Federal

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • July 08, 2026

    Foley Adds Attys From Kirkland, Goodwin To Corporate Team

    Foley & Lardner LLP has strengthened its corporate bench with a Dallas-based partner who came aboard from Kirkland & Ellis LLP and a Boston-based partner from Goodwin Procter LLP.

  • July 07, 2026

    2 Ex-Telehealth Execs Sentenced For $100M Adderall Scheme

    A California federal judge on Tuesday sentenced two former executives of a telehealth company who were convicted of operating a $100 million scheme to illegally distribute Adderall over the internet, fining them $1 million each and giving the founder six years in prison.

  • July 07, 2026

    DC Circ. Backs Tax Bribery Convictions Despite Jury Error

    A D.C. Circuit panel refused on Tuesday to reverse a lower court's judgments against two men in connection to a bribery scheme carried out to evade $2.3 million in business tax obligations, finding a jury instruction error "harmless," among other unsuccessful arguments.

  • July 07, 2026

    Dem Sens. Probe CEOs On Trump-IRS Settlement Immunity

    Three senior Democratic senators are investigating whether several companies with ties to President Donald Trump are benefiting from what they alleged was immunity for him, his family and his businesses in the settlement he reached with the Internal Revenue Service. 

  • July 07, 2026

    Exxon Seeks $324M Judgment In Dispute On Qatar Deal Tax

    Exxon asked a Texas federal court to rule that it's owed a $273 million tax refund and $51 million in penalties in a dispute with the U.S. government over the tax treatment of a natural gas deal with Qatar.

  • July 07, 2026

    IRS Denies Blowing Deadline In $34M Easement Dispute

    The IRS timely issued a notice of adjustment to a partnership claiming a $34 million easement deduction for its donation to a Cleveland historic preservation group, the agency told the U.S. Tax Court, arguing that the partnership is raising a frivolous contention in seeking to throw out the adjustment and penalties.

  • July 07, 2026

    Consultant Says FARA Verdict Should Be Erased

    A political consultant convicted of knowingly failing to register as a foreign agent as she helped draft a $50 million contract involving a former congressman and Venezuela's state-owned oil enterprise continues to argue she should be acquitted or given a new trial, saying the verdict was "against the great weight of the evidence."

  • July 07, 2026

    Claims Court Nixes GILTI Tax Rules Under Loper Bright

    The U.S. Court of Federal Claims invalidated corporate tax regulations that deny amortization deductions tied to certain overseas intangible asset transfers, holding that the rules are the kind of "agency overreach" foreclosed by the U.S. Supreme Court's Loper Bright ruling.

  • July 07, 2026

    Grocers' Microcaptive Not Valid For Tax Benefit, 7th Circ. Told

    Chicagoland grocery chain owners were not entitled to microcaptive tax benefits because they failed to establish a bona fide in-house insurance arrangement, the government told the Seventh Circuit, saying the U.S. Tax Court correctly held that state law does not control the federal tax definition of insurance.

  • July 07, 2026

    Simpson Thacher Adds Energy Tax Partner From Weil In NY

    Simpson Thacher & Bartlett LLP announced Tuesday that a former Weil Gotshal & Manges LLP partner has joined the firm's New York office to advise clients on the U.S. tax aspects of energy and infrastructure transactions.

  • July 06, 2026

    4 Benefits And Exec Comp Policy Moves From 2026's 1st Half

    The U.S. Department of Labor's proposal for a 401(k) fund safe harbor and the U.S. Securities and Exchange Commission's proposal to change the reporting framework for public companies are among the top policy developments from the first half of 2026 that drew benefits and executive compensation attorneys' attention. Here, Law360 looks at four recent developments that attorneys may want to know about.

  • July 06, 2026

    Partnership Agrees To Nix Tenn. Land Gift Deduction

    A partnership agreed with the IRS that its claimed $4.5 million deduction for over 50 acres in Tennessee donated in 2017 should be zero but that it is entitled to a separate deduction of $967,000. 

  • July 06, 2026

    After Tense Terms, Hints Of High Court Harmony With Circuits

    Following several U.S. Supreme Court terms teeming with reversals and rebukes of lower appeals courts, the justices this term found fault less often with rulings by circuit judges, who are likely becoming better attuned to the conservative supermajority, attorneys say.

  • July 06, 2026

    The Moments That Shaped The Monsanto Decision

    U.S. Supreme Court justices forged unusual alliances when they ruled a federal statute preempts claims Monsanto failed to warn consumers its Roundup weed killer may cause cancer. Oral arguments provided insights on the 7-2 outcome, highlighting issues the jurists were grappling with and showcasing rationales that found their way into the opinion.

  • July 06, 2026

    The Funniest Moments Of The Supreme Court's Term

    When one of the U.S. Supreme Court's most talkative members suddenly struggled to speak, the atmosphere at oral arguments grew increasingly anxious — until the justice deadpanned that it was an advocate's golden opportunity to avoid a grilling.

Expert Analysis

  • UK's 1st ICSID Claim Shows Bilateral Investment Treaty Reach

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    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.

  • Trump Tax Law's Most Impactful Corp. And Individual Changes

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    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.

  • From Clerkship To Law Firm: 5 Transition Tips For Associates

    Excerpt from Practical Guidance
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    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.

  • Trump Tax Law's Most Consequential International Changes

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    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.

  • Associates Can Earn Credibility By Investing In Relationships

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    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.

  • Lessons From 7th Circ.'s Deleted Chat Sanctions Ruling

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    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.

  • What 2 Profs Noticed As Transactional Law Students Used AI

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    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.

  • BigLaw Settlements Should Not Spur Ethics Deregulation

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    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.

  • 5 Ways Lawyers Can Earn Back The Public's Trust

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    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.

  • Legal Jeopardy Looms Over Trump's Trade Negotiation Plans

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    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.

  • Opportunity Zone Overhaul Is Good News For Investors

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    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.

  • White House Report Strikes An Optimistic Note On Crypto

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    Taking seriously President Donald Trump's pledge to adopt a pro-innovation mindset toward digital assets and blockchain technologies, a recent benchmark White House report on crypto provides a comprehensive regulatory framework that takes into account the products' novel characteristics within the high-tech ecosystem, say attorneys at Davis Wright.

  • Bipartisan Bill Could Aid ESOP Formation, Valuation Clarity

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    The proposed Retire through Ownership Act represents a meaningful first step toward clarifying whether transactions qualify under the adequate consideration exemption in the Employee Retirement Income Security Act, potentially eliminating the litigation risk that has chilled employee stock ownership plan formation, say attorneys at Moore & Van Allen.

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