Federal
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February 24, 2026
Treasury Eyeing Pillar 2 Safe Harbor Guidance, Official Says
The U.S. Treasury Department expects to negotiate international guidance for the recently agreed-to side-by-side safe harbor under the worldwide corporate minimum tax agreement known as Pillar Two, including updates to the regime's global information return, a Treasury official said Tuesday.
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February 24, 2026
Texas Manufacturer Seeks IRS Refund For Worker Credits
The Internal Revenue Service wouldn't let a manufacturing company correct a typo on a tax return seeking pandemic worker credits and misapplied credits to old tax debt after agreeing not to, the company told a Texas federal court in seeking a $604,000 refund.
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February 24, 2026
DC Circ. Won't Stop IRS From Sharing Data With DHS
Immigrant advocacy groups challenging the legality of an information-sharing agreement between federal immigration authorities and the IRS are not entitled to a court order stopping the tax agency from sharing taxpayer addresses for enforcement purposes, the D.C. Circuit said Tuesday.
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February 24, 2026
IRS Should Strengthen Tax Preparer Oversight, GAO Says
Congress should authorize the Internal Revenue Service to establish professional standards for paid tax preparers to increase oversight on paid tax preparation, the Government Accountability Office reported Tuesday.
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February 23, 2026
FedEx, Bausch, Other Cos. Join Race For Tariff Refunds
FedEx, Bausch & Lomb and L'Oreal are among the companies that raced to the U.S. Court of International Trade on Monday seeking full refunds of the trade duties they paid as a result of the 2025 tariffs that President Donald Trump illegally imposed under the International Emergency Economic Powers Act.
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February 23, 2026
No Substance Found To Homebuilders' $713M Tax Deduction
The IRS was correct to disallow over $713 million of a San Diego partnership's positive basis adjustment in 2012, the U.S. Tax Court held Monday, finding a series of complex transactions were carried out to avoid tax rather than to minimize business risk.
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February 23, 2026
Tax Court Gives Partial Break On Home Sale Gains
A man who told the IRS he realized no gain from two home sales is entitled to a tax break based on some estimated expenses but not a break available for living full time in a home, the U.S. Tax Court ruled Monday.
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February 23, 2026
Senate Dems Aim To Require Refunds Of Illegal Trump Tariffs
Senate Democratic lawmakers introduced legislation Monday to require the federal government to issue refunds to importers for duties paid that were imposed by President Donald Trump under the International Emergency Economic Powers Act, following the U.S. Supreme Court's ruling deeming those measures unlawful.
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February 23, 2026
Tax Court Rejects Son-of-Boss Promoter's Penalty Dispute
A tax shelter promoter behind Son-of-Boss arrangements cannot challenge certain Internal Revenue Service penalties for failing to report the questionable transactions, the U.S. Tax Court ruled Monday, finding he forfeited that right by not participating in the administrative appeals process.
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February 23, 2026
States Back Challenge To IRS Nix Of Wind, Solar Safe Harbor
Sixteen Democratic-led states are backing a legal challenge to an Internal Revenue Service notice eliminating a safe harbor test that large wind and solar projects could use to qualify for clean energy tax credits.
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February 23, 2026
US Customs Stops Collecting Tariffs Starting Tuesday
U.S. Customs and Border Protection will stop collecting the tariffs President Donald Trump illegally imposed under the International Emergency Economic Powers Act beginning at midnight Tuesday, according to guidance sent late Sunday.
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February 23, 2026
$50M Tax Suit Against Plastics Heirs Is Timely, Court Told
The federal government did not miss the deadline for suing the heirs to a plastics company for more than $50 million in estate taxes, the U.S. Department of Justice told a Connecticut federal court Monday, arguing its proof of claim and a probate suit started the clock.
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February 23, 2026
Justices Won't Review Religious Group's Bid Against IRS Lien
The U.S. Supreme Court declined Monday to review a religious organization's constitutional challenge against the Internal Revenue Service over a lien on church property to collect taxes owed by the group's bankrupt founder and her family.
