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Federal
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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.
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April 06, 2026
IRS' Proposed Voluntary Disclosure Rule Could Be Dissuasive
The IRS has proposed relaxing the 75% civil fraud penalty for participants in its voluntary disclosure program, but a corresponding 90-day deadline for complying with all payment and filing requirements could discourage some taxpayers from coming forward.
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April 06, 2026
Self-Employment Earnings Not Partnership Item, 1st Circ. Told
An energy investment firm urged the First Circuit to disregard a 2009 Federal Circuit decision barring individual partners from seeking refunds of a partnership's income taxes, arguing the opinion has no bearing on its own suit challenging self-employment taxes on individual income.
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April 06, 2026
BNY, Robinhood To Help Roll Out Trump Accounts
The Bank of New York Mellon Corp. will be the federal government's financial agent in helping implement the new tax-advantaged brokerage accounts for children called Trump accounts, the U.S. Treasury Department said Monday.
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April 06, 2026
IRS Expands Business Tax Accounts To Tax-Exempt Groups
The IRS has expanded its online self-service business tax accounts, making them available to tax-exempt organizations, partnerships and federal, state, local and tribal governments, the agency announced Monday.
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April 06, 2026
Activewear Co. Fabletics Sued Again For Tariff Refunds
Fabletics, the activewear company cofounded by actress Kate Hudson, was hit with a proposed class action in California federal court Friday alleging it is improperly pocketing tariff surcharges from customers and is refusing to commit to refunds, weeks after a similar suit was filed in Illinois state court.
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April 06, 2026
IRS Lays Out Opportunity Zone Nominating Guidelines
The Internal Revenue Service released guidance Monday describing the nomination process and eligibility requirements for designated qualified opportunity zones and identifying a list of qualifying areas.
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April 06, 2026
IRS Gets Penalty Approval Wrong, Justices Told
The Internal Revenue Service has improperly interpreted a requirement that an agency supervisor must approve tax penalties before they're asserted against a taxpayer, a couple told the U.S. Supreme Court, urging it to overturn an Eleventh Circuit decision slapping them with $345,000 in accuracy-related penalties.
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April 06, 2026
Int'l Tax In March: Tariff Refunds Coming Amid New Disputes
Tariffs dominated the headlines in March, with the process for refunding those illegally imposed under the International Emergency Economic Powers Act being set up — and customers demanding their cut from businesses. Here, Law360 looks at these and other international tax developments from last month.
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April 06, 2026
Top Court Paves Way To Wipe Out Pol's Bribery Conviction
The U.S. Supreme Court on Monday vacated an appeals court's decision to uphold the conviction of a pardoned former Cincinnati council member for bribery and attempted extortion, effectively greenlighting federal prosecutors' motion to toss the case.
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April 06, 2026
Justices Pass On Oklahoma Tribal Tax Case
The U.S. Supreme Court declined Monday to review an Oklahoma high court ruling that denied tax-exempt status to a member of the Muscogee Creek Nation.
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April 03, 2026
Man Denies Owing Gov't $19M In Biofuel Tax Credit Fraud
A businessman told a Utah federal court that he shouldn't need to pay over $19 million for a forfeited loan from a company central to a $511 million biofuel tax credit fraud because the government's calculations are unjust and a government asset tricked him into withholding payment.
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April 03, 2026
Law360 Announces The Members Of Its 2026 Editorial Boards
Law360 is pleased to announce the formation of its 2026 Editorial Advisory Boards.
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April 03, 2026
Feds Fight Atty's Bond Request Amid $22M Tax Fraud Appeal
A North Carolina federal court should reject a lawyer's bid to remain free on bail while she appeals her conviction for helping perpetrate a $22 million tax fraud scheme because she didn't show that her appeal is likely to change her conviction, federal prosecutors said.
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April 03, 2026
Sanctioned Ex-Broker Pushes To Keep IRS Records Suit Alive
The IRS should not be allowed to withhold records of its investigation into an ex-broker sanctioned by the Financial Industry Regulatory Authority for hiding $1.7 million in tax liens, he told a North Carolina federal court Friday, urging it to let his case against the tax agency proceed.
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April 03, 2026
Taxation With Representation: Cleary, Hogan Lovells, Wachtell
In this week's Taxation With Representation, spice maker McCormick acquires Unilever's foods business, wholesale restaurant food distributor Sysco buys Jetro Restaurant Depot, and private equity giant KKR closes a fund focused on investments in North America.
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April 03, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included the agency's request for suggestions on what to prioritize in an upcoming guidance plan.
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April 03, 2026
Clean Energy Tax Credits Could Gain Ground In Tax Planning
Discounted pricing and risk-limiting contracts are driving large companies to buy clean energy tax credits to lower their IRS bills, a move experts said could become standard in corporate tax planning.
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April 02, 2026
Judge Keeps IRS, Booz Allen In Lawsuit Over Tax Data Leak
A class action against the federal government and contractor Booz Allen Hamilton seeking to hold them accountable for the unauthorized disclosure of a trove of wealthy people's tax returns by a worker on the job with the IRS can move forward, a Maryland federal judge said.
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April 02, 2026
Trump Orders 100% Pharma Tariff, Modifies Metals Duties
Later this year, the U.S. will impose 100% tariffs on imported pharmaceuticals, but drug companies could qualify for reduced tariff rates as low as zero if they agree to invest domestically and enter most-favored-nation drug-pricing agreements with the government, according to an executive order President Donald Trump signed Thursday.
