On January 20, 2026, the Internal Revenue Service reopened its group exemption program with the release of Revenue Procedure 2026-8, ending a multi-year suspension on new group exemption applications. The new guidance replaces rules dating back to 1980 and materially changes how group exemptions…
On January 23, 2026, the Internal Revenue Service (the “IRS”) publicly released Field Attorney Advice 20260401F (the “FAA”)1, in which the Office of Chief Counsel rejected a promoted "charitable LLC" structure designed to generate a substantial charitable contribution deduction while allowing…
At a March 19, 2026 status hearing before the U.S. Court of International Trade, U.S. Customs and Border Protection ("CBP") updated the court on its efforts to implement a centralized mechanism for refunding unlawfully collected IEEPA tariffs. The March 19 hearing suggested that CBP has made…
Overview
On March 12, 2026, the U.S. Court of International Trade (“CIT”) issued an order confirming that U.S. Customs and Border Protection (“CBP”) is making “satisfactory progress” towards developing a process to issue refunds of unlawfully collected International Emergency Economic Powers…
During a March 6 settlement conference, U.S. Customs and Border Protection (“CBP”) advised the U.S. Court of International Trade (“CIT”) that CBP is developing a centralized system to process refunds of tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”) but recently…
On March 4, 2026, Judge Richard K. Eaton of the U.S. Court of International Trade (“CIT”) issued a significant ruling holding that all importers of record who paid tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”) are entitled to refunds. The ruling follows the Supreme…
On March 2, 2026, the Internal Revenue Service released Schedule 1‑A (Form 1040) and accompanying updates to the Form 1040 Instructions implementing several new individual tax deductions enacted under the reconciliation legislation commonly referred to as the One, Big, Beautiful Bill Act. Although…
On February 20, 2026, the U.S. Department of the Treasury and the Internal Revenue Service released Notice 2026-16, providing interim guidance on a new 100% special depreciation allowance for certain nonresidential real property, depreciable under MACRS,1 used in manufacturing and other production…
On February 20, 2026, the Supreme Court of the United States issued a landmark decision holding the Trump Administration’s tariffs imposed under the International Emergency Economic Powers Act ("IEEPA") were unlawful and exceeded the authority delegated by Congress. The Court decided, by a 6–3…
Last November, the architecture and engineering firm Guidon – a Krieg DeVault client – became partially employee-owned through an Employee Ownership Trust, or EOT. Guidon’s general counsel, Sonya Seeder, joins Brian Heaton, a longtime Krieg DeVault partner who helps middle- and lower-middle market…
Many importers are filing protective lawsuits in the U.S. Court of International Trade (“CIT”) to preserve potential refund rights relating to tariffs imposed by the Trump Administration under the International Emergency Economic Powers Act (“IEEPA”). This group includes several large, well-known…
On December 18, 2025, President Donald J. Trump issued an Executive Order (the “Order”) directing the federal government to expedite administrative rescheduling of cannabis1 from Schedule I to Schedule III under the Controlled Substances Act of 1970 (the “CSA”).2 The related White House Fact Sheet…
