Federal
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September 03, 2026
Developer Seeks To Restore $78M In Conservation Tax Perks
The Internal Revenue Service was wrong to disallow two conservation easement deductions worth a combined $78 million based on potential mining activity without adequately explaining why, an Alabama real estate developer told the U.S. Tax Court.
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September 03, 2026
Tax Court Keeps Innocent Spouse Case Over IRS Mail Flaw
The Internal Revenue Service failed to establish that it properly mailed a final determination notice to a Nevada woman, the U.S. Tax Court said Thursday, denying the agency's motion to dismiss for untimely filing.
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September 03, 2026
Social Security Number Needed For COVID Rebate, Court Says
The U.S. Tax Court rejected a man's bid to claim a COVID-19-era tax rebate credit Thursday because he didn't provide a Social Security number on his return, instead using an individual taxpayer identification number.
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September 03, 2026
IRS Needs To Improve Representation Training, TIGTA Says
The Internal Revenue Service needs to overhaul training related to taxpayers' rights to representation and direct contact restrictions after a review found some employees lacked required knowledge, the Treasury Inspector General for Tax Administration said.
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September 03, 2026
IRS Could Improve Follow-Up On Rich Nonfilers, TIGTA Says
The IRS could secure a tax return or make an assessment in over 10,000 cases involving wealthy nonfilers by taking further action on those cases after issuing an initial notice, the Treasury Inspector General for Tax Administration estimated in a report released Thursday.
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September 03, 2026
IRS Moves To Strip Schools' Tax Exemptions Over DEI Policies
As many as 18,000 private schools that enact racially based diversity and inclusion policies could lose their federal tax exemptions under a proposed rule released by the Internal Revenue Service on Thursday.
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September 02, 2026
Technology Biz Can't Deduct $59M, Tax Court Says
A California man's technology business can't deduct the $59 million in losses it claimed for 2016 and 2017, the U.S. Tax Court held Wednesday in a case in which it also rejected the IRS' determinations of his individual income.
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September 02, 2026
Airbnb Can't Nix IRS Expert In $1.3B Bill Fight, Tax Court Says
The U.S. Tax Court denied Airbnb's bid to strike IRS expert witness reports from discovery proceedings in the company's challenge against a $1.3 billion tax bill, ruling Wednesday that a procedural rule governing expert testimony applies only to trials.
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September 02, 2026
Vitamin Co. Can't Duck $1.4M Suit Over Ex-Owner's Tax Lien
A vitamin company and its owners must face a suit by the federal government seeking $1.4 million stemming from a tax lien on a former owner's 20% interest in the company, a Connecticut federal judge ruled.
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September 02, 2026
11th Circ. OKs Refusal Of $1.5M Offer To End $140M Tax Debt
The Eleventh Circuit rebuffed a software company founder's $1.5 million offer to settle his $140 million tax debt from 1999, ruling Wednesday that the IRS properly rejected the lowball offer in a case tied to sham arrangements.
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September 02, 2026
Lutnick Says Semiconductor Tariffs Are Coming, With Carveouts
U.S. Secretary of Commerce Howard Lutnick on Wednesday said the U.S. is looking to issue a broad tariff on semiconductors, though he also said it would be structured such that companies that commit to U.S. manufacturing would be exempt.
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September 01, 2026
Siemens Leaders Testify They Were Unaware Of Tax Strategy
Three executives who described how Siemens' digital software business integrated Mentor Graphics' operations after acquiring that electronic design automation company in 2017 seemed oblivious to the tax aspects of the restructuring that occurred in 2018, their testimony Monday and Tuesday showed.
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September 01, 2026
Investment Co. Disputes IRS' $166M Add-On To Capital Gains
An investment company accused the IRS of mistakenly inflating its 2008 short-term capital gains from certain securities investments to about $170 million from $4 million, telling the U.S. Tax Court the gains were properly deferred during the Great Recession.
