Federal
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September 10, 2026
IRS Proposes Opportunity Zone Information Reporting Rules
The Internal Revenue Service proposed rules on Thursday for implementing new statutory requirements for opportunity funds to file information returns to improve the agency's ability to administer and enforce the federal opportunity zone program's tax benefits.
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September 10, 2026
Treasury Floats Foreign Tax Credit Rules After '25 Budget Bill
The U.S. Treasury Department proposed regulations Thursday that would clarify the 2025 federal budget bill's reduction to the range of expenses that companies must allocate to overseas affiliates when calculating foreign tax credits.
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September 10, 2026
McGuireWoods Adds Polsinelli Nonprofit Tax Atty In Atlanta
McGuireWoods LLP has added a partner in Atlanta from Polsinelli PC, strengthening its tax-exempt organizations team with an attorney who has guided nonprofits and tax-exempt organizations on tax matters, the firm announced Thursday.
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September 10, 2026
Tax Court Nod To Income Approach Props Easement Valuation
The IRS has been adversarial toward taxpayers using what is known as the income approach to value conservation easements, but the method's legitimacy was significantly reinforced by the U.S. Tax Court in a recent decision that endorsed the use of the method to value a Los Angeles-area donated property.
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September 10, 2026
US Asks 1st Circ. To Back $3.3M Tax Bill For 'Survivor' Winner
A Rhode Island federal court correctly entered a $3.3 million tax judgment against the first "Survivor" winner, the government told the First Circuit, saying the former contestant failed to refute the tax assessments and had agreed to a U.S. Tax Court decision that determined his liability and penalties.
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September 09, 2026
Defunct Tax Startup CEO Charged In $13.3M Investor Fraud
The CEO of a defunct tax-compliance startup has been arrested on fraud charges based on allegations she defrauded investors out of more than $13 million by lying about her credentials and her company's revenues, the U.S. Department of Justice said Wednesday.
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September 09, 2026
Tax Pros Recall Wrangling Over Siemens' Restructuring
Tax professionals from Siemens and Deloitte described for the U.S. Tax Court on Tuesday and Wednesday the wrangling that went on between the German company and its advisers over the 2018 restructuring plan that led to a $3.5 billion tax deduction in the U.S.
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September 09, 2026
11th. Circ. Upholds Ga. Tax Fraudster's 12½-Year Sentence
The Eleventh Circuit affirmed on Wednesday a12½-year prison sentence for an Atlanta man who was convicted of masterminding a fraudulent tax return scheme that brought in millions of dollars.
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September 09, 2026
Tax Court Backs IRS On Partnership Adjustment Deadline
An Internal Revenue Service notice disallowing a charitable deduction claimed by a Louisiana business partnership was issued in a timely fashion because both sides agreed to an extension that applied to the entire process, the U.S. Tax Court ruled Wednesday.
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September 09, 2026
Economists Tell Fed. Circ. Float Rates Bar Temporary Tariff
President Donald Trump's temporary global tariff lacked legal justification in the current international monetary system, a group of economists, including former U.S. Treasury secretary and Federal Reserve Chair Janet Yellen, told the Federal Circuit on Wednesday in a brief supporting challenges to the duties.
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September 09, 2026
10th Circ. Sets Redo Of Tax Fraud Case To Study Legal Advice
The Tenth Circuit ordered a Kansas federal court to revisit a woman's assertions that ineffective counsel led her to plead guilty to bank and tax fraud charges, saying the trial court needs to further examine whether she indeed received insufficient legal advice.
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September 09, 2026
US Bans Canadian Alcohol, Motorcycles After Tariff Retaliation
President Donald Trump continued the U.S. trade offensive against Canada after its northern neighbor's retaliatory tariffs went into effect, announcing a ban on Canadian imports of certain alcohol, dairy products and motorcycles starting this month.
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September 08, 2026
Judge Nixes Atty's Bid For More Depositions In $12M Tax Suit
A Colorado federal judge denied a request for additional depositions from counsel of an attorney and others accused of siphoning $12 million while advocating an illegal tax fee after determining the request for the depositions was untimely and made outside the discovery window.
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September 08, 2026
Tax Court Adds Five New Trial Locations, Expands Roles
The U.S. Tax Court's chief judge announced that the court will hear cases in five new cities starting Tuesday, bringing the total to 79, while allowing all types of cases to be heard at each location.
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September 08, 2026
Eaton Challenges IRS Example On Intercompany Loans
The IRS is misusing a regulatory example that is unrelated to its argument that Eaton cannot pay foreign affiliates for support that a lender would assume exists in the agency's bid to reduce related-party interest rates and fees, the company told the U.S. Tax Court.
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September 08, 2026
Senate Panel Sets Hearing On IRS Chief Counsel Pick
The Senate Finance Committee will hold a hearing to consider four of President Donald Trump's nominees for various positions, including chief counsel at the Internal Revenue Service, the panel announced Tuesday.
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September 08, 2026
IRS Sets Emission Guidance For Biofuel Tax Credit Eligibility
The IRS released Tuesday the emissions rates use to calculate the tax credit amount for the domestic production of less carbon intensive transportation fuel, including those made primarily of organic materials and other compounds derived from livestock manure.
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September 08, 2026
With New Tax Partner, Simpson Thacher Boosts Sports Focus
Jonathan Westreich joined Simpson Thacher & Bartlett LLP as a tax partner in its Los Angeles office, the firm announced Tuesday, deepening the firm's sports, media and entertainment bench.
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September 08, 2026
IRS Accepting Applications To 2027 Real-Time Audit Program
The Internal Revenue Service is accepting applications for its compliance assurance process real-time audit program for 2027, the agency announced Tuesday.
