Federal

  • October 02, 2026

    Int'l Tax In September: Facebook Ruling, BEAT Bill And More

    September kicked off with the announcement of tariffs on semiconductors and ended with the U.S. Tax Court's long-awaited ruling on a computational dispute involving Facebook, with Siemens USA's trial and a bill that would change the U.S. base erosion and anti-abuse tax in the middle. Here, Law360 looks at some of the biggest international tax developments of the past month.

  • October 02, 2026

    DOJ Can't Reverse IRS Curtailing Of $2.4M Penalty, Court Says

    The Department of Justice lacked the authority to reverse the IRS' abatement of a man's penalty of nearly $2.4 million for promoting abusive tax shelters after the agency realized a supervisor hadn't signed off on it, an Illinois federal court said.

  • October 02, 2026

    Dems Slam Proposed Limit On Tax Credits For Immigrants

    A group of Democratic senators urged the U.S. Department of the Treasury to scrap proposed rules that would cut off refundable tax credits to certain immigrants living in the U.S. legally, arguing that the guidance oversteps regulatory authority and would create a "byzantine" system.

  • October 02, 2026

    2nd Circ. Forges Own Path In Limited Partner Tax Ruling

    The Second Circuit's decision limiting a self-employment tax break for limited partners with significant managerial roles reached a conclusion similar to that of a recent Fifth Circuit ruling, but practitioners said notable differences between them create a split requiring resolution by the IRS, the U.S. Supreme Court or Congress.

  • October 02, 2026

    Former Fla. Rep. Gets 10 Years In Venezuela FARA Case

    A Florida federal judge on Friday sentenced ex-Florida Rep. David Rivera to 10 years in prison for failing to register as a foreign agent and laundering the proceeds of a $50 million contract with a unit of Venezuela's state-owned oil company.

  • October 02, 2026

    Taxation With Representation: Hogan Lovells, Davies, Sidley

    In this week's Taxation With Representation, semiconductor company Advanced Micro Devices buys AI model developer and research lab World Labs, Brixmor Property Group and private investment management firm Everview Partners acquire Slate Grocery REIT, and cyberintelligence company REDLattice merges with blank check company Bold Eagle Acquisition Corp.

  • October 02, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, included the release of emissions rates used to calculate the tax credit amount for the domestic production of less-carbon-intensive transportation fuel.

  • October 01, 2026

    Tax Court OKs Denial Of Whistleblower Award For Bond Info

    The IRS properly denied a whistleblower's award claim for reporting a nonprofit correctional corporation that he said failed to meet its tax obligations related to bonds it issued, the U.S. Tax Court ruled, saying the agency didn't collect proceeds from an investigation into the matter.

  • October 01, 2026

    IRS Proposes Scholarship Contribution Tax Credit Rules

    The IRS proposed rules for the new federal tax credit for contributions to scholarship-granting organizations ahead of its planned launch at the start of 2027, including definitions of certain terminology and reporting requirements.

  • October 01, 2026

    Walmart Hit With New Tariff Suit As Refund Blitz Continues

    Walmart must compensate customers who "bore the economic burden" of Trump administration tariffs before the U.S. Supreme Court struck them down in February, according to a proposed class action in Connecticut federal court that claims the retail behemoth has no plans to share its $2.9 billion refund.

  • October 01, 2026

    Md. Cancer Research Lab Says $4.5M Tax Bill Unconstitutional

    A Maryland cancer research laboratory that said it had no income in 2021 is contesting IRS tax assessments totaling $4.5 million, telling the U.S. Tax Court that the government's imputing of an underpayment violates the U.S. Constitution.

  • October 01, 2026

    NY Judge Gives Tax Preparers Initial OK For $1M OT Deal

    A New York federal magistrate judge gave an initial green light to a $1.05 million class settlement to resolve claims brought by tax preparers who accused a New York tax preparation company of overtime and wage violations, finding the proposed agreement has no obvious deficiencies.

  • October 01, 2026

    Treasury Enrolls 60M Children In Trump Accounts

    The U.S. Department of the Treasury has completed automatic enrollment for tax-advantaged brokerage accounts for children, known as Trump Accounts, enrolling more than 60 million American children in the program, the department announced Thursday.

