Federal
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March 26, 2026
Tax Court Upholds Penalty For Microcaptive Arrangement
An Oklahoma oil businessman is on the hook for an accuracy-related penalty for a microcaptive insurance arrangement that lacked economic substance, the U.S. Tax Court said Thursday, deciding an issue that it had deferred in an earlier ruling.
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March 26, 2026
Tax On Wealth Above $50M Proposed By Senate, House Dems
Net worth above $50 million would be subject to a wealth tax of up to 3% that could generate an estimated $6.2 trillion under a pair of bills introduced in the House and Senate on Thursday.
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March 26, 2026
4 Key Questions On Tariff Investigations
The U.S. announced a bevy of new trade investigations this month to underpin a tariff regime intended to replace duties struck down by the U.S. Supreme Court, but questions remain about the fate of deals struck with trading partners and whether importers will face higher tariffs. Here, Law360 examines four questions on the implications of those investigations.
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March 26, 2026
10th Circ. Should Allow Tax Petition Flexibility, Group Says
The Tenth Circuit should follow previous opinions finding that the 90-day deadline for challenging a tax bill is flexible, a taxpayer advocacy group told the circuit court Thursday, throwing its support behind a senior citizen who missed his petition filing deadline by one day.
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March 26, 2026
Fla. Partnership's Gift Of Ala. Land Worth $22M, Court Told
A Florida partnership defended its charitable deduction for a donation of land in Alabama that it said was worth in excess of $22 million, arguing the IRS erred in zeroing out the donation and assessing a deficiency of $8.3 million plus $3.3 million in penalties for 2021.
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March 26, 2026
Tax Court Slashes Deduction For Miss. Land Conservation
A partnership is only entitled to a $2.2 million tax deduction for donating a conservation easement over land in Mississippi, the U.S. Tax Court said Thursday, rejecting its claims that the value was more than 200% higher because the property could have been used for sand and gravel mining.
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March 26, 2026
EU Parliament Approves US Trade Deal With New Conditions
The full European Parliament voted Thursday to approve a set of contingencies on the European Union's trade deal with the U.S. that would implement major tariff cuts, including the ability to suspend the agreement if President Donald Trump raises tariffs or introduces new ones.
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March 26, 2026
11th Circ. Affirms Slashing Tax Breaks For Conservation Gifts
Two partnerships that claimed tens of millions of dollars in tax deductions for protecting 530 acres in Georgia from development grossly overvalued their contributions and rightfully drew penalties from the Internal Revenue Service, the Eleventh Circuit said in affirming a U.S. Tax Court decision.
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March 25, 2026
PTAB Was Never '100% Discretionary,' Rep. Issa Tells Squires
U.S. Patent and Trademark Office Director John Squires is exceeding the authority Congress intended to grant him in the America Invents Act for discretionarily denying patent challenges, the U.S. House of Representatives' intellectual property leader said Wednesday.
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March 25, 2026
Tax-Credit Cliff Sparks M&A Rush For Clean Energy
The looming July cutoff to maintain eligibility for clean electricity investment and production tax credits is sparking a dealmaking spree as smaller developers who are unable to meet the deadline begin looking to sell projects to deeper-pocketed players who can.
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March 25, 2026
Woman Deserves Relief From Tax Prep Fraud, Justices Told
Two taxpayer groups and a tax counsel association urged the U.S. Supreme Court to hear a woman's appeal over liabilities triggered by a fraudulent preparer, arguing the Third Circuit decision in the case misread the fraud exception in the tax assessment statute.
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March 25, 2026
House Tax Panel Advances IRS Overhaul Bills
The House Ways and Means Committee unanimously advanced several bipartisan bills Wednesday that would make administrative changes at the Internal Revenue Service, including legislation that would establish a dashboard to update taxpayers on backlogs and wait times.
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March 25, 2026
Ala. Partnership Defends Nixed $40M Easement Deduction
An Alabama partnership received an appraisal from a qualified firm to establish the value of land donated to a conservation group in 2021, it told the U.S. Tax Court in challenging the IRS' denial of its $39.8 million deduction.
