Federal

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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. 

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

Expert Analysis

  • Despite Dark Clouds, Outlook For US Solar Has Bright Spots

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    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.

  • Law School's Missed Lessons: Communicating With Clients

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    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.

  • Bill Leaves Renewable Cos. In Dark On Farmland Reporting

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    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.

  • Adapting To Private Practice: From US Rep. To Boutique Firm

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    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.

  • IRS Should Work With Industry On Microcaptive Regs

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    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.

  • CARES Act Fraud Enforcement Is Unlikely To Slow Down

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    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.

  • Spinoff Transaction Considerations For Biotech M&A

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    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.

  • Senate's 41% Litigation Finance Tax Would Hurt Legal System

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    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.

  • Drawbacks For Taxpayers From Justices' Levy Dispute Ruling

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    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.

  • How Energy Cos. Can Prepare For Potential Tax Credit Cuts

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    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.

  • DOJ Has Deep Toolbox For Corporate Immigration Violations

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    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.

  • Trade In Limbo: The Legal Storm Reshaping Trump's Tariffs

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    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.

  • Del. Dispatch: General Partner Discretion In Valuing Incentives

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    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.

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