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Federal
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April 10, 2026
Taxation With Representation: Goodwin, CMS, Wilson Sonsini
In this week's Taxation With Representation, Gilead Sciences Inc. acquires clinical-stage biotechnology company Tubulis GmbH, private equity firm Court Square Capital Partners closes a multibillion-dollar fund and Neurocrine Biosciences Inc. buys rare-disease drugmaker Soleno Therapeutics Inc.
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April 10, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service on Friday published its weekly internal revenue bulletin, which included an update on advance pricing agreements for U.S. multinational corporations completed in 2025.
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April 09, 2026
Rivera's Ex-Partner Kept Cut Of $50M Venezuela Contract
Real estate developer and convicted drug trafficker Hugo Perera told jurors Thursday he regretted "1,000%" getting involved with former U.S. Rep. David Rivera in a $50 million contract with a unit of Venezuela's state-owned oil company but admitted he kept his $5 million cut of the deal.
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April 09, 2026
IRS Urged To Clarify Foreign-Owner Rules For Energy Credits
Public power and nuclear associations, along with battery groups, are among stakeholders urging the Internal Revenue Service to clarify foreign ownership rules that could disqualify projects from certain clean energy tax credits, emphasizing that timely guidance is critical to securing project financing.
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April 09, 2026
Gov't Pushes DC Circ. To Unblock IRS-ICE Data Sharing
The D.C. Circuit should remove a block on the IRS' policy of sharing data with immigration authorities, the government said Thursday, arguing that the groups challenging the policy have failed to show irreparable harm.
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April 09, 2026
Judge Tosses Ex-IRS Worker's Suit Alleging Political Firing
A Virginia federal judge tossed a lawsuit by a former Internal Revenue Service employee who claimed she and others were fired in President Donald Trump's sweep of the agency as part of an effort to thwart audits of high-profile entities.
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April 09, 2026
Trade Court Shifts Tariff Refund Proceedings To New Suit
The underlying U.S. Court of International Trade suit serving as the core of the government's development of a refund system for the now-invalidated International Emergency Economic Powers Act tariffs has changed after the original case was dismissed.
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April 09, 2026
IRS Urges Toss Of Revamped Stock Plan Rule Dispute
A Wisconsin federal court should toss a company's remounted suit claiming the Internal Revenue Service secretly passed a rule targeting its stock ownership plan, the government argued, saying the company still has not presented any evidence that the rule exists.
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April 08, 2026
Tax Court Limits Varian's Deemed Dividends Deduction
A deduction that California-based Varian Medical Systems was allowed for deemed dividends must be reduced by the amount of its corresponding foreign tax credit, the U.S. Tax Court held Wednesday.
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April 08, 2026
Tax Preparer Gets 12 Years In Largest-Ever COVID Tax Fraud
A New Jersey tax preparer was sentenced Wednesday to 12 years in prison and ordered to pay $55 million in restitution to the Internal Revenue Service after a jury convicted him of tax fraud in what authorities said was the nation's largest tax fraud case involving COVID-19 pandemic relief money.
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April 08, 2026
IRS Settles FOIA Suit With Sanctioned Ex-Broker
The federal government has settled a suit seeking the IRS' records of its investigation into an ex-broker sanctioned by the Financial Industry Regulatory Authority for hiding $1.7 million in tax liens, according to documents filed in North Carolina federal court Wednesday.
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April 08, 2026
Biz Owner Gets 4 Years, Owes $27M For Tax Credit Scheme
A Nevada federal court sentenced a business owner to four-and-a-half years in prison and ordered her to pay $27 million to the IRS after she submitted nearly $100 million worth of false claims for employment tax refunds meant to help businesses stay afloat during the pandemic.
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April 08, 2026
Oil Giants Owed Far More Tax Abroad Than In US, Report Says
Major U.S. energy companies continued to owe far more taxes abroad than domestically last year, with Exxon Mobil and Chevron each incurring less than 10% of their total liabilities from the federal government, the Financial Accountability and Corporate Transparency Coalition said in a report.
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April 08, 2026
IRS, NJ Woman Settle Refund Row After High Court Loss
The IRS and a New Jersey resident reached a settlement in a $42,000 tax refund suit in federal court nearly a year after the U.S. Supreme Court maintained the agency could eliminate her tax debt using overpayments she claims were improperly retained.
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April 08, 2026
1 Year Later, How Tariffs Have Crept Into Real Estate Contracts
In the year since President Donald Trump's Rose Garden announcement of sweeping worldwide tariffs last April, real estate and construction lawyers have wrestled with how duties or potential duties fit into clients' deals, and sources recently shared more than half a dozen contract examples from the past year with Law360 Real Estate Authority.
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April 08, 2026
Senate Panel To Hold IRS Budget Hearing Next Week
The Senate Finance Committee will hold a hearing April 15 on President Donald Trump's IRS budget proposal for fiscal year 2027 and on the 2026 tax filing season, the panel's chair said Wednesday.
