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February 06, 2026
Partnership Asks Justices To Restore $23M Loss Deduction
A partnership asked the U.S. Supreme Court to revive its $23 million loss deduction involving a Brazilian company, saying in a petition docketed Friday that the Second Circuit wrongly blocked a key argument and that an IRS anti-abuse regulation applied against the partnership should be invalidated.
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February 06, 2026
Gov'ts Want Safeguards For Tax Data Swaps In UN Pact
The United Nations' framework convention on international tax cooperation must ensure that exchanges of taxpayer information take place only when the information is foreseeably relevant to the requesting government's enforcement of tax laws, several representatives said Friday during negotiations.
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February 06, 2026
Buchanan Ingersoll Adds 2 Veteran Tax Pros In DC
Buchanan Ingersoll & Rooney PC has expanded its tax offerings in the nation's capital with two attorneys, including the former co-chair of the tax and private wealth practice at Whiteford Taylor & Preston LLP.
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February 06, 2026
Gunster Brings On Longtime Tax Law Professor In Florida
Florida business law firm Gunster has added an experienced tax law professor to its ranks as of counsel.
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February 06, 2026
Taxation With Representation: Gibson Dunn, S&C, Wachtell
In this week's Taxation With Representation, Elon Musk announces SpaceX's acquisition of his artificial intelligence company xAI, Devon Energy and Coterra Energy agree to merge, and Banco Santander SA acquires Webster Financial Corp.
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February 06, 2026
CPAs Suggest Treasury Scrap Doc Plans For CFC Rules
The U.S. Treasury Department should rethink planned documentation requirements for overseas income allocations, the American Institute of Certified Public Accountants recommended in a letter released Friday, saying the rules may be unnecessarily burdensome.
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February 05, 2026
Russian Scientist's US Wages Not Tax-Exempt, Tax Court Says
The U.S. Department of Energy's payments to a Russian scientist for subatomic particle research in Virginia don't fall under a U.S.-Russia tax treaty covering tax-exempt grants, the U.S. Tax Court held Thursday.
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February 05, 2026
UN Talks Aim To Identify Gaps On Harmful Tax Practices
Representatives of governments asked their colleagues Thursday to pinpoint gaps in ongoing efforts to address harmful tax practices in order to sharpen the United Nations' framework convention on international tax cooperation.
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February 05, 2026
Ga. Law Firm's CTA Challenge 'Hypothetical,' Feds Argue
The U.S. Treasury Department has asked a federal judge to toss a Georgia lawyer's suit alleging that the 2021 Corporate Transparency Act could force him to violate attorney-client privilege, arguing the suit is based on future "hypothetical changes" to the federal policy of nonenforcement.
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February 05, 2026
Hostages Aren't Receiving Tax Relief, TIGTA Says
Recently released hostages did not receive tax relief despite the Internal Revenue Service implementing new procedures to improve the process to provide tax relief to taxpayers wrongfully detained or taken hostage, the Treasury Inspector General for Tax Administration said in a report released Thursday.
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February 04, 2026
Developing Nations See Tax Data Swaps Lacking Reciprocity
Developing countries' requests for taxpayer information are often denied by other countries even as the resource-strapped nations have invested resources in fulfilling incoming requests, government officials said Wednesday.
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February 04, 2026
Tax Group Of The Year: Davis Polk
Davis Polk & Wardwell LLP scored a significant victory for Exxon Mobil in litigation concerning the tax treatment of a major partnership with Qatar and oversaw several other complex, high-stakes transactions, earning it recognition as a 2025 Law360 Tax Practice Group of the Year.
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February 04, 2026
IRS Urges Tax Court To Cut $315M From Siemens Deduction
The Internal Revenue Service defended its slashing of $315 million from a tax deduction that medical giant Siemens claimed on payments from overseas, telling the U.S. Tax Court that rule writers had congressional backing to issue the regulations underpinning the adjustment.
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February 04, 2026
Walmart Wants Relief In CFC Tax Year Deferral
Walmart asked the U.S. Department of the Treasury to temporarily allow certain taxpayers to file a single 13-month return, instead of two separate returns, in the wake of filing changes regarding controlled foreign corporations, according to a letter released Wednesday.
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February 04, 2026
One Essex Court Barrister Sued For Negligence In £32M Case
Billionaire Michael Platt and his hedge fund have accused a One Essex Court barrister of negligence by failing to set out two key appeal arguments in a dispute with tax authorities over a £32.25 million ($44 million) charge.
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February 03, 2026
Dairy Co. Presses UK Court To Revive Tax Deductions On IP
A European dairy giant asked a London appeals court on Tuesday to overturn lower tribunal rulings denying the company tax deductions for the gradual write-off of brands, intellectual property and goodwill following an acquisition.
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February 03, 2026
Gov'ts Resist Binding Treaty Renegotiations In UN Tax Pact
Several governments expressed opposition Tuesday to a proposed requirement for countries to renegotiate bilateral tax treaties in line with principles aimed at fairly allocating taxing rights as part of the United Nations framework convention on international tax cooperation.
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February 03, 2026
IRS Floats Clean Fuel Credit Rules With Foreign Restrictions
The Internal Revenue Service released long-awaited proposed regulations Tuesday clarifying how domestic transportation fuel producers can qualify for the clean energy fuel tax credit under changes made by Republicans' 2025 budget law, including new foreign restrictions on business owners and feedstock sources.
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February 03, 2026
French Gov't Approves Budget With New Corp. Tax Measures
The French government has adopted a budget that targets wealthy people and corporations, including a surtax on the country's biggest companies that is expected to bring in €7.3 billion ($8.6 billion).
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February 03, 2026
Virgin Islands Co. Wants Experts Barred In $11.5M Pricing Row
A U.S. Virgin Islands mortgage company challenging the territorial government over $11.5 million in tax bills asked a federal court Tuesday to exclude expert testimony meant to bolster the government's case that the company wrongly claimed a tax break meant to help the local economy.
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February 03, 2026
HMRC Disputes Danish Wind Farm's Tax Relief At Top Court
Britain's tax authority told the U.K. Supreme Court on Tuesday that a Danish wind farm company can't claim tax relief on pre-development costs for building wind farms, because the costs are too remote from the actual provision of plants and machinery.
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February 02, 2026
Int'l Tax In January: Global Min. Reached, Trade Deals Abound
January was a busy month in international tax, starting with an agreement by nearly 150 countries on a global minimum tax that effectively exempts U.S. companies and culminating with trade deals between Canada and China as well as India and the European Union. Here, Law360 looks at the biggest developments in international tax over the last month.
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February 02, 2026
Trump, Modi Say US-India Trade Deal Reached
President Donald Trump said Monday he reached a trade deal with India following a call with Prime Minister Narendra Modi that includes lowering the tariff rate on Indian goods entering the U.S. from 50% to 18%.
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February 02, 2026
Spencer Fane Expands To New Orleans With Litigation Hire
Spencer Fane LLP announced that an experienced Louisiana-based attorney from Phelps Dunbar LLP has joined the firm's litigation and dispute resolution team as a partner, marking the fast-growing firm's initial foray into the New Orleans market.
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February 02, 2026
India To Provide Tax Break For Cloud Service Providers
India will implement several tax measures designed to attract multinational corporations, including a "tax holiday" for foreign companies that provide cloud services using the country's data services, the government announced.
Expert Analysis
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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.
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Home Canning Makes Me A Better Lawyer
Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.
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Congress Can And Must Enact A Supreme Court Ethics Code
As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.
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What To Make Of Dueling Corporate Transparency Act Rulings
Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.
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The Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan
Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.