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April 02, 2026
Property Co. Not Liable To Investors In $40M Fraud Suit
A group of investors were told by a Tennessee federal judge that they cannot claim that a property holding company is liable for debts to investors under state statute in a suit accusing a purported green energy outfit and its executives of using promises of extravagant returns to induce investments.
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April 02, 2026
US Tariffs Hiked Consumer Prices By 0.5% To 1%, Report Says
The U.S. government's tariffs imposed last year likely raised consumer prices by 0.5% to 1%, the Yale Budget Lab said Thursday in a report that revised down its initial estimates.
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April 02, 2026
5th Circ. Urged To Rethink Tax Break For Limited Partners
The Internal Revenue Service asked the Fifth Circuit to reconsider its decision allowing business partners with limited liability under state law to be excluded from the federal self-employment tax, saying it threatens the funding of Social Security and Medicare.
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April 02, 2026
$3.6T Of Untaxed Personal Wealth Held Offshore, Oxfam Says
About $3.6 trillion in untaxed household wealth was held offshore in 2024, exceeding the poorer half of humanity's combined wealth by about $1 trillion, Oxfam International reported Thursday.
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April 01, 2026
Facebook Users Lose Cert. Bid In Tax-Data Collection Fight
A California federal judge has refused to certify proposed classes of consumers accusing Meta Platforms Inc. of illegally collecting sensitive financial data from tax preparation websites, finding that the currently proposed classes are "significantly" broad and would likely invite statute-of-limitations defenses that would require "extensive individual inquiries" into each class member.
Expert Analysis
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Despite Dark Clouds, Outlook For US Solar Has Bright Spots
While tariff, tax policy and bankruptcy news seemingly portends unending challenges for the U.S. solar energy industry, signs of continued growth in solar generating capacity and domestic solar manufacturing suggest that there is a path forward, say attorneys at Beveridge & Diamond.
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Law School's Missed Lessons: Communicating With Clients
Law school curricula often overlook client communication procedures, and those who actively teach this crucial facet of the practice can create exceptional client satisfaction and success, says Patrick Hanson at Wiggam Law.
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Bill Leaves Renewable Cos. In Dark On Farmland Reporting
A U.S. Senate bill to update disclosure requirements for foreign control of U.S. farmland does not provide much-needed guidance on how to report renewable energy development on agricultural property, leaving significant compliance risks for project developers, say attorneys at Hodgson Russ.
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Adapting To Private Practice: From US Rep. To Boutique Firm
My transition from serving as a member of Congress to becoming a partner at a boutique firm has been remarkably smooth, in part because I never stopped exercising my legal muscles, maintained relationships with my former colleagues and set the right tone at the outset, says Mondaire Jones at Friedman Kaplan.
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IRS Should Work With Industry On Microcaptive Regs
The IRS should engage with microcaptive insurance owners to develop better regulations on these arrangements or risk the emergence of common law guidance as taxpayers with legitimate programs seek relief in the federal courts, says Dustin Carlson at SRA 831(b) Admin.
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CARES Act Fraud Enforcement Is Unlikely To Slow Down
In the five years since the passage of the Coronavirus Aid, Relief and Economic Security Act, the federal government has devoted massive resources to investigating CARES Act fraud — and all signs suggest the U.S. Department of Justice will continue vigorous enforcement in this area, say attorneys at Kostelanetz.
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Spinoff Transaction Considerations For Biotech M&A
Amid current market challenges, boards and management teams of biotech companies can consider several strategies for maximizing value should a spinoff opportunity arise, but not without significant advance planning and careful implementation, particularly in cases that might qualify as tax-free, say attorneys at Paul Hastings.
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Senate's 41% Litigation Finance Tax Would Hurt Legal System
The Senate’s latest version of the Big Beautiful Bill Act would impose a 41% tax on the litigation finance industry, but the tax is totally disconnected from the concerns it purports to address, and it would set the country back to a time when small plaintiffs had little recourse against big defendants, says Anthony Sebok at Cardozo School of Law.
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Drawbacks For Taxpayers From Justices' Levy Dispute Ruling
The Supreme Court's June decision in Commissioner v. Zuch, holding the Tax Court lacks jurisdiction to resolve disputes where the IRS has stopped pursuing a levy, may require taxpayers to explore new tactics for mitigating the increased difficulty of appealing their liability via collection due process hearings, says Matthew Roberts at Meadows Collier.
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How Energy Cos. Can Prepare For Potential Tax Credit Cuts
The Senate Finance Committee's version of the One Big Beautiful Bill act would create a steep phaseout of renewable energy tax credits, which should prompt companies to take several actions, including conduct a project review to discern which could begin construction before the end of the year, say attorneys at Husch Blackwell.
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DOJ Has Deep Toolbox For Corporate Immigration Violations
With the U.S. Department of Justice now offering rewards to whistleblowers who report businesses that employ unauthorized workers, companies should understand the immigration enforcement landscape and how they can reduce their risk, say attorneys at McDermott.
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Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs
In the final days of May, decisions in two significant court actions upended the tariff and trade landscape, so until the U.S. Supreme Court rules, businesses and supply chains should expect tariffs to remain in place, and for the Trump administration to continue pursuing and enforcing all available trade policies, say attorneys at Ice Miller.
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Del. Dispatch: General Partner Discretion In Valuing Incentives
In Walker v. FRP Investors, the Delaware Court of Chancery recently held that the general partner of a limited partnership breached its obligations when determining the threshold value of newly issued incentive units, highlighting the court's willingness to reconstruct what a reasonable determination of value by a general partner should have been, say attorneys at Fried Frank.