Federal

  • March 24, 2026

    Tax Penalties Didn't Need Early Approval, Justices Told

    A lower-ranking IRS agent was allowed to tell a couple, before getting her supervisor's approval, that she recommended they pay tax penalties, the federal government told the U.S. Supreme Court in urging it to uphold the Eleventh Circuit's reading of a supervisor sign-off requirement.

  • March 24, 2026

    Tax Agencies Using AI Mainly To Flag Fraud, OECD Says

    Tax administrations in member countries of the Organization for Economic Cooperation and Development are using artificial intelligence mainly to detect tax evasion and fraud, the OECD reported Tuesday, saying this is because of the technology's ability to identify patterns and outliers.

  • March 24, 2026

    Buying Energy Tax Credits Likely A Corp. Norm, Report Says

    Around 80% of the largest U.S. corporations that began buying clean energy tax credits three years ago remained active buyers in 2025, signaling the practice becoming standard in corporate tax planning, according to a Tuesday report by a clean energy capital platform.

  • March 23, 2026

    IRS Concedes To Partnership's $48M Easement Deduction

    A partnership will be entitled to all of a $48.3 million tax deduction for donating a Louisiana conservation easement amid allegations that the IRS improperly backdated documents to impose civil fraud penalties and circumvent the statute of limitations, according to a decision entered Monday in the U.S. Tax Court.

  • March 23, 2026

    Tax Court Filing Deadline Is Not Flexible, 4th Circ. Told

    A man who missed the deadline for challenging his tax bill in the U.S. Tax Court should not be allowed extra time to make his case, the government told the Fourth Circuit on Monday, saying the deadline, despite conflicting views among the circuits, is not flexible.

  • March 23, 2026

    IRS Direct File Had Low Participation, TIGTA Says

    Participation in the Internal Revenue Service's shuttered Direct File pilot program was lower than the agency expected, but there were many opportunities for the agency to improve the user experience, the Treasury Inspector General for Tax Administration said in a report.

  • March 23, 2026

    ND Law Firm Can't Justify Equitable Tolling, IRS Tells 8th Circ.

    A North Dakota law firm that got the U.S. Supreme Court to revive its day-late levy challenge has failed to prove that it deserved equitable tolling of its statute of limitations, the IRS told the Eighth Circuit on Monday.

  • March 23, 2026

    Wyden Questions Leon Black On Epstein Financial Dealings

    The Senate Finance Committee's top Democrat pressed Apollo Global Management co-founder Leon Black in a letter released Monday to provide more information about his financial dealings with Jeffrey Epstein, including why he agreed to pay Epstein $170 million for supposed tax and estate planning services.

  • March 23, 2026

    IRS Lacks Solid Plan To Audit Large Partnerships, TIGTA Says

    The IRS has no solid strategy for auditing large partnerships, resulting in markedly fewer audits as partnerships proliferate and compliance efforts that go nowhere, the Treasury Inspector General for Tax Administration said in a report.

  • March 23, 2026

    Bahamian Law Can't Shield Trusts In $28M Tax Suit, DOJ Says

    A Floridian facing a $28 million tax bill cannot invoke Bahamian law to avoid repatriating funds held in two Bahamian trusts, the U.S. government told a federal court, contending he is "cherry-picking" which jurisdiction's law applies in different situations.

  • March 23, 2026

    Democratic AGs Demand IEEPA Tariff Refund Legislation

    A group of Democratic state attorneys general pushed congressional leaders to enact legislation that would require timely refunds of all duties levied under the now-invalidated International Emergency Economic Powers Act tariffs, including interest.

  • March 23, 2026

    Tax-Evading Farm Biz Owner Hospitalized On Way To Prison

    The owner of a vertical farming business whom federal authorities sought to arrest after he failed to report to prison for tax evasion was hospitalized for a medical emergency on his way to surrender, his wife told a Pennsylvania federal court Monday.

