Federal
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January 29, 2026
8th Circ.'s Ruling For 3M 'Makes No Sense,' Gov't Says
The Eighth Circuit's ruling that Brazilian law prevented the IRS from reallocating income to 3M from its subsidiary in that country "makes no sense" because the law limits only royalties, not other forms of income, the government argued Thursday in seeking a rehearing by the full court.
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January 29, 2026
What Makes A Good Tax Court Expert? Economists Share Tips
It's not easy being an expert witness in a U.S. Tax Court case. Lawyers ask leading questions and bring up old research; hypothetical scenarios abound, requiring analysis on the fly; and judges have varying levels of expertise, with some seeking detailed explanation and others offended by it.
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January 29, 2026
Minor League Hockey Exec Charged With Tax Fraud In NC
The CEO and minority owner of Charlotte's minor league hockey team is facing tax fraud charges after federal prosecutors in North Carolina said he failed to report more than $4.5 million in income from his charity and skipped filing tax returns altogether in certain years.
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January 29, 2026
Microsemi To Report $144M In Overseas Sales In Settlement
Semiconductor manufacturer Microsemi has agreed to report $144 million in income from sales to its Irish affiliate but will avoid some tax penalties under the terms of a transfer pricing settlement with the Internal Revenue Service, according to a filing in the U.S. Tax Court.
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January 28, 2026
Unions Say FEMA Staff Cuts Threaten Disaster Readiness
A coalition of unions, nonprofit organizations and local governments that are challenging the Trump administration's federal worker layoffs and agency reorganizations asked a California federal judge Tuesday for permission to add the Federal Emergency Management Agency as a defendant, saying ongoing staff cuts threaten its legally mandated responsibility to respond to disasters.
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January 28, 2026
Tobey Maguire Says He Rerouted Fee To Goldstein
"Spider-Man" star Tobey Maguire told the jury Wednesday in Thomas Goldstein's tax fraud trial that he paid $500,000 for his legal services to another poker player the former SCOTUSblog founder owed money to, rather than Goldstein's law firm.
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January 28, 2026
Tax Court Rejects Aventis' Securitizing Debt Assets
Pharmaceutical giant Aventis Inc. is ineligible for a favorable tax treatment on its securitization of financial assets, the U.S. Tax Court ruled Wednesday, finding the company did not comply with statutory requirements and failed to show it was not the beneficial owner of the assets.
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January 28, 2026
Taxpayer Advocate Predicts Errors, Delays This Tax Season
The IRS has demonstrably improved service over the last few tax filing seasons, but errors and delays could be a hallmark of the 2026 season as the agency enacts tax changes while facing a significant staff shortage, the national taxpayer advocate said Wednesday.
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January 28, 2026
Partnerships Fight Nix Of $163M In Conservation Tax Breaks
The IRS wrongly rejected nearly $163 million in claimed tax deductions for conservation easement donations by two Georgia partnerships and then penalized them for negligence and gross valuation misstatements, a partnership representative told the U.S. Tax Court in challenging the determinations.
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January 28, 2026
Tax Group Of The Year: Skadden
Skadden Arps Slate Meagher & Flom LLP's tax practice guided several major cases and deals this past year, including representing drugmaker Amgen Inc. in one of the largest transfer pricing cases litigated last year, earning the firm a spot among the 2025 Law360 Tax Groups of the Year.
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January 28, 2026
Gov't Escapes Bad Faith Sanctions In FBAR Dispute
A New York federal judge declined Wednesday to sanction the U.S. government in its suit against the estate of a businessman over undisclosed offshore bank accounts, holding that his widow failed to show the government acted in bad faith.
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January 28, 2026
11th Circ. Panel Skeptical Of $20.7M Conservation Deduction
Eleventh Circuit judges expressed doubts Wednesday about a partnership's effort to restore its $20.7 million tax deduction for donating a conservation easement, saying the U.S. Tax Court had found that the partnership's managers thought the land was actually worth far less.
