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Luís C. Calderón Gómez (Cardozo), Is Tax “Law”?, 94 Fordham L. Rev. 1781 (2026): Although taxation remains a hotly contested issue in debates by both politicians and political theo...
The most notable tax law developments of the past month
Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, H.R. 5334, 119th Cong. (2026) (enrolled bill transmitted to the President Sept. 17, 2027); 26 U.S.C. § 62(a)(2)(D), (...
Application of Section 250(b)(3)(A)(i)(VII) to Sales or Other Dispositions of Property, REG-117130-25, 91 Fed. Reg. _____ (proposed Aug. 20, 2026) (to be codified at 26 C.F.R....
Introduction The question of whether the Government can retain an amount collected as tax despite the absence of a lawful statutory liability has repeatedly arisen under the erstwh...
Pellegrino v. United States, No. 1:26-cv-00403, 2026 WL (Fed. Cl. Aug. 20, 2026) In Pellegrino v. United States, No. 1:26-cv-00403 (Fed. Cl. Aug. 20, 2026), Judge Philip S....
Notice of Proposed Rulemaking, REG-119882-25, RIN 1545-BS06, ‘Application of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 to the Refunded Portion...
The problems for the 26th Annual Law Student Tax Challenge are now available. Both the J.D. and LL.M. Division problems, along with the official rules and submission instructions,...
The following law schools are looking to hire in tax law this year (updates from the original post are in bold): Please feel free to email any corrections or additions to taxprofbl...
When Public Law 119-21, commonly referred to as the One Big Beautiful Bill Act (“OBBBA”), was signed into law last year, most families breathed a sigh of relief. The law made the d...
Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance, REG-115145-25, July 31, 2026 The Department of the Treasury...
Taxes don't pause; chaotic policy; larger tax burden; and other highlights from our favorite tax bloggers.
Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss, REG-115646-25, 91 Fed. Reg. _____ (proposed Aug. 26, 2026) The Department of the Treasury and the Internal R...
Estate of Paul Bruyea v. United States, F.4th , No. 25-1563, ECF No. 58 (Fed. Cir. Aug. 31, 2026), reversing Bruyea v. United States, 174 Fed. Cl. 238 (2024). Matthew Christ...
Department of the Treasury, Internal Revenue Service, Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income, N...
As I’ve previously written, in January, the Fifth Circuit ruled in Sirius Solutions, LLLP v. Commissioner that the term “limited partner,” as defined in section 1402(a)(13) (the so...
The economic substance doctrine is a judicial anti-abuse rule—traceable to Gregory v. Helvering—that permits the government to disregard a transaction which technically complies wi...
The Trump administration’s latest volley of tariffs include those imposed under section 301 and those imposed under section 338. The 50% tariffs now in effect on Canada (with more...
Jiangfeng Li (Kirkland & Ellis), Taxation and Expropriation in International Investment Arbitration, 47 U. Pa. J. Int’l L. 158 (2025) In recent decades, there has been a signif...
The Taxation Bill, which contains legislation required to enact tax initiatives announced in this year's Budget.
Soroban Capital Partners LP v. Commissioner of Internal Revenue, Nos. 25-2079 (L), 25-2250 (CON) (2d Cir. Sept. 17, 2026), aff’g 161 T.C. 310 (2023), and T.C.M. (RIA) 2025-52....
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