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Federal
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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.
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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.
Expert Analysis
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Writing Musicals Makes Me A Better Lawyer
My experiences with writing musicals and practicing law have shown that the building blocks for both endeavors are one and the same, because drama is necessary for the law to exist, says Addison O’Donnell at LOIS Law.
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How Fashion, Tech Can Maximize New Small Biz Tax Breaks
Fashion and technology companies, which invest heavily in innovation, should consider taking advantage of provisions in the One Big Beautiful Bill Act that favor small businesses, restructuing if necessary to become eligible for expanded research and experimental expenditure credits and qualified small business stock incentives, says Aime Salazar at Olshan Frome.
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Adapting To Private Practice: From Va. AUSA To Mid-Law
Returning to the firm where I began my career after seven years as an assistant U.S. attorney in Virginia has been complex, nuanced and rewarding, and I’ve learned that the pursuit of justice remains the constant, even as the mindset and client change, says Kristin Johnson at Woods Rogers.
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7 Document Review Concepts New Attorneys Need To Know
For new associates joining firms this fall, stepping into the world of e-discovery can feel like learning a new language, but understanding a handful of fundamentals — from coding layouts to metadata — can help attorneys become fluent in document review, says Ann Motl at Bowman and Brooke.
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Agentic AI Puts A New Twist On Attorney Ethics Obligations
As lawyers increasingly use autonomous artificial intelligence agents, disciplinary authorities must decide whether attorney responsibility for an AI-caused legal ethics violation is personal or supervisory, and firms must enact strong policies regarding agentic AI use and supervision, says Grace Wynn at HWG.
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Opportunity Zone's Future Corp. Tax Benefits Still Uncertain
Despite recent legislative enhancements to the qualified opportunity fund program, and a new G7 understanding that would exempt U.S.-parented multinationals from the undertaxed profits rule, uncertainties over future tax benefits could dampen investment interest in the program, says Alan Lederman at Gunster.
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How GILTI Reform Affects M&A Golden Parachute Planning
Deal teams should evaluate the effect of a recent seemingly technical change to U.S. international tax law on the golden parachute analysis that often plays a critical part of many corporate transactions to avoid underestimating its impact on an acquirer's worldwide taxable income following a triggering transaction, say attorneys at MoFo.
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What To Expect As Trump's 401(k) Order Materializes
Following the Trump administration’s recent executive order on 401(k) plan investments in alternative assets like cryptocurrencies and real estate, the U.S. Department of Labor and the U.S. Securities and Exchange Commission will need to answer several outstanding questions before any regulatory changes are implemented, say attorneys at Cleary.
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Demystifying The Civil Procedure Rules Amendment Process
Every year, an advisory committee receives dozens of proposals to amend the Federal Rules of Civil Procedure, most of which are never adopted — but a few pointers can help maximize the likelihood that an amendment will be adopted, says Josh Gardner at DLA Piper.
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Parenting Skills That Can Help Lawyers Thrive Professionally
As kids head back to school, the time is ripe for lawyers who are parents to consider how they can incorporate their parenting skills to build a deep, meaningful and sustainable legal practice, say attorneys at Alston & Bird.
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Unpacking The New Opportunity Zone Tax Incentive Program
The One Big Beautiful Bill Act brought several improvements to the opportunity zone tax incentive program that should boost investments in qualified funds, including making it permanent, increasing federal income tax benefits in rural areas, redesignating the qualified zones, and requiring more in-depth reporting, says Marc Schultz at Snell & Wilmer.
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Trump Tax Law's Most Impactful Energy Changes
The One Big Beautiful Bill Act's deferral of begin-construction deadlines and the phaseout of certain energy tax credits will provide emerging technologies with welcome breathing room, though other changes, like the increased credit rate for sustainable aviation fuel, create challenges for developers, say attorneys at Weil.
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Adapting To Private Practice: From Texas AUSA To BigLaw
As I learned when I transitioned from an assistant U.S. attorney to a BigLaw partner, the move from government to private practice is not without its hurdles, but it offers immense potential for growth and the opportunity to use highly transferable skills developed in public service, says Jeffery Vaden at Bracewell.