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Federal
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April 01, 2026
NYSBA Urges Broader Doc. Rules In Treasury's Sourcing Regs
The U.S. Treasury Department should provide more flexibility for documentation requirements in upcoming guidance for determining the source of payments in certain securities lending transactions, the New York State Bar Association's Tax Section said.
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March 31, 2026
Lobbyist Blocked Rivera After Tying Him To $50M Oil Deal
Republican lobbyist Brian Ballard was "exceptionally angry" and blocked former Florida Congressman David Rivera's number after Rivera insinuated Ballard was tied to a $50 million consulting agreement Rivera signed with the U.S. affiliate of Venezuela's state-owned company, Ballard testified Tuesday in federal court.
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March 31, 2026
DOL's Push To Curb 401(k) Suits Could Face Court Challenges
The U.S. Department of Labor's recent proposal to give retirement plan fiduciaries legal cover to select a broader range of investments aims to reduce ERISA litigation, but attorneys on both sides of the bar say they expect the rule to face legal challenges if finalized as proposed.
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March 31, 2026
$50M Estate Tax Suit Is Late, Plastics Heir Tells Court
A Connecticut federal court should reject the U.S. government's request for a ruling that its $50 million estate tax suit against the heirs of a plastics company owner is timely, one of the heirs argued, saying a decades-old proof of claim didn't pause the clock on collection.
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March 31, 2026
Tariff Refunds On Liquidated Goods To Come, Customs Says
U.S. Customs and Border Protection will enable refunds for imports already liquidated that were subject to tariffs struck down by the U.S. Supreme Court, but that functionality still requires more time to develop, according to an official's declaration filed Tuesday in the U.S. Court of International Trade.
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March 31, 2026
APAs Continue To Drop From 2023 Record, IRS Says
The Internal Revenue Service finalized fewer advance pricing agreements for U.S. multinational corporations in 2025 following peak levels seen in previous years, according to a report from the agency.
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March 31, 2026
IRS Can Collect $371M From Convicted Ex-Atty, 7th Circ. Says
The Internal Revenue Service can assess and collect restitution against a former attorney who served prison time in connection with $7 billion in tax fraud, making the amount immediately due and payable, the Seventh Circuit ruled, saying it was the first circuit court to address the issue.
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March 31, 2026
US Biz Group Asks EU To Limit Tax Abuse Rules' Application
The European Union's anti-tax abuse provisions should be limited to situations where avoidance is a genuine risk, and the 15% global minimum tax should take precedence over the tax avoidance directive when inconsistencies arise, a U.S. business lobbying group told the bloc.
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March 30, 2026
FinCEN Cautions On Benefits Fraud, Floats Tipster Award Plan
The U.S. Department of the Treasury's illicit finance watchdog called Monday for banks to step up monitoring for Medicare and Medicaid fraud, issuing new guidance on flagging suspicious activity, which came as officials also moved to incentivize financial crime reporting with new draft rules to offer tipster rewards.
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March 30, 2026
Eye Doctor Appeals Microcaptive Tax Payments At 5th Circ.
An eye doctor and his wife asked the Fifth Circuit to overturn a U.S. Tax Court decision from last year that affirmed Internal Revenue Service penalties and payments associated with their ophthalmology practice's microcaptive insurance arrangements.
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March 30, 2026
Mother And Son Tax Preparers Accused Of Fraud
A Texas mother and son were indicted for filing fraudulent tax returns through their tax preparation businesses, according to the U.S. Department of Justice, which said the pair tried to get unwarranted refunds by fabricating deductions.
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March 30, 2026
Morgan Lewis Brings On More Tax Pros From Baker McKenzie
Morgan Lewis & Bockius LLP announced Monday it has welcomed a four-member Baker McKenzie team with experience in tax and transfer pricing to the firm's New York office.
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March 30, 2026
Partnerships Fight $150M In Nixed Conservation Deductions
Three partnerships challenged the Internal Revenue Service's rejection of $150 million in tax deductions for their donations of conservation easements, telling the U.S. Tax Court that the determinations should be stricken for being arbitrary and capricious.
