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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Tax Court Ruling Signals Cross-Border Loan Scrutiny
The U.S. Tax Court’s recent decision in Aventis v. Commissioner compounds ongoing regulatory focus on debt originations and should prompt practitioners to assess their existing cross-border lending structures for potential exposure to U.S. federal income tax, say attorneys at Eversheds.
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Lessons From Justices' Split On Major Questions Doctrine
The justices' varied opinions in Learning Resources v. Trump, which held the International Emergency Economy Powers Act did not confer the power to impose tariffs, offer a meaningful window into the U.S. Supreme Court's perspective on the major questions doctrine that will likely shape lower courts' approach to executive action challenges, say attorneys at Venable.
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Resilience Planning As Nat'l Security Shifts Tech Import Policy
In response to a sustained reorientation of U.S. trade policy around national security considerations, businesses reliant on processed critical minerals must closely monitor diplomatic negotiations and the potential expansion of trade measures, incorporating contingency planning into procurement and long-term investment strategies, says attorney Sohan Dasgupta.
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How The New Tariff Landscape May Unfold
To replace tariffs formerly imposed under the International Emergency Economic Powers Act, the administration will rely on a patchwork of statutes, potentially leading to procedural challenges and a complex tariff landscape with varying levels, durations and applicability, says Joseph Grossman-Trawick at King & Spalding.
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What Orgs. Should Note In IRS Group Tax Exemption Overhaul
In a significant update, the IRS Revenue Procedure 2026-8 shows that the group exemption program is moving into a new regulatory era involving more uniformity, oversight and compliance obligations, and early action is key to preserve group exemption status and avoid disruption for subordinate organizations, says Ravi Sundara at Spencer Fane.
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How Banks Can Apply FinCEN Beneficial Ownership Relief
A recent Financial Crimes Enforcement Unit order limiting the circumstances under which banks should identify and verify beneficial owners may allow banks to tailor their approach to verification compliance, but only after reviewing customer due diligence policies and evaluating alignment with their risk profiles, say attorneys at Cleary.
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Parsing Clarifications On Foreign Entity Rules For Tax Credits
Recent U.S. Internal Revenue Service and Treasury Department guidance answers taxpayer questions on several key foreign entity rules under the One Big Beautiful Bill Act, but questions remain over transactions with companies that have ties to covered nations such as Iran, say attorneys at Cleary.
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Aligning Microsoft Tools With NYC Bar AI Recording Guidance
The New York City Bar Association’s recently issued formal opinion, providing ethical guidance on artificial intelligence-assisted recording, transcription and summarization, raises immediate questions about data governance and e-discovery for companies that use Microsoft 365 and Copilot, say Staci Kaliner, Martin Tully and John Collins at Redgrave.
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Preferred Equity Monetizations Unlock Energy Tax Credits
As private capital funds more energy and infrastructure projects, preferred equity monetization structures — combining elements of tax credit transfers and tax equity partnership-flip transactions with hybrid capital structures — can help project sponsors monetize federal tax credits, access private capital markets and gain structuring flexibility, say attorneys at Willkie.
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5 Different AI Systems Raise Distinct Privilege Issues
A New York federal court’s recent U.S. v. Heppner decision, holding that a defendant’s use of Claude was not privileged, only addressed one narrow artificial intelligence system, but lawyers must recognize that the spectrum of AI tools raises different confidentiality and privilege questions, says Heidi Nadel at HP.
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After Learning Resources: A Practical Guide For US Importers
Following the U.S. Supreme Court's Feb. 20 decision in Learning Resources v. Trump, U.S. importers and consumers on whom tariffs were imposed under the International Emergency Economic Powers Act can seek relief through existing administrative procedures or a yet-to-be-determined bespoke refund mechanism, and should plan for more changes in the tariff landscape, say attorneys at Baker Botts.
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AI-Assisted Arbitration Needs Safeguards To Ensure Fairness
As tribunals and arbitral institutions increasingly use artificial intelligence tools in their decision-making processes, clear disclosure standards and procedural safeguards are necessary to ensure that efficiency gains do not erode the fairness principles on which arbitration depends, says Alexander Lima at Wesco International.
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AI-Generated Doc Ruling Guides Attys On Privilege Risks
A New York federal court's ruling, in U.S. v. Heppner, that documents created by a defendant using an artificial intelligence tool were not privileged, can serve as a guide to attorneys for retaining attorney-client or work-product privilege over client documents created with AI, say attorneys at Sher Tremonte.