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February 23, 2026
IRS Updates Timeline On Retirement Plan Min. Distributions
The Internal Revenue Service updated its guidance Monday on the timing of required minimum distributions from several types of individual retirement accounts that were amended by a 2022 retirement savings law.
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February 23, 2026
IRS Workers Received Laptops Late, TIGTA Says
Many employees hired by the Internal Revenue Service may have been unable to work effectively because they didn't receive laptops within a week of their start dates, the Treasury Inspector General for Tax Administration said in a report released Monday.
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February 23, 2026
Justices Won't Review Conviction In $1B Renewables Fraud
The U.S. Supreme Court declined Monday to hear an appeal from the convicted leader of a fraudulent $1 billion renewable-energy scheme who contended that he was unlawfully ordered to forfeit a "gobsmacking" $181 million based on joint and several liability.
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February 23, 2026
Justices Won't Review Sentence Of Bitcoin 'Peace Promoter'
The U.S. Supreme Court declined on Monday to review the eight-year sentence that a church founder and self-described "peace promoter" received after he was charged with tax evasion and other crimes tied to a bitcoin operation he founded in 2014.
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February 20, 2026
3 Questions After Justices Sink Trump's Emergency Tariffs
The U.S. Supreme Court's ruling that President Donald Trump's tariffs imposed under the International Emergency Economic Powers Act are unlawful left open questions for practitioners, including how importers may qualify and claim refunds for the illegal duties paid. Here, Law360 examines three open questions following the justices' ruling.
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February 20, 2026
Treasury, IRS Lay Out Eligibility For Depreciation Allowance
The U.S. Treasury Department and Internal Revenue Service released interim guidance Friday on what production property is eligible for the special depreciation allowance under last summer's federal budget law and announced plans to float official regulations on the provision.
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February 20, 2026
Up Next At High Court: Cuban Seizures & Removal Deadlines
The U.S. Supreme Court will kick off its February oral argument session by hearing cases that could expand or limit the availability of damages for U.S. victims of property seized by the Cuban government and a defendant's chance to remove state court cases to federal court.
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February 20, 2026
Full 8th Circ. Won't Revisit 3M's Win Against IRS
The full Eighth Circuit declined to rethink a panel's ruling that held the Internal Revenue Service lacked the statutory authority to allocate nearly $24 million in royalty payments that 3M Co. said it was blocked from receiving under Brazilian law.
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February 20, 2026
Cozen Adds One Big Beautiful Bill Tax Provision Designer
The architect of the tax provision in the One Big Beautiful Bill Act, who spent the past seven years on Capitol Hill and previously served as the top oversight counsel for the House Ways and Means Committee, has joined Cozen O'Connor Public Strategies, the group recently announced.
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February 20, 2026
Western Digital Wants Back $21M In COVID-Era Tax Interest
The IRS improperly charged hard drive maker Western Digital $21 million in interest on its tax debt during a period when interest was supposed to be suspended because of the COVID-19 pandemic, the company told the U.S. Court of Federal Claims in asking for a refund.
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February 20, 2026
Taxation With Representation: Freshfields, Simpson Thacher
In this week's Taxation With Representation, science and technology company Danaher Corp. acquires medical technology company Masimo Corp., Covetrus merges with a unit of fellow animal health technology company Cencora, and private equity firm Leonard Green & Partners LP buys outstanding Mister Car Wash Inc. shares not already owned by LGP affiliates.
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February 20, 2026
Partnership Defends $22M Donation Under 5th Amendment
A Georgia partnership raised arguments under the Fifth, Seventh and Eighth amendments in defending a $22.9 million conservation easement deduction for 2018, saying the denial of the deduction amounts to the government taking property for public use without just compensation.
Expert Analysis
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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.
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Advice For 1st-Gen Lawyers Entering The Legal Profession
Nikki Hurtado at The Ferraro Law Firm tells her story of being a first-generation lawyer and how others who begin their professional journeys without the benefit of playbooks handed down by relatives can turn this disadvantage into their greatest strength.