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March 30, 2026
Deloitte Must Face Suit Over Philanthropists' Tax Bill
Deloitte lost its bid to avoid a June trial in a dispute over the accounting firm's handling of a $77 million share repurchase and planned charitable transfer that allegedly led to an unexpected tax bill for Boston-area developers and philanthropists William and Joyce Cummings.
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March 30, 2026
Savings From Canceled IRS Contracts Limited, Report Says
The cost savings from hundreds of canceled IRS contracts has been limited or is unknown, in some cases because the money had already been spent, according to a report Monday by the Treasury Inspector General for Tax Administration.
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March 27, 2026
Lawyer Says Contract With Rivera Was For Venezuela's Oil Co.
The $50 million consulting contract that former Florida Congressman David Rivera signed with the U.S. affiliate of Venezuela's state-owned oil company was ultimately funded and controlled by the Venezuelan parent company, the attorney who drafted the document said Friday at Rivera's trial on charges of failing to register as a foreign agent.
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March 27, 2026
$70M Easement Tax Break Sticks After IRS Concedes Lateness
A partnership is entitled to all of its claimed $70 million tax deduction for donating a conservation easement in Louisiana, as the IRS stipulated to missing a notification deadline for disallowing the tax break, according to a decision entered Friday in the U.S. Tax Court.
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March 27, 2026
Atty Asks To Stay Out On Bond Amid $22M Tax Fraud Appeal
A Missouri lawyer convicted of helping perpetrate a $22 million tax scheme is asking to stay out of prison while she appeals, telling a North Carolina federal court that she believes her appeal could be successful on grounds that her indictment was obtained unconstitutionally.
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March 27, 2026
NYC Sheds FDIC's Claim For Silicon Valley Bank Tax Refund
A D.C. federal court said Friday it does not have the authority to order New York City to issue a tax refund sought by the Federal Deposit Insurance Corp. in its capacity as receiver of the failed Silicon Valley Bank.
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March 27, 2026
US Takes $89M Perrigo Economic Substance Fight To 6th Circ.
The U.S. government is appealing a Michigan federal court's conclusion that Perrigo overpaid $89.2 million in taxes, which was based on a finding that the company's transactions with a foreign affiliate had economic substance rather than sole tax avoidance purposes.
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March 27, 2026
Ex-CEO Sues Former NJ AG Over Tossed RICO Case
The former CEO of The Michaels Organization, who was indicted in New Jersey's now-dismissed criminal racketeering case against South Jersey power broker George E. Norcross III, has accused former New Jersey Attorney General Matthew J. Platkin and other members of his office of commencing the prosecution knowing there was no probable cause.
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March 27, 2026
Family Members Get Prison Terms For Tax Refund Scheme
Family members convicted of designing a trust scheme that tried to net $8.5 million in tax refunds were sentenced to prison by a Texas federal judge and ordered to pay back $1.7 million they spent on cryptocurrency and luxuries, according to the U.S. Department of Justice.
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March 27, 2026
IRS Has Spent $16B Of Funding Boost, TIGTA Says
The IRS had spent nearly $16 billion — or 61% — of its Inflation Reduction Act funding boost as of the end of last fiscal year, the Treasury Inspector General for Tax Administration said Friday.
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March 27, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly revenue bulletin, released Friday, included guidance on tax-exempt refunding bonds that would clarify how to request refunds for rebate overpayments.
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March 26, 2026
Venezuelan Leader Says Ex-Fla. Rep Couldn't Get US Meetings
A Venezuelan political opposition leader told jurors Thursday that he connected with former Florida congressman David Rivera to try to secure meetings with high-level U.S. officials in the first Trump administration, but Rivera — who is on trial for allegedly failing to register as a foreign agent — failed to deliver.
Expert Analysis
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Playing Soccer Makes Me A Better Lawyer
Soccer has become a key contributor to how I approach my work, and the lessons I’ve learned on the pitch about leadership, adaptability, resilience and communication make me better at what I do every day in my legal career, says Whitney O’Byrne at MoFo.
