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Federal
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June 12, 2026
Court Partly Dismisses Co.'s COVID Credit Reg Challenge
A company that provides payroll services to healthcare providers failed to prove it was entitled to injunctive relief that would bar the IRS from enforcing guidance on the employee retention tax credit, an Ohio federal court said, dismissing three of the company's claims.
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June 12, 2026
2nd Circ. Doubts Tax Plea Advice Misled Man On Deportation
A skeptical Second Circuit judge on Friday told a Connecticut attorney to stop saying his client was "affirmatively misled" while pleading guilty to tax evasion charges, hinting a written plea agreement and verbal warnings from a federal judge were probably sufficient to advise the client he could be deported.
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June 12, 2026
Global Minimum Tax Was A Bad Bargain, Tax Pros Say
The global minimum tax known as Pillar Two had the paradoxical goal of increasing countries' taxing power by having them cede some of their authority to set corporate rates — and ultimately would have hurt both wealthy and developing nations, tax specialists said at a conference Friday.
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June 12, 2026
IRS Must Revisit Whistleblower Award Denial, DC Circ. Rules
The D.C. Circuit said Friday that the Internal Revenue Service must reconsider a whistleblower's claim that her information helped the agency collect taxes on more than $31 million in corporate income, reversing a U.S. Tax Court ruling that sided with the IRS.
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June 12, 2026
Biz Groups Back Liberty Global In $2.4B Tax Substance Fight
The Tenth Circuit should reconsider its decision denying telecommunications company Liberty Global a $2.4 billion income deduction, the U.S. Chamber of Commerce and other groups said, arguing the court excessively broadened a rule that is meant to disallow tax benefits in limited situations.
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June 12, 2026
Fox Rothschild Hires Tax Atty From McDermott In DC
Fox Rothschild LLP has hired a former tax attorney from McDermott Will & Schulte LLP who is bringing his advisory practice focused on sophisticated tax planning and structuring matters to the Washington, D.C., team, the firm announced Thursday.
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June 12, 2026
Taxation With Representation: Gibson Dunn, Davis Polk, S&C
In this week's Taxation With Representation, SpaceX prices a $75 billion initial public offering at its designated price range, Apollo Global Management leads a capital commitment for a Broadcom initiative to build artificial intelligence infrastructure for companies including Anthropic, and pharma giant GSK acquires cancer therapy specialist Nuvalent.
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June 12, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, issued Friday, included guidance clarifying that proposed rules from 2025 regarding foreign sovereign wealth fund investment in the U.S. would not apply retroactively to the existing holdings of foreign governments.
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June 11, 2026
Revised Microcaptive Rules Still Violate APA, 6th Circ. Told
A microcaptive insurance advisory firm asked the Sixth Circuit on Thursday to overturn a Tennessee federal court's ruling that a set of revised IRS rules requiring taxpayers to disclose some microcaptive arrangements doesn't violate the Administrative Procedure Act.
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June 11, 2026
Investors Say Energy Co. Sold Fraudulent Tribal Tax Credits
Two investors accused an energy company of selling them fraudulent tax shelters marketed as tribal tax credits for $600,000 in a complaint filed in an Arkansas federal court.
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June 11, 2026
Auto Parts Biz Says Freight Co. Duped It Into Container Fraud
A Michigan-based importer and seller of aftermarket auto parts that was stuck with added costs from U.S. Customs and Border Protection related to empty shipping containers has sued its freight-forwarding contractor, claiming it was tricked into facilitating a fraud scheme.
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June 11, 2026
Senate Bill Would Increase Stock Buyback Tax
A 4% excise tax would be imposed on stock buybacks under legislation introduced by several high-ranking Senate Democrats, including Senate Minority Leader Chuck Schumer, on Thursday.
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June 11, 2026
FedEx Tells 6th Circ. Recent Rulings Back $89M Tax Refund
FedEx's case for an $89 million tax refund is supported by a decision in the U.S. Tax Court that outlined a formula for disallowing foreign tax credits and a Sixth Circuit decision about how to view the purpose of tax legislation, the company told the Sixth Circuit.
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June 11, 2026
Man Agrees To $10M Tax Bill Over Unreported Biz Income
A man found to have received income by using his company's cash as his own is on the hook for approximately $10.4 million in taxes and penalties, according to agreed-upon computations the taxpayer and the U.S. government filed in the U.S. Tax Court.
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June 10, 2026
4 Key Questions Surrounding US Forced Labor Tariff Rates
New proposed U.S. tariffs meant to address goods tied to forced labor are likely to create new administrative burdens for importers, from new compliance hurdles domestically to the potential for retaliatory measures by trading partners on U.S. goods shipped abroad, attorneys told Law360.