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February 03, 2026
Law360 Seeks Members For Its 2026 Editorial Boards
Law360 is looking for avid readers of our publications to serve as members of our 2026 editorial advisory boards.
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January 27, 2026
TIGTA Warns About IRS Hiring Levels Ahead Of Senate Vote
The Treasury Inspector General for Tax Administration raised concerns over the IRS' readiness for the tax filing season Tuesday ahead of Senate votes that would reduce funding, saying that staffing levels could impact the agency's ability to process returns this year.
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January 27, 2026
Wis. Homeowners Challenge Tribal Tax Ruling At 7th Circ.
A group of Wisconsin homeowners is asking the Seventh Circuit to revive its claims that local political jurisdictions of the Menominee Indian Tribe joined forces to increase the homeowners' tax burden, arguing a lower court was wrong to dismiss the case.
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January 27, 2026
Korean Lawmakers Duel Over Trump Tariff Threat Response
President Donald Trump's threat of a tariff hike on South Korea for "not living up to" its trade deal with the U.S. had South Korea's two major parties warring Tuesday over the pact's approval process.
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January 27, 2026
Perrigo Overpaid Tax, Penalties By $89M, Court Finds
Pharmaceutical giant Perrigo overpaid $89.2 million in taxes, penalties and interest during years 2009 through 2012, a Michigan court found in a final judgment issued Tuesday.
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January 27, 2026
Trump's Greenland Tariff Threats Could Backfire On US
The brief turmoil over President Donald Trump's sweeping tariff threats involving Greenland has abated for Europe and the global financial markets, but European governments may be more likely to retaliate with their own tariffs on the U.S. in the future, experts said.
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January 27, 2026
IRS To Offer Tax Refund Options In Phasing Out Paper Checks
Individuals who do not have access to traditional banking services will have an opportunity to receive their tax return refunds through alternative electronic payment methods as the Internal Revenue Service phases out paper checks, the agency said in a fact sheet Tuesday.
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January 27, 2026
Baltimore Atty Ordered To Pay Part Of Client's $3.3M Tax Debt
A Baltimore attorney found personally responsible for paying a client's unpaid taxes owes only part of the debt, a federal magistrate judge said, finding the attorney owed $1.9 million rather than the $3.3 million sought by the government.
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January 26, 2026
Justices' FCC Review Could Reshape IRS Penalty Disputes
The U.S. Supreme Court's upcoming review of a pair of cases questioning the validity of the Federal Communications Commission's penalty authority could have ripple effects that further delineate the Internal Revenue Service's authority to impose penalties.
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January 26, 2026
DOJ Urges 6th Circ. To Uphold IRS Jet Fee Excise Tax
A fractional aircraft ownership company is liable for federal excise taxes, the U.S. Department of Justice told the Sixth Circuit, arguing that the company failed to establish any statutory or equitable defense while urging the appellate judges to affirm a lower court's ruling.
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January 26, 2026
Canada Says China Tariff Agreement Isn't Free Trade Deal
Canadian Prime Minister Mark Carney and the country's foreign affairs minister downplayed the country's recent tariff deescalation with China, indicating Canada will not pursue a free trade agreement with China as President Donald Trump threatened a 100% tariff this weekend over the deal.
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January 26, 2026
IRS Pushes Deadline For IRA Amendments To 2027
The Internal Revenue Service extended the deadline for making amendments to individual retirement arrangements by another year, pushing the date to December 2027, according to guidance released Monday.
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January 26, 2026
Most Avoided Debt Penalties During Pandemic, TIGTA Says
Most taxpayers who were supposed to receive relief from Internal Revenue Service penalties for failing to pay their tax debts during the pandemic received it, the Treasury Inspector General for Tax Administration reported Monday.
Expert Analysis
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3 Key Takeaways From Planned Rescheduling Of Cannabis
An executive order reviving cannabis rescheduling represents a monumental change for the industry and, while the substance will remain illegal at the federal level, introduces several benefits, including improving state-legal cannabis operators' tax treatment, lowering the industry's legal risk profile, and leaving state-regulated markets largely intact, say attorneys at Dentons.
