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Federal
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July 13, 2026
Estate's $4M Tax Bill Rife With IRS Errors, Executor Says
The Internal Revenue Service made a litany of errors in determining that an individual's estate faces a tax deficiency of approximately $4 million and more than $744,000 in penalties, the estate's Oklahoma-based executor told the U.S. Tax Court.
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July 13, 2026
McKesson Says IRS Overreads Law Backing Pricing Rules
Pharmaceutical giant McKesson asked a Texas federal court to invalidate transfer pricing regulations that underpin the company's $10 million tax refund bid, arguing the U.S. government mistakenly thinks the underlying statute gives the IRS "near-limitless authority" to define key terms.
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July 13, 2026
Biofuel Tax Fraudster Loses Bid For Extra Sentence Reduction
A Utah federal judge declined to reduce further the original sentence of an accomplice in a $500 million biofuel production tax credit fraud scheme, finding that his prior reduction to 12 years had sufficiently reflected his cooperation in the trial of another defendant.
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July 13, 2026
US Biz Group Urges EU To Honor Side-By-Side Treatment
A lobbying group representing U.S. companies called on the European Union to respect the country's side-by-side agreement as the bloc continues to work on a tax simplification overhaul.
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July 13, 2026
Trump-IRS Settlement Result Of Sham Suit, Judge Rules
President Donald Trump's $10 billion suit against his own Internal Revenue Service and the resulting settlement deal lacked a legitimate controversy, given Trump's control over both the agency and the U.S. Department of Justice, a Florida district judge said Monday in an order barring Trump or others from citing the deal.
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July 10, 2026
Mattress Seller, Mo. Customers End Use Tax Overcharge Fight
A Missouri federal court closed a class action by online customers claiming excessive tax charges by a mattress retailer after the parties reached a deal that will see the customers refunded.
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July 10, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin included a revenue procedure to provide a gift tax reporting safe harbor for certain contributions to the new tax-advantaged brokerage accounts for newborns, known as Trump Accounts.
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July 10, 2026
IRS Defends Tax Court's Deduction In Arrest Injury Settlement
The U.S. Tax Court correctly ruled that part of a man's $35,000 settlement payment from a Massachusetts town is deductible as damages paid for physical injuries, the IRS told the D.C. Circuit on Friday.
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July 10, 2026
US-Canada Stalemate Expected To Hold Amid USMCA Review
The trade stalemate between the U.S. and Canada is likely to continue through a drawn-out review process for the U.S.-Mexico-Canada Agreement, though companies will benefit from an underlying level of stability as the deal remains in effect, trade lawyers said.
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July 10, 2026
Vague IRS Rules Should Nix Foreign Gift Penalties, Court Told
A California civil service worker asked a federal court to waive penalties imposed by the IRS over her failure to report wedding gifts received from family in China, contending the agency was unclear about filing requirements.
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July 10, 2026
Taxation With Representation: Cleary, Paul Weiss, Fried Frank
In this week's Taxation With Representation, Solstice Advanced Materials Inc. acquires specialty chemicals technology company Element Solutions Inc., Vertex Pharmaceuticals Inc. buys Crinetics Pharmaceuticals Inc., and Lockheed Martin acquires naval defense company Ultra Maritime.
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July 09, 2026
Judge Backs Feds' Valuation Method In Windfarm Grant Fight
A U.S. Court of Federal Claims judge ordered several California wind farm owners and the federal government to largely employ a method the government proposed to value their facilities and hash out a decade-old dispute over grants worth hundreds of millions of dollars.
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July 09, 2026
Okla. Tax Officials Say McGirt Can't Upend Osage Ruling
Oklahoma tax officials say the Osage Nation can't rely on a 2020 landmark U.S. Supreme Court ruling to overturn a decision that declined to vacate a 16-year-old determination that its reservation boundaries had been disestablished, telling the Tenth Circuit that the tribe's challenge is too late.
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July 09, 2026
IRS Asks 7th Circ. To Rehear $300M Hyatt Perks Tax Dispute
The IRS asked the Seventh Circuit to reconsider its decision to remand a dispute over $300 million in Hyatt Hotels' loyalty rewards program fund to the U.S. Tax Court for it to determine whether the money can be excluded from taxable income under what's known as the claim of right doctrine.
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July 09, 2026
IRS Updates Outdated References In Estate Tax Rules
The Internal Revenue Service released final regulations that modify and replace outdated references in rules for deceased taxpayers who have passed their property to a noncitizen spouse in a domestic trust.
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July 09, 2026
Reclassified Debt Didn't Cause $21M Gain, Partnership Says
The IRS wrongly treated the reclassification of $21.1 million in debt to equity as a taxable event when hitting a partnership with $12.8 million in taxes, penalties and estimated interest, the partnership told the U.S. Tax Court.
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July 09, 2026
4th Circ. Rebuffs Tax Attys' Request To Rethink Convictions
The Fourth Circuit will not rethink its decision last month affirming the convictions of two St. Louis attorneys accused of engineering a $22 million tax avoidance scheme.
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July 09, 2026
5 Clifford Chance Finance And Tax Attys Join Sidley In NY, DC
Sidley Austin LLP announced Thursday that five Clifford Chance LLP attorneys have joined the firm's global finance and tax practices in New York and Washington, D.C.
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July 09, 2026
Pillar 2 Carveouts Won't Undercut Global Tax, Official Says
The integrity of the 15% global minimum tax system will not be undermined by a host of nations gaining access to provisions that exempt them from certain obligations, the tax head at the Organization for Economic Cooperation and Development said Thursday.