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September 08, 2026
Canada Defends Retaliatory Tariffs Against US As Necessary
Canadian Prime Minister Mark Carney defended Canada's retaliatory tariffs against the U.S. as they went into effect Tuesday, saying they are needed to protect Canadian workers and industries from President Donald Trump's latest trade war action.
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September 08, 2026
DC Circ. Affirms Injunction Against IRS-ICE Data Sharing
The D.C. Circuit affirmed a lower court's preliminary injunction Tuesday barring the IRS from sharing taxpayer data with immigration authorities, finding that the coalition challenging the deal has standing and that the arrangement likely violates the law.
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September 04, 2026
DOJ Ordered To Turn Over 'Weaponization' Fund Discovery
A Virginia federal magistrate judge ordered the Trump administration Friday to move quickly in turning over documents connected to its proposed "Anti-Weaponization Fund," including the names of those who structured it before the idea was shot down in several federal courts and withdrawn by the U.S. Department of Justice.
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September 04, 2026
4 Books Transfer Pricing Economists Think You Should Read
What do transfer pricing experts — economists, specifically — do in the summer? In July, many of them attend the National Association for Business Economics' annual transfer pricing symposium and discuss their favorite books with Law360 during the coffee breaks. Others were kind enough to do it during their regular work hours. Here, Law360 looks at four of their picks.
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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.
Expert Analysis
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Compliance Pointers Amid Domestic Terrorism Clampdown
A recent presidential memorandum marks a shift in federal domestic-terrorism enforcement that should prompt nonprofits to enhance diligence related to grantees, vendors and events, and financial institutions to shore up their internal resources for increased suspicious-activity monitoring and reporting obligations, say attorneys at Morgan Lewis.
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Trump Tax Law Has Mixed Impacts On Commercial Real Estate
The One Big Beautiful Bill Act brings sweeping changes to the real estate industry — and while the permanency of opportunity zones and bonus depreciation creates predictability for some taxpayers, sunsetting incentives for renewable energy projects will leave others with hard choices, says Jordan Metzger at Cole Schotz.
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Protecting Sensitive Court Filings After Recent Cyber Breach
In the wake of a recent cyberattack on federal courts' Case Management/Electronic Case Files system, civil litigants should consider seeking enhanced protections for sensitive materials filed under seal to mitigate the risk of unauthorized exposure, say attorneys at Redgrave.
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What Ethics Rules Say On Atty Discipline For Online Speech
Though law firms are free to discipline employees for their online commentary about Charlie Kirk or other social media activity, saying crude or insensitive things on the internet generally doesn’t subject attorneys to professional discipline under the Model Rules of Professional Conduct, says Stacie H. Rosenzweig at Halling & Cayo.
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2 Rulings Highlight IRS' Uncertain Civil Fraud Penalty Powers
Conflicting decisions from the U.S. Tax Court and the Northern District of Texas that hinge on whether the IRS can administratively assert civil fraud penalties since the U.S. Supreme Court’s 2024 decision in SEC v. Jarkesy provide both opportunities and potential pitfalls for taxpayers, says Michael Landman at Bird Marella.
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Junior Attys Must Beware Of 5 Common Legal Brief Mistakes
Excerpt from Practical Guidance
Junior law firm associates must be careful to avoid five common pitfalls when drafting legal briefs — from including every possible argument to not developing a theme — to build the reputation of a sought-after litigator, says James Argionis at Cozen O'Connor.
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Digital Asset Report Opens Doors For Banks, But Risks Linger
A recent report from a White House working group discussing digital asset market structure signals how banks may elect to expand into digital asset custody, trading and related services in the years ahead, but the road remains layered with challenges, say attorneys at Foley & Lardner.
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Power To The Paralegals: How And Why Training Must Evolve
Empowering paralegals through new models of education that emphasize digital fluency, interdisciplinary collaboration and human-centered lawyering could help solve workforce challenges and the justice gap — if firms, educators and policymakers get on board, say Kristine Custodio Suero and Kelli Radnothy.
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5 Real Estate Takeaways From Trump's Sweeping Tax Law
Changes to the Internal Revenue Code included in the One Big Beautiful Bill Act will have a range of effects on real estate sponsors, investors and real estate investment trusts — from more compliance flexibility around taxable REIT subsidiary limits to new considerations raised by a key retaliatory tax provision that was left out, say attorneys at DLA Piper.
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Evaluating The Current State Of Trump's Tariff Deals
As the Trump administration's ambitious tariff effort rolls into its ninth month, and many deals lack the details necessary to provide trade market certainty, attorneys at Adams & Reese examine where things stand.
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How Hyperlinks Are Changing E-Discovery Responsibilities
A recent e-discovery dispute over hyperlinked data in Hubbard v. Crow shows how courts have increasingly broadened the definition of control to account for cloud-based evidence, and why organizations must rethink preservation practices to avoid spoliation risks, says Bree Murphy at Exterro.
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Preserving Refunds As Tariffs Await Supreme Court Weigh-In
In the event that the U.S. Supreme Court decides in V.O.S. Selections v. Trump that the president doesn't have authority to levy tariffs under the International Emergency Economic Powers Act, importers should keep records of imports on which they have paid such tariffs and carefully monitor the liquidation dates, say attorneys at Butzel.
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Revamped Opportunity Zones Can Aid Clean Energy Projects
The Qualified Opportunity Zone program, introduced in 2017 and reshaped in the One Big Beautiful Bill Act, offers investors federal tax incentives for development in low-income communities — incentives that are especially meaningful for clean energy projects, where capital-intensive infrastructure and long-term planning are essential, say attorneys at Dentons.