  • October 01, 2026

    DOJ Outlines New Corporate Fraud Enforcement Priorities

    Federal prosecutors "must place great weight" on a new list of factors when considering potential charges in corporate fraud cases, including whether the matters involve government programs, threats to national security or immigration offenses, according to a memo released Thursday by the U.S. Department of Justice.

  • September 30, 2026

    3rd Circ. Probes Payment Recipients In Fund's $100M Tax Row

    A Third Circuit panel examined dealer-and-customer relations under accounting rules governing their transactions on Wednesday to determine whether the Internal Revenue Service was right to slap a $100 million tax bill against a Cayman Islands hedge fund for payments tied to U.S. portfolio companies.

  • September 30, 2026

    Senate Approves IRS Taxpayer Service Revamp

    The Senate passed a wide-ranging bipartisan package Wednesday that would implement a slew of changes intended to improve taxpayer service, including a mandate that the agency digitize more tax returns and other correspondence.

  • September 30, 2026

    Tax Court Says Pair Can't Nullify Deadline Extension

    The Internal Revenue Service timely sent notices regarding federal income tax deficiencies and accuracy-related penalties to a pair of Florida residents who challenged the agency's determinations, the U.S. Tax Court said Wednesday, rejecting the taxpayers' bid to void an agreement that extended the time for assessment.

  • September 30, 2026

    Landowners Seek 11th Circ. Redo On Easement Value Cut

    Three Georgia conservation easement donors asked the full Eleventh Circuit to review a panel's split decision to slash the value of an easement they donated from $18 million to $1 million, saying the decision failed to take into account the property's highest and best use.

  • September 30, 2026

    Brothers Cop To Tax Crimes From Golf Side Hustle

    Twin brothers pled guilty to failing to report $1.3 million in income to the Internal Revenue Service, including money made from a golf tee-time brokering business they ran as a side hustle, California federal prosecutors said.

  • September 30, 2026

    IRS Grants Relief To Taxpayers In Israel, West Bank, Gaza

    Individuals and businesses in Israel, the West Bank and Gaza have additional time to file U.S. tax returns, make payments and perform other time-sensitive actions, the Internal Revenue Service said Wednesday.

  • September 30, 2026

    Polish Digital Tax Would Burden US Business, NFTC Says

    The National Foreign Trade Council urged the Polish government to pause discussions about a proposed digital services tax, contending the measure would challenge international tax principles by disproportionately targeting U.S. companies.

  • September 30, 2026

    IRS Lists Budget Bill Guidance Among Top Priorities

    Regulations to continue implementing the 2025 budget reconciliation bill are among the key items the Internal Revenue Service listed as priorities for the next 12 months, including guidance that would address changes to the base erosion and anti-abuse tax.

  • September 30, 2026

    Bessent Owes $910K In Taxes As Limited Partner, Wyden Says

    Treasury Secretary Scott Bessent should pay more than $910,000 in payroll taxes as a hedge fund limited partner after the Second Circuit ruled that such partners are subject to the self-employment tax, Senate Finance Committee ranking member Ron Wyden said Wednesday.

  • September 29, 2026

    Tax Court Eschews IRS' Math In Facebook Royalty Dispute

    The U.S. Tax Court rejected the IRS' proposed flat-rate royalty calculation for Facebook's deal with an Irish affiliate to develop intangibles, holding Tuesday that the rate should vary across asset categories and change over time to reflect underlying economic factors.

  • September 29, 2026

    IRS Plans To Scrap 71 More Guidance Docs Deemed Outdated

    A revenue ruling that discussed prohibited allocations of securities in an S corporation and a notice that announced a higher withholding rate for gambling winnings are among dozens of guidance documents the IRS identified as extraneous and up for removal, the agency said Tuesday.

Expert Analysis

  • Legal And Industry Impacts Of America's Maritime Action Plan

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    America's Maritime Action Plan, unveiled by the White House last month, introduces changes to trade investigations, a new maritime trust fund and more — adding regulatory and compliance obligations for companies and counsel, but also new avenues for client engagement in project finance, contract negotiation and dispute resolution, say attorneys at Holland & Knight.