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June 10, 2026
Income Tax Underpayment Due To Fraud, Tax Court Rules
A couple's income tax underpayment stemmed from fraud, the U.S. Tax Court said in an order Wednesday, affirming the Internal Revenue Service's income tax deficiencies and civil fraud penalties.
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June 10, 2026
Treasury Previews Guidance For Scholarship Tax Credit
Guidance is coming soon on a new federal scholarship tax credit to help prepare for its planned launch at the start of 2027, including definitions of certain terminology and certain reporting requirements, the U.S. Department of the Treasury said Wednesday.
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June 10, 2026
IRS Lists Counties Eligible For Energy Community Credit
The Internal Revenue Service on Wednesday provided a list of eligible energy communities that can claim the Inflation Reduction Act's energy community bonus credit.
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June 10, 2026
Amgen Can't Amend Petition To Address Potential Double Tax
Drugmaker Amgen isn't entitled to amend its petition to protect against possible double taxation after an eight-week trial and briefing in its income-allocation case already have been completed, the U.S. Tax Court said, noting that the trial concluded in January 2025.
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June 10, 2026
Former Sen. Tim Scott Staffer Joins K&L Gates In DC
A former committee staff director for U.S. Sen. Tim Scott, R-S.C., has been hired at K&L Gates LLP, the firm announced Wednesday, following her time as a senior vice president with a bipartisan government relations and lobbying firm.
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June 10, 2026
AI Startup Says Worker Must Arbitrate Misclassification Suit
A hiring startup that supplies workers to train artificial intelligence models for OpenAI, Anthropic and Meta urged a Texas federal judge to send a proposed class action alleging worker misclassification to individual arbitration, arguing the named plaintiff signed seven agreements requiring it.
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June 10, 2026
Perkins Coie Atty Talks Tax Law 'Tension' In Data Center REITs
A real estate investment trust can be an attractive business model for data centers, but complying with federal REIT rules is tricky for properties with digital infrastructure, given their unique needs, according to a Perkins Coie LLP partner.
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June 10, 2026
Partnership Agrees To Zero Out $56M Deduction For Land Gift
A partnership claiming a $56 million tax deduction for its 2019 donation of more than 200 acres in Louisiana agreed with the IRS that its deduction for the gift should be zero but that it is entitled to an "other deduction" of nearly $11 million for the same year.
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June 10, 2026
5th Circ. Rejects Gov't Bid To Revisit Home Distilling Ban
The Fifth Circuit denied the U.S. government's request for the full court to review a three-judge panel's April opinion finding the tax code's ban on distilling whiskey at home unconstitutional after another appeals court's opposite conclusion affirmed the ban.
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June 09, 2026
Challengers Of Trump's 'Slush Fund' Want Proof Plan Is Dead
Plaintiffs challenging what they call President Donald Trump's proposed $1.8 billion "slush fund" in Virginia and Washington, D.C., federal court on Tuesday expressed doubt that the administration's plan to pay victims of "lawfare and weaponization" is truly "not moving forward" as the acting attorney general has claimed.
4 Questions As Gov't Appeals Illegal Tariff Refund Suit
The government's appeal of an order requiring immediate refunds for tariffs that were deemed illegal by the U.S. Supreme Court earlier this year is the latest obstacle for importers forced to stall investments in new products and brace for a longer wait for their refunds in response.
Judge Demands Proof $1.8B Trump Settlement Fund Is Dead
A Virginia federal court judge ordered the federal government Friday to submit in writing that it won't create a $1.8 billion payment fund to settle President Donald Trump's tax leak suit against the Internal Revenue Service.
Fed. Circ. Pauses Trade Court's Limited Block Of Global Tariffs
The Federal Circuit halted a U.S. Court of International Trade ruling prohibiting the government from collecting temporary global tariffs on two retailers and the state of Washington while it considers whether those duties are lawful, according to an order Thursday.
Featured Stories
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4 Questions As Gov't Appeals Illegal Tariff Refund Suit
The government's appeal of an order requiring immediate refunds for tariffs that were deemed illegal by the U.S. Supreme Court earlier this year is the latest obstacle for importers forced to stall investments in new products and brace for a longer wait for their refunds in response.
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4 Key Questions Surrounding US Forced Labor Tariff Rates
New proposed U.S. tariffs meant to address goods tied to forced labor are likely to create new administrative burdens for importers, from new compliance hurdles domestically to the potential for retaliatory measures by trading partners on U.S. goods shipped abroad, attorneys told Law360.
