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Federal
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July 21, 2026
IRS Lacks Expert Testimony In Easement Fight, Donor Says
The Internal Revenue Service is trying to disallow a partnership donor's $19.1 million charitable deduction for a Georgia conservation easement with limited expert testimony, the partnership told the U.S. Tax Court, arguing that approach violates the rules governing valuation cases.
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July 21, 2026
Arbitrator Orders IRS To Restore Telework, Remote Work
The IRS violated the National Treasury Employees Union's collective bargaining agreement and committed unfair labor practices when it required employees to return to work in person last year, an arbitrator said, ordering the agency to restore telework and remote work arrangements to levels allowed before March 2025.
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July 21, 2026
IRS Issues 2027 Table For Premium Tax Credit Calculations
The Internal Revenue Service published the table used for calculating the health insurance premium tax credit for 2027 on Tuesday.
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July 21, 2026
Amgen To Pay $74M To End Investor Suit Over $10.7B Tax Bill
Pharmaceutical giant Amgen has agreed to pay $74 million to resolve an investor class action alleging it hid a $10.7 billion tax bill from shareholders, according to an agreement filed in New York federal court.
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July 21, 2026
AI Could Raise US Tax Take $216B By 2030, Report Says
Rapid adoption of artificial intelligence could grow U.S. federal tax revenues by up to $216 billion in 2030, yet that figure would be twice as large if income gains weren't skewed toward capital instead of labor, the Yale Budget Lab said.
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July 21, 2026
Nintendo Seeks Game Over For Tariff Refund Class Suit
A proposed class action looking to force Nintendo to reimburse customers for increased costs that were explicitly tied to President Donald Trump's now struck-down tariff regime should be handled in arbitration or tossed entirely, the company told a Seattle federal court.
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July 21, 2026
Budget Bill's FDII Tax Changes Head To OMB Review
The Office of Management and Budget is reviewing the U.S. Treasury Department's proposed regulations for the 2025 federal budget bill's changes to the tax treatment of domestically held intellectual property, including an anti-abuse rule for related-party transactions.
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July 20, 2026
Trump Unveils 50% Canada Tariffs Over 'Trade Discrimination'
President Donald Trump Monday unveiled plans for 50% tariffs on a slew of Canadian products, including alcoholic beverages, dairy products and motor vehicles, pointing to "discriminatory treatment of U.S. commerce" and a provision of the Tariff Act that has seldom been used.
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July 20, 2026
DOJ Hints Russian Court Ruling May Not Stop $5B Award
The Trump administration on Monday urged the D.C. Circuit to closely evaluate a Russian court's determination that an underlying arbitration agreement is invalid as it weighs whether to enforce a nearly $5 billion arbitral award against the Kremlin, saying circumstances surrounding the ruling should be a factor.
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July 20, 2026
Taxpayer's Expert Not Qualified To Determine Life Expectancy
A taxpayer's expert wasn't qualified to determine a man's life expectancy for purposes of valuing gifts made to him by his children, the U.S. Tax Court held Monday.
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July 20, 2026
Energy Cash-Grant Case Casts Light On Investment Tax Credit
The U.S. Court of Federal Claims' long-awaited decision on a California wind farm's valuation for a now-defunct cash grant program offers insight into an issue on which the IRS has issued little guidance: how to value clean energy projects financed by the investment tax credit.
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July 20, 2026
DOJ Says $1.8B Fund Is Dead, Urges Court To Toss Suit
A Virginia federal judge should dismiss a suit challenging the U.S. Department of Justice's $1.8 billion settlement fund that was to be included in a deal to close President Donald Trump's tax leak suit, the federal government said, arguing the case is moot.
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July 20, 2026
Microsoft Hit With Tariff Refund Suit By Xbox Buyer
Microsoft Corp. stands to make an "unjustified windfall profit" through refunds of President Donald Trump's now-invalidated global tariff regime, according to a proposed consumer class action removed to Washington federal court Friday.
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July 20, 2026
Water Transfer Co. Seeks $351K In Worker Credit Refunds
The Internal Revenue Service owes a water transfer services company nearly $351,000 in employee retention tax credit refunds, the business told a Pennsylvania federal court, saying the agency improperly retained the overpayments to offset a supposed civil penalty against the company.
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July 20, 2026
Wis. Village Can't Void Tribal Land Trust Order, 7th Circ. Told
The U.S. Department of the Interior is asking the Seventh Circuit to reject a Wisconsin village's appeal that seeks to undo the agency's decision to place 500 acres into trust for the Oneida Nation, arguing that the municipality can't overcome Congress' power to regulate Indian affairs.
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July 20, 2026
House Dems Bill Would Provide Second IRS Funding Boost
The Internal Revenue Service would receive an $83 billion funding boost for enforcement efforts, technology modernization, taxpayer services improvements and business system enhancements under legislation backed by nearly 40 House Democrats on Monday.