  • March 23, 2026

    IRS Seeks Input On 2025 Law, Deregulation For Guidance Plan

    The U.S. Treasury Department and IRS asked for suggestions Monday on what to prioritize in an upcoming guidance plan, seeking input on tax issues related to the 2025 budget reconciliation law and on opportunities for deregulation.

  • March 20, 2026

    5th Circ. Wipes Out FTC's TurboTax 'Deceptive' Ad Ruling

    The Fifth Circuit on Friday vacated the Federal Trade Commission's cease-and-desist order imposed on Intuit Inc. for its TurboTax advertising that regulators say duped customers into thinking they could file their tax returns for free, saying the agency's in-house decision is unconstitutional, and the dispute must go to federal court.

  • March 20, 2026

    4 Open Questions On Tariff Refund System Development

    U.S. Customs and Border Protection is developing a system to refund tariffs struck down by the U.S. Supreme Court, but it remains unclear whether it will cover the entire gamut of duties President Donald Trump imposed under the International Emergency Economic Powers Act. Here, Law360 examines four open questions surrounding the IEEPA tariff refund system being developed by Customs.

  • March 20, 2026

    DC Circ. Urged To Maintain Block On IRS-ICE Data Sharing

    The D.C. Circuit should keep in place a block on the IRS' policy of sharing data with immigration authorities because the policy is unlawful and a lower court properly weighed the matter, a coalition of nonprofits and labor unions said.

  • March 20, 2026

    $22M Easement With Viable Mine Not 'Abusive,' 11th Circ. Told

    A Georgia conservation easement donor asked the Eleventh Circuit to resurrect a nearly $22 million deduction associated with the land donation, saying the U.S. Tax Court admitted that there was no abuse in the donated transaction.

  • March 20, 2026

    Duane Morris Bolsters SF Team With Hanson Bridgett Hire

    Duane Morris LLP is growing its West Coast team, bringing in a Hanson Bridgett LLP transactions attorney as a partner in its San Francisco office.

  • March 20, 2026

    4th Circ. Dubious Of Undoing Execs' Payroll Tax Convictions

    Two former software executives in North Carolina challenging their conviction for failing to pay employment taxes seemed unlikely to get a reversal in the Fourth Circuit on Friday, with at least one judge hearkening back to his days as a prosecutor as he opined that the pair had essentially been "stealing."

  • March 20, 2026

    Taxation With Representation: Clifford Chance, Davis Polk

    In this Week's Taxation With Representation, Public Storage acquires National Storage Affiliates Trust, 3M teams up with Bain Capital to buy Madison Fire & Rescue, and Mastercard acquires stablecoin infrastructure firm BVNK.

  • March 20, 2026

    Paris Firm Adds Longtime Transfer Pricing Expert

    De Gaulle Fleurance, a Paris firm specializing in business law, has boosted its international tax department with the addition of a longtime expert in transfer pricing.

  • March 20, 2026

    Weekly Internal Revenue Bulletin

    The Internal Revenue Service's weekly bulletin, released Friday, included the proposed revocation of partnership basis-shifting regulations that were meant to curb income tax abuse but have been criticized as burdening businesses.

  • March 19, 2026

    IRS Seeks To Save Increased Penalties In $43M Easement Row

    The owner of a Kentucky historic property should be subject to additional penalties for improperly deducting $1.6 million in expenses associated with a $43 million tax break claim for a preservation easement that the IRS rejected for accuracy reasons, the agency told the U.S. Tax Court.

  • March 19, 2026

    Meta Says IRS Defying Settled Facts In $16B Tax Fight

    The IRS is refusing to agree to the truth of parts of the trial transcript and the U.S. Tax Court's opinion last year in a Facebook transfer pricing case as the social media platform's parent, Meta, disputes a $16 billion tax bill in a related case, the company told the court.

  • March 19, 2026

    Partnership Can't Assert Due Process Right, Tax Court Rules

    A partnership cannot assert Fifth Amendment due process claims on behalf of its individual members to challenge the Internal Revenue Service's centralized audit regime under the Bipartisan Budget Act, the U.S. Tax Court ruled Thursday.

