Federal
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September 04, 2026
IRS Finalizes 50% Personal-Use Test For Car Loan Tax Break
A vehicle's amount of personal use would be based on the buyer's expected use over the period of ownership for purposes of determining eligibility for the tax break on car loan interest enacted in last summer's budget law, according to final regulations released Friday.
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September 04, 2026
ERISA Recap: 5 Appellate Rulings To Know From August
The Seventh Circuit kept an Arkansas pharmacy benefit manager rule in place as not preempted by federal benefits law, the Fourth Circuit revived an Altria ex-worker's dispute over benefit plan documents, and the Eleventh Circuit reversed a pretrial win for Royal Caribbean in cruise workers' suit challenging 401(k) funds. Here, Law360 looks at those and two other major appellate decisions from August involving ERISA that benefits attorneys may want to know.
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September 04, 2026
Chrisleys Fight Balch & Bingham's Bid To Ax Malpractice Suit
Reality television stars Todd and Julie Chrisley asked a Georgia federal judge on Friday to reject an attempt by their former attorneys to dismiss a legal malpractice lawsuit that claims a critical pretrial mistake allowed evidence obtained through an unlawful search to be used against them at their criminal trial.
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September 04, 2026
4th Circ. Affirms $2.9M IRS Fine For Unreported Accounts
The Fourth Circuit affirmed a $2.9 million fine Friday against a Hong Kong-based U.S. businessman, holding that he should have known there was a "grave risk" of inaccurate tax filings when he failed to disclose offshore accounts to the IRS.
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September 04, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included proposed rules addressing the 2025 federal budget bill's changes to how U.S. corporations account for the earnings of their offshore affiliates when calculating their taxable income.
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September 04, 2026
IRS Updates Rules For Changing R&D Accounting Methods
The Internal Revenue Service on Friday updated its guidelines for those looking to get automatic consent to change their method of accounting for research and development expenditures to comply with changes made in President Donald Trump's two major tax bills.
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September 04, 2026
IRS Spent 64% Of $26B Current Funding, Watchdog Says
The Internal Revenue Service has already spent 64% of the $26 billion that Congress appropriated earlier this year for the agency through 2031, directing most of the money toward enforcement and taxpayer services, according to the tax administration watchdog's report.
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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.
Expert Analysis
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Legal And Industry Impacts Of America's Maritime Action Plan
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.
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4 Ways To Help CBP Curb Shell Co. Import Schemes
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.
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7 Steps For Gov't Contractors In Post-IEEPA Tariff Landscape
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.
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The Benefits Of Choosing A Niche Practice In The AI Age
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.
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Section 122 Tariffs Show Shift In Strategy, Not Trade Policy
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.
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Tax Court Ruling Signals Cross-Border Loan Scrutiny
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.
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Lessons From Justices' Split On Major Questions Doctrine
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.
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Resilience Planning As Nat'l Security Shifts Tech Import Policy
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.
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How The New Tariff Landscape May Unfold
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.
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What Orgs. Should Note In IRS Group Tax Exemption Overhaul
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.
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How Banks Can Apply FinCEN Beneficial Ownership Relief
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.
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Parsing Clarifications On Foreign Entity Rules For Tax Credits
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.
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Aligning Microsoft Tools With NYC Bar AI Recording Guidance
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.