Federal
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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.
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February 20, 2026
AICPA Urges IRS To Provide R&D Tax Break Guidance
The Internal Revenue Service should clarify the capitalization and amortization election as it applies to the tax break for domestic research and development costs enacted under July's budget law, the American Institute of Certified Public Accountants said in a letter released Friday.
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February 20, 2026
Weekly Internal Revenue Bulletin
The Internal Revenue Service's weekly bulletin, released Friday, included proposed rules clarifying how domestic transportation fuel producers can qualify for the clean energy fuel tax credit under changes made by the Republicans' 2025 budget law.
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February 20, 2026
Trump Imposes Maximum Tariff After Supreme Court Rebuke
President Donald Trump imposed a temporary global tariff with several exemptions hours after the U.S. Supreme Court struck down tariffs imposed under the International Emergency Economic Powers Act, then announced that he would increase the duty to the 15% maximum.
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February 19, 2026
Takeaways From US-India Interim Trade Deal
Trade tensions between the U.S. and India have cooled off after a deal to reduce U.S. tariffs was reached this month, but questions remain about how the interim agreement will materialize and influence future negotiations. Here, Law360 examines several takeaways from the interim deal and efforts toward a broader deal arrangement.
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February 19, 2026
Coalition Asks Court To Back Probe Into IRS-ICE Data Sharing
More discovery is needed into the IRS' data-sharing agreement with Immigration and Customs Enforcement in light of the tax authority recently admitting to breaching its terms, a coalition challenging the agreement told a D.C. federal court in seeking a remand.
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February 19, 2026
Tax Court Slashes $115M Easement Deduction
A partnership is not entitled to a $115 million tax deduction for donating a conservation easement over rural farmland in Louisiana, the U.S. Tax Court ruled Thursday, saying the amount "grotesquely" exceeded the easement's actual value.
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February 19, 2026
Federal Gov't Overrides DC's Rejection Of Tax Breaks
President Donald Trump signed a resolution repealing a Washington, D.C., law that decoupled sections of the city's tax code from federal changes made as part of last summer's budget law.
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February 19, 2026
IRS Wins Dismissal Of FOIA Suit Over Business Tax Records
A man failed to show entitlement to tax records he sought related to his family printing company, a D.C. federal court found Thursday, granting the Internal Revenue Service's motion to dismiss his Freedom of Information Act suit.
Expert Analysis
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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.
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UK's 1st ICSID Claim Shows Bilateral Investment Treaty Reach
For the first time, the U.K. is facing a claim under the International Centre for Settlement of Investment Disputes Convention, underscoring the broader reality that treaty protections are no longer confined to investors in emerging markets, says Philipp Kurek at Signature Litigation.