  • 4 Ways To Help CBP Curb Shell Co. Import Schemes

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    Shifting to a proactive rather than reactive enforcement posture in addressing shell companies set up to skirt tariffs requires equipping U.S. Customs and Border Protection with enhanced investigative authorities, better intelligence support, and mechanisms to identify and hold accountable the ultimate illicit actors, say attorneys at Kelley Drye.

  • 7 Steps For Gov't Contractors In Post-IEEPA Tariff Landscape

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    In response to U.S. Supreme Court's recent decision to strike down tariffs issued by the Trump administration under the International Emergency Economic Powers Act, there are several actions federal contractors should take to preserve their place in any refund waterfall, and to manage audit, overpayment and False Claims Act risk, say attorneys at Holland & Knight.

  • The Benefits Of Choosing A Niche Practice In The AI Age

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    As artificial intelligence becomes increasingly accessible, lawyers with a niche practice may stand out as clients seek specialized judgment that automation cannot replicate, but it is important to choose a niche that is durable, engaging and a good personal fit, says Daniel Borneman at Lowenstein Sandler.

  • Section 122 Tariffs Show Shift In Strategy, Not Trade Policy

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    By imposing temporary tariffs under Section 122 of the Trade Act as a stopgap measure while it pivots to less transitory statutory authorities, the Trump administration sent a clear message that the U.S. Supreme Court’s decision in Learning Resources v. Trump, invalidating duties imposed under the International Emergency Economic Powers Act, will not precipitate a change in policy direction, say attorneys at Snell & Wilmer.

  • Tax Court Ruling Signals Cross-Border Loan Scrutiny

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    The U.S. Tax Court’s recent decision in Aventis v. Commissioner compounds ongoing regulatory focus on debt originations and should prompt practitioners to assess their existing cross-border lending structures for potential exposure to U.S. federal income tax, say attorneys at Eversheds.

  • Lessons From Justices' Split On Major Questions Doctrine

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    The justices' varied opinions in Learning Resources v. Trump, which held the International Emergency Economy Powers Act did not confer the power to impose tariffs, offer a meaningful window into the U.S. Supreme Court's perspective on the major questions doctrine that will likely shape lower courts' approach to executive action challenges, say attorneys at Venable.

  • Resilience Planning As Nat'l Security Shifts Tech Import Policy

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    In response to a sustained reorientation of U.S. trade policy around national security considerations, businesses reliant on processed critical minerals must closely monitor diplomatic negotiations and the potential expansion of trade measures, incorporating contingency planning into procurement and long-term investment strategies, says attorney Sohan Dasgupta.

  • How The New Tariff Landscape May Unfold

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    To replace tariffs formerly imposed under the International Emergency Economic Powers Act, the administration will rely on a patchwork of statutes, potentially leading to procedural challenges and a complex tariff landscape with varying levels, durations and applicability, says Joseph Grossman-Trawick at King & Spalding.

  • What Orgs. Should Note In IRS Group Tax Exemption Overhaul

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    In a significant update, the IRS Revenue Procedure 2026-8 shows that the group exemption program is moving into a new regulatory era involving more uniformity, oversight and compliance obligations, and early action is key to preserve group exemption status and avoid disruption for subordinate organizations, says Ravi Sundara at Spencer Fane.

  • How Banks Can Apply FinCEN Beneficial Ownership Relief

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    A recent Financial Crimes Enforcement Unit order limiting the circumstances under which banks should identify and verify beneficial owners may allow banks to tailor their approach to verification compliance, but only after reviewing customer due diligence policies and evaluating alignment with their risk profiles, say attorneys at Cleary.

  • Parsing Clarifications On Foreign Entity Rules For Tax Credits

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    Recent U.S. Internal Revenue Service and Treasury Department guidance answers taxpayer questions on several key foreign entity rules under the One Big Beautiful Bill Act, but questions remain over transactions with companies that have ties to covered nations such as Iran, say attorneys at Cleary.

  • Aligning Microsoft Tools With NYC Bar AI Recording Guidance

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    The New York City Bar Association’s recently issued formal opinion, providing ethical guidance on artificial intelligence-assisted recording, transcription and summarization, raises immediate questions about data governance and e-discovery for companies that use Microsoft 365 and Copilot, say Staci Kaliner, Martin Tully and John Collins at Redgrave.

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