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Developers Stumped By Energy Credits' Foreign Debt Limits
Developers seeking to finalize projects financed with clean energy tax credits and several loans are hitting a roadblock in demonstrating to the IRS that their debt has limited ties to prohibited foreign entities, a requirement for qualifying for the incentives.
Expert Analysis
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Cow Horse Makes Me A Better Lawyer
Moving an unwilling 800-pound cow while riding a horse at high speed is exhilarating, a little unhinged and, at least for me, a surprisingly effective training ground for litigation — both demand focus, preparation over rigid planning and the willingness to act despite fear, says Ashley Zitrin at Glenn Agre.
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Checking For AI Errors Is Now A Two-Way Street
A handful of recent federal and state cases demonstrate the importance of checking for errors generated by artificial intelligence not only in your own court submissions, but also your opponent's, as well as when catching opposing counsel's AI mistakes could result in an award for attorney fees, says Tamara Barago at Hollingsworth.
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5 Things Associates Must Ask About Their Firm's Merger Plan
The associates who navigate law firm mergers best ask the right questions early, such as inquiring about partners' plans, to assess how the merger could affect their workflow and career path, says Jackie Bokser-LeFebvre at Major Lindsey.
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2 'Rocket Dockets' And The Rules That Propel Them
The fastest civil trial courts in the country are currently in the Eastern District of Virginia and the Southern District of Florida, and their chief judges provide insights into the court rules that keep them ahead, says Robert Tata at Hunton.
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Key Legal Considerations For Data Center Battery Storage
Battery energy storage systems have become essential infrastructure for data center development — but as trade, energy and tax policies continue to shift, companies operating in this space must understand the importance of supply chain requirements and industry-tailored contracts, says RJ Colwell at Davis Graham.
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Your Next Litigation Hold Should Cover AI Chat Logs
The Delaware Chancery Court’s recent decision in Fortis Advisors v. Krafton to treat a CEO’s artificial intelligence chats as substantive evidence is being read as a discovery warning to litigators, but there is a second duty-to-preserve lesson that is especially pertinent to in-house counsel, say attorneys at Faegre Drinker.
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Cannabis Policy Shift May Reshape Banking, Insolvency Risks
The Trump administration's cannabis rescheduling initiative aims to correct classification that had rendered federal banking, tax administration and insolvency law incoherent, and will begin to restore some alignment between federal law and the economic reality of the marijuana industry, says Richard Ormond at Buchalter.
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Studying Foreign Languages Makes Me A Better Lawyer
Studying Italian and Japanese has shown me that learning a new language can benefit a legal career in several ways, including by demonstrating the importance of approaching problems from a fresh perspective and the value of practicing patience with colleagues and clients, says Anna King at Genworth Financial.
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Sold Inventory May Drive Tax Treatment Of Tariff Refunds
Companies determining the tax treatment of refunds expected following the U.S. Supreme Court's February decision invalidating tariffs imposed under the International Emergency Economic Powers Act should consider whether the tariff costs have already reduced their income considering the cost of goods sold, say attorneys at McDermott.
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Adapting To AI-Driven Scrutiny Of Foreign Asset Disclosures
As the government expands AI-driven, cross-agency fraud detection, foreign asset disclosure should be viewed as part of a broader, data‑driven enforcement ecosystem that prioritizes consistency, documentation and proactive governance, says Logan Koehring at FBT Gibbons.
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Sizing Up The Rescheduling Hurdles Medical Pot Cos. Face
The Justice Department’s recent lowering of certain medical marijuana products to Schedule III means operators — particularly those simultaneously offering federally illegal adult-use cannabis — must implement greater structural discipline to navigate an increasingly fragmented legal landscape if they hope to benefit from new tax deductions and access to capital, say attorneys at Akerman.
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Tax Teams Get No Bright-Line Rule From AI Privilege Cases
Three recent appellate decisions that considered artificial intelligence in the context of attorney-client privilege protections illustrate that taxpayers and tax practitioners alike must consider the pertinent facts on a case-by-case basis, with particular attention to confidentiality, disclosure risk and system design, say attorneys at Morgan Lewis.
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NY Times Word Puzzles Make Me A Better Lawyer
Every morning I let The New York Times humble me with word games, which offer a chance to recalibrate my brain before the day's chaos arrives and remind me that a solution — whether to a puzzle or employment law issue — almost always exists once I find the right angle, says Amy Epstein Gluck at Pierson Ferdinand.