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OFAC Sanctions Will Intensify Amid Global Tensions In 2026
The Office of Foreign Assets Control will ramp up its targeting of companies in the private equity, venture capital, real estate and legal markets in 2026, in keeping with the aggressive foreign policy approach embraced by the Trump administration in 2025, say attorneys at Holland & Knight.
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5 E-Discovery Predictions For 2026 And Beyond
2026 will likely be shaped by issues ranging from artificial intelligence regulatory turbulence to potential evidence rule changes, and e-discovery professionals will need to understand how to effectively guide the responsible and defensible adoption of emerging tools, while also ensuring effective safeguards, say attorneys at Littler.
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Judges On AI: How Courts Can Boost Access To Justice
Arizona Court of Appeals Judge Samuel A. Thumma writes that generative artificial intelligence tools offer a profound opportunity to enhance access to justice and engender public confidence in courts’ use of technology, and judges can seize this opportunity in five key ways.
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Examining Privilege In Dual-Purpose Workplace Investigations
The Sixth Circuit's recent holding in FirstEnergy's bribery probe ruling that attorney-client privilege applied to a dual-purpose workplace investigation because its primary purpose was obtaining legal advice highlights the uncertainty companies face as federal circuit courts remain split on the appropriate test, say attorneys at Proskauer.
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Hot Topics For Family Offices In 2026
For family offices, the throughline of 2026 is disciplined readiness, as navigating impact from the One Big Beautiful Bill Act and platform maturation will be necessary to preserve flexibility and enhance client outcomes, say attorneys at Morgan Lewis.
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The Case For Emulating, Not Dividing, The Ninth Circuit
Champions for improved judicial administration should reject the unfounded criticisms driving recent Senate proposals to divide the Ninth Circuit and instead seek to replicate the court's unique strengths and successes, says Ninth Circuit Judge J. Clifford Wallace.
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How Changes At The IRS Will Affect Tax Controversy In 2026
Taxpayers will need to adjust approaches to dealing with the IRS in 2026, as the agency is likely to shift its audit strategies and increases reliance on technology following the significant reductions in funding and personnel last year, say attorneys at Crowell & Moring.
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5 Tariff And Trade Developments To Watch In 2026
A new trade landscape emerged in 2025, the contours of which will be further defined by developments that will merit close attention this year, including a key ruling from the U.S. Supreme Court and a review of the U.S.-Mexico-Canada Agreement, says Ted Posner at Baker Botts.
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4 Developments That Defined The 2025 Ethics Landscape
The legal profession spent 2025 at the edge of its ethical comfort zone as courts, firms and regulators confronted how fast-moving technologies and new business models collide with long-standing professional duties, signaling that the profession is entering a period of sustained disruption that will continue into 2026, says Hilary Gerzhoy at HWG Law.
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How Fractional GCs Can Manage Risks Of Engagement
As more organizations eliminate their in-house legal departments in favor of outsourcing legal work, fractional general counsel roles offer practitioners an engaging and flexible way to practice at a high level, but they can also present legal, ethical and operational risks that must be proactively managed, say attorneys at Boies Schiller.
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How OECD Tax Update Tackles Mobile Workforce Complexity
The Organization for Economic Cooperation and Development’s recently updated model tax convention — a recalibration of international tax principles in response to an increasingly mobile workforce — should prompt companies to reevaluate cross-border operations, transfer pricing policies and tax controversy strategies, say attorneys at Eversheds.
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A Uniform Federal Rule Would Curb Gen AI Missteps In Court
To address the patchwork of courts’ standing orders on generative artificial intelligence, curbing abuses and relieving the burden on judges, the federal judiciary should consider amending its civil procedure rules to require litigants to certify they’ve reviewed legal filings for accuracy, say attorneys at Shook Hardy.