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Lessons On Parallel Settlements From Vanguard Class Action
A Pennsylvania federal judge’s unexpected denial of a proposed $40 million settlement of an investor class action against Vanguard highlights key factors parties should consider when settlement involves both regulators and civil plaintiffs, say attorneys at Ropes & Gray.
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Adapting To Private Practice: From ATF Director To BigLaw
As a two-time boomerang partner, returning to BigLaw after stints as a U.S. attorney and the director of the Bureau of Alcohol, Tobacco, Firearms and Explosives, people ask me how I know when to move on, but there’s no single answer — just clearly set your priorities, says Steven Dettelbach at BakerHostetler.
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Mulling Worker Reclassification In Light Of No Tax On OT
The One Big Beautiful Bill Act's no-tax-on-overtime provisions provide tax relief for employees who regularly work overtime and are nonexempt from the Fair Labor Standards Act, but reclassifying employees may lead to higher compliance costs and increased wage and hour litigation for employers, says Steve Bronars at Edgeworth Economics.
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Clean Energy Tax Changes Cut Timelines, Add Red Tape
With its dramatic changes to energy tax credits, the One Big Beautiful Bill Act will reshape project financing and investment planning — and wind and solar developers, especially those in the early stages of projects, face stricter timelines and heightened compliance challenges, says Dan Ruth at Balch & Bingham.
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Playing Baseball Makes Me A Better Lawyer
Playing baseball in college, and now Wiffle ball in a local league, has taught me that teamwork, mental endurance and emotional intelligence are not only important to success in the sport, but also to success as a trial attorney, says Kevan Dorsey at Swift Currie.
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Reform Partly Modernizes Small Biz Stock Gains Exclusion
Changes to the Internal Revenue Code in the One Big Beautiful Bill Act update the qualified small business stock gains exclusion to reflect inflation, but the regime would be more in line with current business realities if Congress had also made the exemption available to additional business structures, says Mark Parthemer at Glenmede.
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How Real Estate Funds Can Leverage Del. Statutory Trusts
Over the last two years, traditional real estate fund sponsors have begun to more frequently adopt Delaware Statutory Trust programs, which can help diversify capital-raising strategies and access to new sources of capital, among other benefits, say attorneys at Polsinelli.
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DOJ Crypto Enforcement Is Shifting To Target Willfulness
Three pending criminal prosecutions could be an indication of how the U.S. Department of Justice's recent digital assets memo is shaping enforcement of the area, and show a growing focus on executives who knowingly allow their platforms to be used for criminal conduct involving sanctions offenses, say attorneys at Gibson Dunn.
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4 Former Justices Would Likely Frown On Litigation Funding
As courts increasingly confront cases involving hidden litigation finance contracts, the jurisprudence of four former U.S. Supreme Court justices establishes a constitutional framework that risks erosion by undisclosed financial interests, says Roland Eisenhuth at the American Property Casualty Insurance Association.
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Practical Implications Of SEC's New Crypto Staking Guidance
The U.S. Securities and Exchange Commission's recent staff guidance that protocol staking does not constitute securities offerings provides a workable compliance blueprint for crypto developers, validators and custodial platforms willing to keep staking strictly limited to protocol-driven rewards, say attorneys at Cahill.
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How Attys Can Use AI To Surface Narratives In E-Discovery
E-discovery has reached a turning point where document review is no longer just about procedural tasks like identifying relevance and redacting privilege — rather, generative artificial intelligence tools now allow attorneys to draw connections, extract meaning and tell a coherent story, says Rose Jones at Hilgers Graben.
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AbbVie Frees Taxpayers From M&A Capital Loss Limitations
The U.S. Tax Court’s June 17 opinion in AbbVie v. Commissioner, finding that a $1.6 billion break fee was an ordinary and necessary business expense, marks a pivotal rejection of the Internal Revenue Service’s position on the tax treatment of termination fees related to failed mergers or acquisitions, say attorneys at Holland & Knight.