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July 08, 2026
Partnership Defends $55.6M Deduction For Mo. Land Gift
A partnership that donated over 73 acres in Butler County, Missouri, to a conservation group told the U.S. Tax Court it properly deducted $55.6 million for the gift, saying the value was based on the analysis of two qualified appraisers.
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July 08, 2026
IRS To Give Automatic Penalty Relief To Compliant Taxpayers
Taxpayers with a history of filing and paying on time will no longer have to request penalty relief under an automatic exemption expected to roll out this summer, the IRS announced Wednesday.
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July 08, 2026
IRS Finalizes Life Insurance Reporting Exception Regs
The Internal Revenue Service confirmed that certain tax-free transfers of life insurance contracts are exempt from the 2019 reporting rules for life settlement transactions, including policy sales and death benefit payments, under final regulations released Wednesday.
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July 08, 2026
IRS Urged To Make Digital Broker E-Statements Easier
The IRS should update regulations that would allow digital asset brokers to provide statements electronically to remove operational hurdles and designate more effective communication methods, such as in-app messaging and SMS, stakeholders told the agency Wednesday.
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July 08, 2026
Shopping Center Owner's Estate Disputes $41M Deficiency
The estate of a man who co-owned a Massachusetts shopping center challenged a $40.8 million deficiency assessment in the U.S. Tax Court, saying the IRS wrongly determined that a 2012 sale of his interest in the partnership owning the center wasn't bona fide.
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July 08, 2026
IRS Targets Certain Annuity Trusts As Potential Tax Shelters
The IRS unveiled final rules Wednesday designating certain charitable remainder annuity trusts as reportable transactions because they involve abusive tax avoidance practices, subjecting participants to potential penalties if they do not disclose such arrangements.
Expert Analysis
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Adapting To Private Practice: From Texas AUSA To BigLaw
As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.
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Advice For 1st-Gen Lawyers Entering The Legal Profession
Nikki Hurtado at The Ferraro Law Firm tells her story of being a first-generation lawyer and how others who begin their professional journeys without the benefit of playbooks handed down by relatives can turn this disadvantage into their greatest strength.
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UK's 1st ICSID Claim Shows Bilateral Investment Treaty Reach
For the first time, the U.K. is facing a claim under the International Centre for Settlement of Investment Disputes Convention, underscoring the broader reality that treaty protections are no longer confined to investors in emerging markets, says Philipp Kurek at Signature Litigation.
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Trump Tax Law's Most Impactful Corp. And Individual Changes
The One Big Beautiful Bill Act built on and reshaped elements of the Tax Cuts and Jobs Act, including business interest deductions, bonus depreciation and personal income relief, delivering substantial changes to both corporate and individual tax policy, say attorneys at Weil.
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From Clerkship To Law Firm: 5 Transition Tips For Associates
Excerpt from Practical Guidance
Transitioning from a judicial clerkship to an associate position at a law firm may seem daunting, but by using knowledge gained while clerking, being mindful of key differences and taking advantage of professional development opportunities, these attorneys can flourish in private practice, say attorneys at Lowenstein Sandler.
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Trump Tax Law's Most Consequential International Changes
The international tax provisions in the One Big Beautiful Bill Act may result in higher effective tax rates for some multinational corporations, but others, particularly those operating in low-tax jurisdictions, may benefit from alignment with global anti-profit shifting efforts, say attorneys at Weil.
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Associates Can Earn Credibility By Investing In Relationships
As the class of 2025 prepares to join law firms this fall, new associates must adapt to office dynamics and establish credible reputations — which require quiet, consistent relationship-building skills as much as legal acumen, says Kyle Forges at Bast Amron.
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Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling
The Seventh Circuit’s recent decision in Pable v. Chicago Transit Authority, affirming the dismissal of an ex-employee’s retaliation claims, highlights the importance of properly handling the preservation of ephemeral messages and clarifies key sanctions issues, says Philip Favro at Favro Law.
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What 2 Profs Noticed As Transactional Law Students Used AI
After a semester using generative artificial intelligence tools with students in an entrepreneurship law clinic, we came away with numerous observations about the opportunities and challenges such tools present to new transactional lawyers, say professors at Cornell Law School.
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BigLaw Settlements Should Not Spur Ethics Deregulation
A recent Law360 op-ed argued that loosening law firm funding restrictions would make BigLaw firms less inclined to settle with the Trump administration, but deregulating legal financing ethics may well prove to be not merely ineffective, but counterproductive, says Laurel Kilgour at the American Economic Liberties Project.
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5 Ways Lawyers Can Earn Back The Public's Trust
Amid salacious headlines about lawyers behaving badly and recent polls showing the public’s increasingly unfavorable view of attorneys, we must make meaningful changes to our culture to rebuild trust in the legal system, says Carl Taylor at Carl Taylor Law.
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Legal Jeopardy Looms Over Trump's Trade Negotiation Plans
Even as the Trump administration announces one trade deal after another, the legal authority of the executive branch to impose tariffs under consensual arrangements with leading trading partners is just as debatable as the unilateral imposition of U.S. tariffs under the president's executive orders, says Jeffrey Bialos at Eversheds Sutherland.
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Opportunity Zone Overhaul Is Good News For Investors
Recently enacted reforms making the qualified opportunity zone program permanent, restoring the basis step-up for capital gains and adding flexibility to the zone designation process enhance the program’s appeal for long-term investment, says Steven Hadjilogiou at McDermott.