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September 01, 2026
Strip Club Boss Wants Only Probation After $1.5M Tax Penalty
The former boss of a Connecticut strip club who pled guilty to five charges after being accused of hiding $5.7 million from the IRS told a federal court he should serve no prison time since he already coughed up more than $1.5 million in tax.
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September 01, 2026
Valid Regs Require Abbott To Pay Tax On $8B Gain, IRS Says
The IRS urged the U.S. Tax Court to validate regulations that the agency said required Abbott Laboratories to pay taxes on an $8 billion gain stemming from transactions between its foreign affiliates, arguing the pharmaceutical giant is pushing for "an inappropriately rigid" statutory interpretation.
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September 01, 2026
NC Bar Defends Discipline Of Former Judge To Top Court
The North Carolina State Bar's decision to punish a former judge for actions he took while on the bench is not an attack on judicial independence, the bar argued in urging the state's top court not to take up an appeal challenging an order of discipline against him.
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September 01, 2026
Temporary Tariffs Exceeded Trump's Power, Fed. Circ. Told
President Donald Trump illegally based his temporary tariffs on the misapplication of a law allowing the president to address balance-of-payment deficits, two businesses told the Federal Circuit, pushing the court to preserve a U.S. Court of International Trade ruling against the tariffs.
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August 31, 2026
Siemens Urges Court Toward Wide View Of 2018 Restructuring
An attorney for Siemens USA asked the U.S. Tax Court on Monday to consider all elements of the restructuring that followed the company's 2017 acquisition of Mentor Graphics and led to a $3.5 billion deduction the following year.
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August 31, 2026
States Ask Fed. Circ. To Revive Their Temporary Tariff Claims
Two dozen states pushed the Federal Circuit on Monday to revive their specific claims against now-expired temporary tariffs while simultaneously pushing the panel to otherwise back the U.S. Court of International Trade's ruling that the tariffs were illegal.
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August 31, 2026
3rd Circ. OKs Ex-Biofuel Execs' Fraud Subsidy Convictions
The Third Circuit upheld two former biofuels executives' fraud convictions tied to IRS and EPA fuel subsidies, denying them a retrial based on claims that a Pennsylvania lower court improperly refused to provide jurors more information on the agencies' regulations.
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August 31, 2026
Investors Can't Escape Danish Tax Fraud Case, 2nd Circ. Says
Four investors and their pension plans owe $476 million for their role in a tax fraud scheme against the Danish government, the Second Circuit affirmed Monday, rejecting the investors' contention that they are beyond the reach of Danish revenue collectors.
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August 31, 2026
Levi Strauss Buyer Seeks Refund After Trump Tariffs Tossed
Levi Strauss & Co. has yet to provide a way for its customers to get refunds of unlawful tariff-related costs they had to pay for imported goods affected by President Donald Trump's since-invalidated global "tariff regime," alleges a proposed class action filed in Louisiana federal court Friday.
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August 31, 2026
Avalara Investors Suing Over $8.4B Buyout Win Class Cert.
A Washington federal judge granted class certification to investors in tax software company Avalara in a suit alleging it misled investors ahead of an $8.4 billion deal to take the company private.
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August 31, 2026
Canada, France Treaties Don't Ax Investment Tax, Court Says
U.S. tax treaties with Canada and France don't shield taxpayers from the net investment income tax because the treaties' foreign tax credits are subject to limitations in the Internal Revenue Code, the Court of Appeals for the Federal Circuit said Monday, reversing two decisions.
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August 31, 2026
Tax Court Says Trader Didn't Aid In $7.3B IRS Probe
A U.S. Tax Court judge rejected a former stock trader's claim for a whistleblower award Monday, saying he did not play a significant role in Internal Revenue Service investigations into digital option tax shelters that recovered at least $7.3 billion.
