botched Tax Liability Adjustments
The IRS incorrectly determined that an insurance company had a nearly $447,000 tax deficiency after adjusting its net written premiums, the company told the U.S. Tax Court, asking the court to determine that it isn't liable for any deficiency, penalty or underpayment interest charges.
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April 24, 2026
IRS Taxpayer Advocacy Panel Recommends Clearer Notices
The Internal Revenue Service should make taxpayer notices clear, streamline correspondence processes, reduce call wait times and enhance online tools and digital services, the Internal Revenue Service's Taxpayer Advocacy Panel recommended in its annual report Friday.
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April 24, 2026
Grocers' Microcaptive Tax Breaks Wrongly Axed, 7th Circ. Told
Chicagoland grocery chain owners asked the Seventh Circuit to restore the tax benefits tied to their business' microcaptive insurance, arguing that the U.S. Tax Court's decision to disallow those deductions violated a 1945 federal law authorizing state regulation of insurers.
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April 24, 2026
Taxation With Representation: Gibson Dunn, Paul Weiss
In this week's Taxation With Representation, Elon Musk's SpaceX strikes a deal with Cursor that could lead to an acquisition of the artificial intelligence startup, building products distributor QXO Inc. buys TopBuild Corp., and Eli Lilly & Co. acquires clinical-stage biotechnology company Kelonia Therapeutics.
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April 24, 2026
Trump Makes Fresh US Tariff Threat Over UK Digital Tax
President Donald Trump warned that his administration will impose new tariffs on the U.K. unless the British government dismantles its digital services tax targeting tech giants.
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April 24, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included the list of the dozens of occupations that qualify for the no-tax-on-tips provision passed in summer 2025, clarifying what counts as a tip and who can take the deduction.
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April 24, 2026
Barnes & Thornburg Lands 6 Bradley Arant Attys In Southeast
Barnes & Thornburg LLP announced Thursday that the firm has hired six attorneys from Bradley Arant Boult Cummings LLP for its Atlanta and Palm Beach Gardens, Florida, offices, increasing its capabilities in the tax and insurance recovery practice groups.
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April 23, 2026
BofA, EY Strike $2.5M Deal To Settle MOVEit Breach Claims
Bank of America and EY have agreed to pay $2.5 million to nearly 200,000 people to settle claims in multidistrict litigation over the May 2023 breach of file transfer application MOVEit, according to a motion for settlement.
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April 23, 2026
Pair Accused Of Scheming To Dodge $2.5M IRS Tax Debt
A Connecticut grand jury has charged an in-state businessman allegedly $2.5 million in debt to the Internal Revenue Service and a North Carolina man with engineering a series of financial transactions to keep tax authorities from collecting the debt, according to federal prosecutors.
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April 23, 2026
IRS' $15M Valuation Of Estate An Issue For Trial
The IRS' failure to provide a statement explaining its $15.1 million valuation of an estate doesn't require that the valuation and resulting deficiency assessment should be thrown out, the U.S. Tax Court held Thursday, saying the issue is one for trial.
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April 23, 2026
IRS Plans To Update Tax-Exempt Org Reporting Form
The Internal Revenue Service will revise its form for tax-exempt organizations to report information under an initiative announced by the U.S. Department of the Treasury on Thursday.
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April 23, 2026
Lender's COVID Boom Bars $5M Worker Credit Claim, US Says
A mortgage lender isn't entitled to a $5 million refund for denied COVID-19 worker tax credits because the company's true business was never halted by a government order, the U.S. government told a California federal court, noting that the company's revenue actually increased by 600%.
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April 23, 2026
AI Missteps Could Prompt Tax Court To Adopt Misuse Rules
As the U.S. Tax Court continues to encounter false information generated by artificial intelligence, practitioners are urging the court to set some guidance to curb misuse of the technology and reduce the burden on judicial reviewers to catch those errors.
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April 23, 2026
IRS Defends Ranch's Easement Deduction Disallowance
The Internal Revenue Service properly disallowed a partnership's nearly $26 million charitable deduction for a donated easement on a 110-acre pasture, the agency told the Eleventh Circuit, urging it to affirm the lower court's decision.
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April 23, 2026
Plastics Heirs Settle $50M Estate Tax Suit
The family of the late owner of a plastics company settled a dispute with the U.S. Department of Justice over more than $50 million in estate taxes the agency alleged went unpaid, a Connecticut federal court announced Thursday.
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April 23, 2026
DOJ Final Order Loosens Rules For State-Legal Medical Pot
The U.S. Department of Justice published a final order Thursday loosening federal restrictions on medical marijuana products that fall within the ambit of state-regulated programs or have approval from the U.S. Food and Drug Administration.
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April 22, 2026
House Appropriations Committee OKs $1B IRS Funding Cut
The House Appropriations Committee passed legislation Wednesday that would cut the Internal Revenue Service's funding by $1 billion for the 2027 fiscal year.
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April 22, 2026
7th Circ. Revives $300M Hyatt Rewards Tax Dispute
The U.S. Tax Court relied on an incomplete analysis when it sided with the IRS and held that nearly $300 million in revenue from Hyatt Hotels' loyalty rewards program fund should be treated as taxable income, the Seventh Circuit held Wednesday.
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April 22, 2026
Temp Agency Owner's Tax Convictions Upheld By 1st Circ.
The First Circuit on Wednesday affirmed the convictions of a Quincy, Massachusetts, temp agency owner who prosecutors said evaded more than $800,000 in payroll taxes by paying employees under the table.