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July 20, 2026
Pension Guarantor Proposes Rule On Disclosure Penalties
The Pension Benefit Guaranty Corp. proposed a rule Monday on monetary penalties for failures to provide information on single-employer and multiemployer benefit plans that clarifies how plan sponsors can lower what's owed when they run afoul of their disclosure duties under federal benefits law.
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July 20, 2026
CIT Judge Changes IEEPA Test Case But Retains Schedule
The U.S. Court of International Trade has selected a new underlying case as the one to test the federal government's updates on its system for refunding duties charged under President Donald Trump's struck-down global tariff regime, though it otherwise kept in place certain reporting and hearing deadlines.
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July 17, 2026
Wash. Owner Of Sites Gets 20 Months For $4.8M Tax Evasion
A commercial real estate owner who was convicted of tax evasion for concealing roughly $4.8 million in income from the IRS was sentenced to nearly two years in prison by a Washington federal judge.
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July 17, 2026
Keysight Invalidates IRS Rule On GILTI, Abbott Says
A 2019 rule on the calculation of global intangible low-taxed income that the IRS relied on to allocate $8 million to Abbott Laboratories in 2020 is invalid, the company said, citing a recent ruling by the U.S. Court of Federal Claims.
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July 17, 2026
DC Circ. Backs Maximum Prison Term For Trump Tax Leaker
The D.C. Circuit has upheld the maximum prison sentence handed down in the case of an IRS contractor who pled guilty to leaking President Donald Trump's tax returns, along with thousands of others, ruling Friday that the punishment was "reasonable."
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July 17, 2026
Oil Co. Asks Tax Court To Make Additional Tax Credit Claim
An energy company that the U.S. Tax Court allowed to give up the normal carryback period for its net operating losses without waiving the 10-year period for specified liability losses wants the court to amend its claim to include a higher foreign tax credit.
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July 17, 2026
Taxation With Representation: Freshfields, Slaughter And May
In this week's Taxation With Representation, Uber Technologies Inc. buys food delivery company Delivery Hero SE, engineering group ABB Ltd. acquires flow technology company Rotork PLC, and Eli Lilly and Co. buys drug developer AtaiBeckley Inc.
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July 17, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included an update to the list of Native American tribes that have settled tribal trust cases with the federal government for tax purposes.
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July 16, 2026
11th Circ. Affirms Quarry Valuation Sank $23M Easement Perk
A 103-acre tract's best alternative use is not an aggregate quarry, the 11th Circuit ruled, rejecting the valuation that supported a partnership's $23 million deduction claim for donating the Georgia property as a conservation easement.
Expert Analysis
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Navigating The Perks Of Qualified Opportunity Zones 2.0
The second iteration of the qualified opportunity zone program, effective Jan. 1, 2027, will introduce new tax incentives for rural real estate development, but these benefits can only be realized if proper governance is a priority, including clear documentation and securities law compliance, says Coni Rathbone at VF Law.
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Getting The Most Out Of Learning And Development Programs
Excerpt from Practical Guidance
Junior associates can better develop the legal, business and interpersonal skills they need for long-term success by approaching their firms’ learning and development programs armed with five tips for getting the most out of these resources, says Lauren Hakala at Reed Smith.
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AI Presents A Make-Or-Break Moment For Outside Counsel
The rapid adoption of artificial intelligence by corporate legal departments is forcing a long-overdue reset of the relationship between inside and outside counsel, and introducing a significant opportunity to shed frustrating inefficiencies and strengthen collaboration for firms willing to embrace the shift, says Intel Chief Legal Officer April Miller Boise.
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8 Tariff Refund Questions For Restructuring Professionals
For restructuring and turnaround professionals, seeking refunds following the U.S. Supreme Court's recent decision invalidating tariffs imposed under the International Emergency Economic Powers Act raises several questions about how to capture legitimate recoveries while protecting an enterprise from the consequences of its own history, says Jonny Frank and Laura Greenman at StoneTurn, and Andrew Popescu at Province.
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5 Tips For Navigating Your Firm's All-Attorney Summit
Excerpt from Practical Guidance
Law firm retreats should be approached strategically, as they present valuable opportunities to advance both the firm's objectives and attorneys' professional development through meaningful participation, building and strengthening internal relationships, and proactive follow-up, says James Argionis at Cozen O’Connor.
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How Bankrupt Cos. Can Seek Refunds For Illegal Tariffs
In light of the U.S. Supreme Court's recent decision striking down President Donald Trump's International Emergency Economic Powers Act tariffs as illegal, some companies may have strong prospects for recovering refunds from the government, and trustees in bankruptcy may have a significant role to play in seeking such recovery, say attorneys at Stinson.
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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.