Expert Analysis

  • How AI May Reshape The Future Of Adjudication

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    As discussed at a recent panel at Texas A&M, artificial intelligence will not erase the human element of adjudication in the next 10 to 20 years, but it will drive efficiencies that spur private arbiters to experiment, lead public courts to evolve and force attorneys to adapt, says Christopher Seck at Squire Patton.

  • When Legal Advocacy Crosses The Line Into Incivility

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    As judges issue sanctions for courtroom incivility, and state bars advance formal discipline rules, trial lawyers must understand that the difference between zealous advocacy and unprofessionalism is not just a matter of tone; it's a marker of skill, credibility and potentially disciplinary exposure, says Nate Sabri at Perkins Coie.

  • Attacks On Judicial Independence Tend To Manifest In 3 Ways

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    Attacks on judicial independence now run the gamut from gross (bald-faced interference) to systemic (structural changes) to insidious (efforts to undermine public trust), so lawyers, judges and the public must recognize the fateful moment in which we live and defend the rule of law every day, says Jim Moliterno at Washington and Lee University.

  • Increased Tariffs Create Opportunity To Protect IP Rights

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    Heightened tariffs on certain foreign imports have created operational and fiscal challenges for companies, but the corresponding increase in customs inspections could offer a silver lining of more consistent enforcement against counterfeit and infringing goods, says Andraya Pulaski Brunau at Day Pitney.

  • Dissecting House And Senate's Differing No-Tax-On-Tips Bills

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    Employers should understand how the House and Senate versions of no-tax-on-tips bills differ — including in the scope of related deductions and reporting requirements — to meet any new compliance obligations and communicate with their employees, say attorneys at Greenberg Traurig.

  • Section 899 Could Be A Costly Tax Shift For US Borrowers

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    Intended to deter foreign governments from applying unfair taxes to U.S. companies, the proposal adding new Section 899 to the Internal Revenue Code would more likely increase tax burdens on U.S. borrowers than non-U.S. lenders unless Congress limits its scope, says Michael Bolotin at Debevoise.

  • Calif. Bar Exam Fiasco Shows Why Attys Must Disclose AI Use

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    The recent revelation that a handful of questions from the controversial California bar exam administered in February were drafted using generative artificial intelligence demonstrates the continued importance of disclosure for attorneys who use AI tools, say attorneys at Troutman.

  • In 2nd Place, Va. 'Rocket Docket' Remains Old Reliable

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    The U.S. District Court for the Eastern District of Virginia was again one of the fastest civil trial courts in the nation last year, and an interview with the court’s newest judge provides insights into why it continues to soar, says Robert Tata at Hunton.

  • How Attorneys Can Become Change Agents For Racial Equity

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    As the administration targets diversity, equity and inclusion efforts and law firms consider pulling back from their programs, lawyers who care about racial equity and justice can employ four strategies to create microspaces of justice, which can then be parlayed into drivers of transformational change, says Susan Sturm at Columbia Law School.

  • Adapting To Private Practice: From US Attorney To BigLaw

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    When I transitioned to private practice after government service — most recently as the U.S. attorney for the Eastern District of Virginia — I learned there are more similarities between the two jobs than many realize, with both disciplines requiring resourcefulness, zealous advocacy and foresight, says Zach Terwilliger at V&E.

  • Opportunity Zone Revamp Could Improve The Program

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    If adopted, the budget bill's new iteration of the opportunity zone program could renew, refine and enhance the effectiveness and accountability of the original program by including structural reforms, expanded eligibility rules and incentives for rural investment, say attorneys at Pillsbury.

  • The Ins And Outs Of Consensual Judicial References

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    As parties consider the possibility of judicial reference to resolve complex disputes, it is critical to understand how the process works, why it's gaining traction, and why carefully crafted agreements make all the difference, say attorneys at Pillsbury.

  • The BigLaw Settlements Are About Risk, Not Profit

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    The nine Am Law 100 firms that settled with the Trump administration likely did so because of the personal risk faced by equity partners in today's billion‑dollar national practices, enabled by an ethics rule primed for modernization, says Adam Forest at Scale.

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