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April 22, 2026
Spinoff Landscape Unclear In Wake Of Tossed IRS Guidance
The Internal Revenue Service has scrapped controversial guidance that limited the types of spinoff transactions that revenue officials would approve as tax-free ahead of time, but the path to seeking the agency's blessing for certain intercompany reorganizations remains hazy.
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April 22, 2026
Split 6th Circ. Lets Brewer Challenge Tax Code's Distilling Ban
An Ohio brewery owner has standing to challenge the constitutionality of the federal tax code's ban on distilling whiskey at home, but the ban is necessary for the government to collect taxes on distilled spirits, a split Sixth Circuit panel ruled.
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April 22, 2026
Tax Court Denies Boutique Owner's Biz, Rental Deductions
A Missouri boutique owner offered limited support to claim business and rental property expense deductions in her 2017 and 2019 returns, the U.S. Tax Court ruled Wednesday, siding with the IRS that she underreported her taxable income.
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April 22, 2026
Nintendo Customers Jump In On Tariff Refund Suits
Video game giant Nintendo stands to make "windfall profits" through refunds of President Donald Trump's now-invalidated global tariff regime since those costs were actually passed on to consumers, a proposed class action in Washington federal court said, joining the chorus of customers looking to secure tariff-related refunds.
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April 22, 2026
$1.4B Budget Cut Wouldn't Hinder IRS Update, Bessent Says
Treasury Secretary Scott Bessent told Senate lawmakers Wednesday that a $1.4 billion cut in the Internal Revenue Service's budget next year would still allow the agency to modernize its technology and provide better digital customer service to taxpayers.
Expert Analysis
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4 Ways GCs Can Manage Growing Service Of Process Volume
As automation and arbitration increase the volume of legal filings, in-house counsel must build scalable service of process systems that strengthen corporate governance and manage risk in real time, says Paul Mathews at Corporation Service Co.
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The Law Firm Merger Diaries: Forming Measurable Ties
Relationship-building should begin as early as possible in a law firm merger, as intentional pathways to bringing people together drive collaboration, positive client response, engagements and growth, says Amie Colby at Troutman.
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3 Key Takeaways From Planned Rescheduling Of Cannabis
An executive order reviving cannabis rescheduling represents a monumental change for the industry and, while the substance will remain illegal at the federal level, introduces several benefits, including improving state-legal cannabis operators' tax treatment, lowering the industry's legal risk profile, and leaving state-regulated markets largely intact, say attorneys at Dentons.
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OFAC Sanctions Will Intensify Amid Global Tensions In 2026
The Office of Foreign Assets Control will ramp up its targeting of companies in the private equity, venture capital, real estate and legal markets in 2026, in keeping with the aggressive foreign policy approach embraced by the Trump administration in 2025, say attorneys at Holland & Knight.
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5 E-Discovery Predictions For 2026 And Beyond
2026 will likely be shaped by issues ranging from artificial intelligence regulatory turbulence to potential evidence rule changes, and e-discovery professionals will need to understand how to effectively guide the responsible and defensible adoption of emerging tools, while also ensuring effective safeguards, say attorneys at Littler.
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Judges On AI: How Courts Can Boost Access To Justice
Arizona Court of Appeals Judge Samuel A. Thumma writes that generative artificial intelligence tools offer a profound opportunity to enhance access to justice and engender public confidence in courts’ use of technology, and judges can seize this opportunity in five key ways.
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Examining Privilege In Dual-Purpose Workplace Investigations
The Sixth Circuit's recent holding in FirstEnergy's bribery probe ruling that attorney-client privilege applied to a dual-purpose workplace investigation because its primary purpose was obtaining legal advice highlights the uncertainty companies face as federal circuit courts remain split on the appropriate test, say attorneys at Proskauer.
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Hot Topics For Family Offices In 2026
For family offices, the throughline of 2026 is disciplined readiness, as navigating impact from the One Big Beautiful Bill Act and platform maturation will be necessary to preserve flexibility and enhance client outcomes, say attorneys at Morgan Lewis.
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The Case For Emulating, Not Dividing, The Ninth Circuit
Champions for improved judicial administration should reject the unfounded criticisms driving recent Senate proposals to divide the Ninth Circuit and instead seek to replicate the court's unique strengths and successes, says Ninth Circuit Judge J. Clifford Wallace.
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How Changes At The IRS Will Affect Tax Controversy In 2026
Taxpayers will need to adjust approaches to dealing with the IRS in 2026, as the agency is likely to shift its audit strategies and increases reliance on technology following the significant reductions in funding and personnel last year, say attorneys at Crowell & Moring.
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5 Tariff And Trade Developments To Watch In 2026
A new trade landscape emerged in 2025, the contours of which will be further defined by developments that will merit close attention this year, including a key ruling from the U.S. Supreme Court and a review of the U.S.-Mexico-Canada Agreement, says Ted Posner at Baker Botts.
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4 Developments That Defined The 2025 Ethics Landscape
The legal profession spent 2025 at the edge of its ethical comfort zone as courts, firms and regulators confronted how fast-moving technologies and new business models collide with long-standing professional duties, signaling that the profession is entering a period of sustained disruption that will continue into 2026, says Hilary Gerzhoy at HWG Law.
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How Fractional GCs Can Manage Risks Of Engagement
As more organizations eliminate their in-house legal departments in favor of outsourcing legal work, fractional general counsel roles offer practitioners an engaging and flexible way to practice at a high level, but they can also present legal, ethical and operational risks that must be proactively managed, say attorneys at Boies Schiller.