Expert Analysis
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How Data Center Accounting May Draw Enforcement Scrutiny
As public and media scrutiny of the data center industry intensifies, regulators, enforcement authorities and Congress will likely focus on accounting judgments that rely on aggressive assumptions, opaque financing structures or rapidly evolving collateral classes, heightening the risk of investigations and inquiries, say attorneys at King & Spalding.
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Improving Well-Being In Law, 10 Years After Landmark Study
An important 2016 study revealed significant substance abuse and mental health issues among lawyers, and while the findings helped normalize the conversation around these topics, a decade later, structural change is still needed, says Denise Robinson at PLI.
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How To Gear Up For Trump's Pharma Tariffs
President Donald Trump's proclamation establishing tariffs on certain pharmaceutical products holds a few areas of ambiguity that companies should review and prepare for before the tariffs come into effect later this year, say attorneys at Arnold & Porter.
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Steps To Consider As DOJ Launches Fraud Division
The establishment this month of the National Fraud Enforcement Division within the U.S. Department of Justice is a significant reorganization that suggests an increase in enforcement activity involving federally funded programs but leaves a number of important questions unanswered, say attorneys at Crowell & Moring.
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What To Expect From The SEC's New SOX Group
In a potential shift away from Public Company Accounting Oversight Board enforcement, the U.S. Securities and Exchange Commission's formation of a new group to investigate and litigate potential violations of the Sarbanes-Oxley Act brings both risks and benefits for auditors, say attorneys at King & Spalding.
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Hungary CPAC Funding Probe Could Implicate US Entities
A Hungarian anti-corruption investigation into claims that the former prime minister used taxpayer funds to support the Conservative Political Action Conference could include potential cross-border political and financial dimensions that create multiple touchpoints for U.S. regulatory and enforcement interest, say attorneys at Ballard Spahr.
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Mitigating Multistate Risks As California Expands Tax Reach
Though California's new sourcing rules and extension of the pass-through entity election have created uncertainty, practitioners should file protective returns to respect the law's ambiguity and take certain other steps to protect clients from the costs of losing a future audit, says attorney Delina Yasmeh.
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E-Discovery Quarterly: Recent Rulings On ESI Control
Several recent federal court decisions have perpetuated a split over what constitutes “control” of electronically stored information — with judges divided on whether the standard should turn on a party's legal right or practical ability to obtain the information, say attorneys at Sidley.
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Anticipating The Justices' Potential Ruling On Tax Takings
Recent oral arguments in the U.S. Supreme Court case Pung v. Isabella focused on rules for valuation, timing and administrability of tax auction proceeds and whichever method the court adopts for determining just compensation, it will have far-reaching impacts on tax collection, homeowners' equity and the secondary market for tax-foreclosed property, say attorneys at Holland & Knight.
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2 Discovery Rulings Break With Heppner On AI Privilege Issue
While a New York federal court’s recent ruling in U.S. v. Heppner suggests that some litigants’ communications with AI tools are discoverable, two other recent federal court decisions demonstrate that such interactions generally qualify for work-product protection under the Federal Rules of Civil Procedure, says Joshua Dunn at Brown Rudnick.
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CBP's $166B Tariff Refund Portal Needs 4 Safeguards
Before launching its automated web portal to process tariff-refund disbursements on April 20, U.S. Customs and Border Protection should apply the expensive lessons learned from the pandemic-era employee retention credit, says Peter Gariepy at RubinBrown.
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How Developers Can Leverage The New Markets Tax Credit
An increased regulatory focus on affordable housing raises important legal considerations for structuring transactions using the oft overlooked New Markets Tax Credit, which can fill a gap in affordable for-sale housing financing by lowering community developer costs but comes with unique compliance, structuring and documentation demands, say attorneys at Stinson.
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Calculating Damages In IEEPA Tariff Refund Litigation
To calculate damages in the spate of refund litigation triggered by the U.S. Supreme Court's recent decision invalidating tariffs collected under the International Emergency Economic Powers Act, the central question will be how to determine where in the supply chain their economic burden ultimately came to rest, say analysts at Charles River Associates.