Privilege Ruling Could Spur Tax Pros To Inspect AI Policies

Kat Lucero

A New York federal court ruling denying privilege to a client's communications with an artificial intelligence platform could prompt tax practitioners to reconsider such technology's use in sensitive matters and update client agreements to clarify their AI policies.

Timing Wrinkle Could Muddle Foreign Currency Tax Rules

Natalie Olivo
Senior Tax Correspondent

The U.S. Treasury Department has signaled plans to simplify the process for determining the taxable corporate income of affiliates that conduct business in foreign currencies, but the unclear timeline of upcoming guidance could complicate compliance initially.

Trade Probes Likely To Be Strong Bulwark For Trump's Tariffs

Dylan Moroses

President Donald Trump will likely deploy new tariffs this summer across numerous countries under a law that provides the federal government with its strongest legal footing yet in federal court for a global tariff regime.

Tax Teams Get No Bright-Line Rule From AI Privilege Cases

Three recent appellate decisions that considered artificial intelligence in the context of attorney-client privilege protections illustrate that taxpayers and tax practitioners alike must consider the pertinent facts on a case-by-case basis, with particular attention to confidentiality, disclosure risk and system design, say attorneys at Morgan Lewis.

NY Times Word Puzzles Make Me A Better Lawyer

Every morning I let The New York Times humble me with word games, which offer a chance to recalibrate my brain before the day's chaos arrives and remind me that a solution — whether to a puzzle or employment law issue — almost always exists once I find the right angle, says Amy Epstein Gluck at Pierson Ferdinand.

Law School's Missed Lesson: Diagnose Before Arguing

Law school often skips over explicitly teaching students how to determine what kind of problem a case presents before they commit to a particular doctrinal path, which risks building arguments that are internally coherent but externally misaligned, says Melanie Oxhorn at Kobre & Kim.

Judges On AI: How Courts Can Survive The Tech Revolution

Colorado Supreme Court Justice Maria Berkenkotter and Colorado Court of Appeals Judge Lino Lipinsky de Orlov discuss how artificial intelligence has already fundamentally altered the legal system and offer tips for courts navigating deepfakes, hallucinations and a gap in access to AI tools.

3 AI Adoption Mistakes GCs Should Avoid

The pressure in-house legal teams face to quickly adopt artificial intelligence tools, combined with budget constraints and the need to evaluate a crowded market of options, sets the stage for implementation mistakes that are often difficult to undo, says former 23andMe general counsel Guy Chayoun.

4 Emerging Approaches To AI Protective Order Language

Over the last year, at least five federal district courts have issued or analyzed specific protective order provisions restricting the use of generative artificial intelligence platforms with protected materials, establishing that proactive AI-specific provisions are now standard practice and demonstrating that no single model works for every case, says Joel Bush at Kilpatrick.

Heppner Ruling Left AI Privilege Risk For Lawyers Unresolved

While a New York federal judge’s recent ruling in U.S. v. Heppner resolved a privilege question surrounding client-side artificial intelligence use, it did not address how to mitigate the risks that can arise when confidential information enters the operative context of an AI system used by an attorney, says Jianfei Chen at Quarles & Brady​​​​​​​.

Speed Jigsaw Puzzling Makes Me A Better Lawyer

My passion for speed puzzling — I can complete a 500-piece jigsaw puzzle in under 50 minutes — has sharpened my legal skills in more ways than one, with both disciplines requiring patience, precision and the ability to keep the bigger picture in mind while working through the details, says Tazia Statucki at Proskauer.

Documenting Business Purpose After IRS' 10th Circ. Win

Following the Tenth Circuit’s recent Liberty Global v. U.S. decision, which held the economic substance doctrine does not require a threshold relevancy determination, taxpayers can prepare for potential audits by maintaining contemporaneous documentation and taking other steps that demonstrate the business purpose of transactions, say attorneys at Crowell & Moring.

2 AI Snafus Show Why Attys Can't Outsource Judgment

The recent incident involving Sullivan & Cromwell where citations in a filed motion were fabricated by artificial intelligence, as well as a punitive ruling from the Sixth Circuit in U.S. v. Farris, demonstrate that the obligation to supervise AI has belonged and always will belong to lawyers, says John Powell at the Kentucky School Boards Association.

Improving Well-Being In Law, 10 Years After Landmark Study

An important 2016 study revealed significant substance abuse and mental health issues among lawyers, and while the findings helped normalize the conversation around these topics, a decade later, structural change is still needed, says Denise Robinson at PLI.

Hungary CPAC Funding Probe Could Implicate US Entities

A Hungarian anti-corruption investigation into claims that the former prime minister used taxpayer funds to support the Conservative Political Action Conference could include potential cross-border political and financial dimensions that create multiple touchpoints for U.S. regulatory and enforcement interest, say attorneys at Ballard Spahr.

Mitigating Multistate Risks As California Expands Tax Reach

Though California's new sourcing rules and extension of the pass-through entity election have created uncertainty, practitioners should file protective returns to respect the law's ambiguity and take certain other steps to protect clients from the costs of losing a future audit, says attorney Delina Yasmeh.