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March 25, 2026
Small-Biz Owners Can't Unfreeze Corp. Transparency Act Case
A Texas federal judge declined to unpause a challenge to the Corporate Transparency Act brought by two small-business owners who the U.S. government argued would have moot claims after the U.S. Treasury Department finalizes new regulations.
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March 25, 2026
Amazon Worker's Settlement Is Taxable, Tax Court Says
A former Amazon.com worker who received a settlement from the company after injuring her back on the job owes taxes on the deal, the U.S. Tax Court said Wednesday, finding the company had paid to settle a wrongful termination claim, not to address her injury.
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March 25, 2026
Sen. Scott Sues Booz Allen, IRS Leaker Over Data Breach
U.S. Sen. Rick Scott, R-Fla., has sued federal contractor Booz Allen Hamilton and a former employee for leaking his tax returns along with a trove of confidential tax data on President Donald Trump and other wealthy people, adding to mounting litigation over the breach.
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March 25, 2026
CBP Rolling Out Online Duty Payments For US Virgin Islands
The U.S. federal government's online portal for electronic payments of duties, taxes and fees on imported merchandise will be rolled out in the U.S. Virgin Islands over the coming months, U.S. Customs and Border Protection said Wednesday.
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March 25, 2026
ABA Urges Flexibility In IRS Voluntary Disclosure Practice
Participation in the IRS' voluntary disclosure practice would likely increase if the agency rethinks its proposed three-month deadline for individuals to file returns and pay liabilities, the American Bar Association's tax section said in a letter publicly released Wednesday.
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March 24, 2026
Rubio Says He Didn't Know Of Friend's Venezuelan Oil Deal
U.S. Secretary of State Marco Rubio would not have met with an old friend, former Rep. David Rivera, to discuss a government transition in Venezuela had he known Rivera's company had a contract with a subsidiary of Venezuela's state-owned oil company, Rubio told jurors Monday.
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March 24, 2026
Goldstein Seeks New Trial, Citing 'A Series Of Legal Errors'
SCOTUSblog founder and appellate icon Thomas Goldstein has filed a lengthy motion for a new trial or acquittal after his conviction on a dozen criminal charges related to tax evasion, alleging his trial was marred by improper jury instructions, improper exclusion of evidence and inadequate evidence, among other things.
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March 24, 2026
IRS Must Address AI Skills Gaps, GAO Says
The Internal Revenue Service has rapidly increased its artificial intelligence use since August 2022, but major staffing reductions at the agency could have a significant impact on its ability to use AI, the U.S. Government Accountability Office said in a report released Tuesday.
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March 24, 2026
FedEx Asks 6th Circ. To Uphold $89M Foreign Tax Credit
FedEx is entitled to an $89 million tax refund because the U.S. Department of the Treasury lacked the authority to issue regulations disallowing foreign tax credits for offset earnings, the company told the Sixth Circuit, asking the court to uphold a lower court ruling.
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March 24, 2026
Tax Penalties Didn't Need Early Approval, Justices Told
A lower-ranking IRS agent was allowed to tell a couple, before getting her supervisor's approval, that she recommended they pay tax penalties, the federal government told the U.S. Supreme Court in urging it to uphold the Eleventh Circuit's reading of a supervisor sign-off requirement.
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March 24, 2026
Tax Agencies Using AI Mainly To Flag Fraud, OECD Says
Tax administrations in member countries of the Organization for Economic Cooperation and Development are using artificial intelligence mainly to detect tax evasion and fraud, the OECD reported Tuesday, saying this is because of the technology's ability to identify patterns and outliers.
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March 24, 2026
Buying Energy Tax Credits Likely A Corp. Norm, Report Says
Around 80% of the largest U.S. corporations that began buying clean energy tax credits three years ago remained active buyers in 2025, signaling the practice becoming standard in corporate tax planning, according to a Tuesday report by a clean energy capital platform.
Expert Analysis
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Rare Tariff Authority May Boost US Battery Manufacturing
Finalizing preliminary tariffs on active anode material from China — the result of a rare exercise of statutory authority finding that foreign dumping hampered the development of a nascent U.S. industry — should help domestic battery manufacturing, but potential price increases could discourage related clean-energy use, say attorneys at MoloLamken.