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April 07, 2026
Rivera Kept $50M Venezuela Deal Quiet, Ex-Partner Says
The government's star witness took the stand Tuesday in the criminal case against former U.S. Rep. David Rivera of Florida, telling jurors that Rivera and others kept a $50 million consulting contract with a unit of Venezuela's state-owned oil company quiet because of concerns about how it would be perceived in Miami.
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April 07, 2026
3rd Circ. Affirms NJ Man's Conviction For $40M Tax Fraud
A jury was right to convict a New Jersey man who made $40 million from filing false tax returns in a countrywide securities fraud scheme, the Third Circuit found in upholding the conviction, saying his arguments were not compelling enough to reverse the guilty verdict.
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April 07, 2026
Partnership Wants Tax Court To Reconsider Basis Question
A partnership asked the U.S. Tax Court to reconsider its finding that a company contributing a promissory note for a stake in the partnership had zero basis in the note, saying basis must be determined when a note is contributed, not at its conception.
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April 07, 2026
Partnership Tells Tax Court Settlement Was Long-Term Gain
The $4 million payment a California partnership received in 2021 as part of a settlement should be characterized as long-term gain and not ordinary income, it told the U.S. Tax Court, saying its issue is the same as that in pending cases for prior years.
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April 07, 2026
Sen. Justice Challenges IRS Over $3.6M Tax Penalty
West Virginia Sen. Jim Justice and his wife challenged a $3.6 million tax penalty for claiming what the Internal Revenue Service said was an erroneous refund for $18 million, telling the U.S. Tax Court they were improperly prevented from appealing the fine and can't afford to pay.
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April 07, 2026
IRS Updates Foreign Housing Expense Limits For 2026
The Internal Revenue Service released adjustments Tuesday to the limitation on foreign housing expense deductions and exclusions for 2026.
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April 07, 2026
IRS Met Legal Requirements When Asking For Extensions
The Internal Revenue Service followed the law when asking taxpayers to extend the statute of limitations for assessments, the Treasury Inspector General for Tax Administration said in a report released Tuesday.
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April 07, 2026
Floridian Says Jury Was Required Before $20M FBAR Fine
A dual U.S.-German citizen urged a Florida federal court to reject a magistrate judge's recommendation to uphold a nearly $20 million tax judgment for undisclosed foreign bank account information, contending the judge failed to recognize a recent change in the law about access to jury trials.
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April 07, 2026
DOJ Backs Wrong View Of Accounting Error, 11th Circ. Told
A hedge fund manager challenging the denial of a $1.9 million tax refund related to his private jet told the Eleventh Circuit that the federal government is wrongly parroting a lower court's unreasonable approach to the accounting error underlying the dispute.
Expert Analysis
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Calif. Bar Exam Fiasco Shows Why Attys Must Disclose AI Use
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.
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In 2nd Place, Va. 'Rocket Docket' Remains Old Reliable
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.
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How Attorneys Can Become Change Agents For Racial Equity
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.
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Adapting To Private Practice: From US Attorney To BigLaw
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.
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Opportunity Zone Revamp Could Improve The Program
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.
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The Ins And Outs Of Consensual Judicial References
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.
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The BigLaw Settlements Are About Risk, Not Profit
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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House Bill Tax Tweaks Would Hinder Renewable Projects
Provisions in the budget reconciliation bill recently passed by the U.S. House of Representatives would rapidly phase out clean energy tax credits, constrain renewable energy financing arrangements and impose sweeping restrictions on projects with foreign ties, which may create compliance and supply chain issues for many developers, say attorneys at Paul Hastings.
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Power To The Paralegals: An Untapped Source For Biz Roles
Law firms looking to recruit legal business talent should consider turning to paralegals, who practice several key skills every day that prepare them to thrive in marketing and client development roles, says Vanessa Torres at Lowenstein Sandler.
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How Trucking Cos. Can Keep Rolling Under Tariff Burdens
Recent Trump administration tariffs present major challenges for the transportation and logistics sector — and, in particular, trucking — but providers who focus on operational efficiency, cost control, customer relationships, creative contract structures and unique offerings will stand out from the competition, say attorneys at Benesch.
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Tariff Strategies For The US Renewable Energy Sector
The Trump administration's tariff actions over the last few months are challenging for the renewable energy industry — but there are strategies for contending with the uncertainty, including diversifying supply chains, seeking certification about equipment origins, and adding tariff-related language to supply contracts and offtake agreements, say attorneys at Sheppard Mullin.
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Ch. 7 Marshaling Ruling Rests On Shaky Legal Grounds
In its recent holding in a Chapter 7 bankruptcy case that marshaling may not be applied against the IRS, a Texas federal court misapplied a bankruptcy code section and case law, leaving a draconian decision that could limit the scope of a powerful equitable estate tool, says Brian Shaw at Cozen O'Connor.
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3 Tax Issues Manufacturers Should Watch In 2025 Budget Bill
As Congress works toward a budget reconciliation bill, manufacturing companies should keep a keen eye on proposals to change bonus depreciation, the qualified business income deduction and energy tax credits, which could have a significant impact on capital-intensive industries, say attorneys at Frost Brown Todd.