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Considerations When Invoking The Common-Interest Privilege
To successfully leverage the common-interest doctrine in a multiparty transaction or complex litigation, practitioners should be able to demonstrate that the parties intended for it to apply, that an underlying privilege like attorney-client has attached, and guard against disclosures that could waive privilege and defeat its purpose, say attorneys at DLA Piper.
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The Law Firm Merger Diaries: Making The Case To Combine
When making the decision to merge, law firm leaders must factor in strategic alignment, cultural compatibility and leadership commitment in order to build a compelling case for combining firms to achieve shared goals and long-term success, says Kevin McLaughlin at UB Greensfelder.
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What To Watch As NY LLC Transparency Act Is Stuck In Limbo
Just about a month before it's set to take effect, the status of the New York LLC Transparency Act remains murky because of a pending amendment and the lack of recent regulatory attention in New York, but business owners should at least prepare for the possibility of having to comply, says Jonathan Wilson at Buchalter.
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Despite Deputy AG Remarks, DOJ Can't Sideline DC Bar
Deputy Attorney General Todd Blanche’s recent suggestion that the D.C. Bar would be prevented from reviewing misconduct complaints about U.S. Department of Justice attorneys runs contrary to federal statutes, local rules and decades of case law, and sends the troubling message that federal prosecutors are subject to different rules, say attorneys at HWG.
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8th Circ. Decision Shipwrecks IRS On Shoals Of Loper Bright
The Eighth Circuit’s recent decision invalidating transfer pricing regulations in 3M Co. v. Commissioner may be the most significant tax case implementing Loper Bright's rejection of agency deference as a judicial tool in statutory construction, says Edward Froelich at McDermott.
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Rule Amendments Pave Path For A Privilege Claim 'Offensive'
Litigators should consider leveraging forthcoming amendments to the Federal Rules of Civil Procedure, which will require early negotiations of privilege-related discovery claims, by taking an offensive posture toward privilege logs at the outset of discovery, says David Ben-Meir at Ben-Meir Law.
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Litigation Funding Could Create Ethics Issues For Attorneys
A litigation investor’s recent complaint claiming a New York mass torts lawyer effectively ran a Ponzi scheme illustrates how litigation funding arrangements can subject attorneys to legal ethics dilemmas and potential liability, so engagement letters must have very clear terms, says Matthew Feinberg at Goldberg Segalla.
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SEC's Dual Share Class Approval Signals New Era For ETFs
The U.S. Securities and Exchange Commission's recent approval of the dual share class structure marks a landmark moment for the U.S. fund industry, opening the door for asset managers to benefit from combining mutual fund and exchange-traded fund share classes under a single portfolio, say Ilan Guedj at Bates White and Brian Henderson at George Washington University.
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E-Discovery Quarterly: Recent Rulings On Dynamic Databases
Several recent federal court decisions illustrate how parties continue to grapple with the discovery of data in dynamic databases, so counsel involved in these disputes must consider how structured data should be produced consistent with the requirements of the Federal Rules of Civil Procedure, say attorneys at Sidley.
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What To Do If A Retirement Plan Participant Is Deported
Given recent immigration policy changes in the U.S., many businesses are experiencing employee deportations, but retirement plan administrators should still pay and report benefits to avoid violating the plan, the Employee Retirement Income Security Act or tax reporting requirements, says Teri King at Smith Gambrell.
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Defeating Estoppel-Based Claims In Legal Malpractice Actions
State supreme court cases from recent years have addressed whether positions taken by attorneys in an underlying lawsuit can be used against them in a subsequent legal malpractice action, providing a foundation to defeat ex-clients’ estoppel claims, says Christopher Blazejewski at Sherin and Lodgen.
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The Biz Court Digest: How It Works In Massachusetts
Since its founding in 2000, the Massachusetts Business Litigation Session's expertise, procedural flexibility and litigant-friendly case management practices have contributed to the development of a robust body of commercial jurisprudence, say James Donnelly at Mirick O’Connell, Felicia Ellsworth at WilmerHale and Lisa Wood at Foley Hoag.