Tax Law and International Tax Law

Partner Lauren Azebu examines the qualified small business stock (QSBS) gain exclusion rules under Section 1202, exploring the complexities that arise when QSBS is held through pass-through entities. The article analyzes technical issues including ownership limitations, transfer restrictions, and entity conversion strategies, while highlighting areas where guidance remains limited and emphasizing the importance of proactive planning.

H. David Rosenbloom contributes an essay examining United States income tax treaties as part of a commemorative publication honoring Kees van Raad's nearly five decades of teaching international tax law. The essay explores the defense and significance of U.S. tax treaty policy within the broader context of international taxation.

The Second Circuit Court of Appeals has weighed in on a critical tax question affecting partnership and LLC owners, affirming a narrow interpretation of who qualifies as a "limited" partner exempt from self-employment tax. This decision creates potential conflict with the Fifth Circuit's approach, raising questions about whether the Supreme Court will need to resolve the split and provide definitive guidance on this important issue for business owners.

The IRS and Treasury Department have issued proposed regulations addressing the allocation of deductions to foreign-source income under Section 951A, while recent Tax Court decisions clarify critical issues surrounding the Section 245A dividends-received deduction, consolidated return consents, and penalty assessment procedures. These developments carry significant implications for multinational corporations navigating foreign tax credit limitations and domestic loss calculations.

A New York Court of Claims judge has ordered substantial revisions to how New York City administers its Pied-à-Terre tax surcharge, canceling previously issued notices and shifting the burden of proof to the Department of Finance. The ruling requires individualized determinations before notices can be sent and eliminates the controversial exemption application process that had confused thousands of property owners. While the decision doesn't strike down the PAT law itself, it fundamentally restructures

The US Treasury and IRS have issued new guidance targeting ETF tax strategies, including the controversial '351 conversion transaction' that allows investors to defer taxation on appreciated securities. Revenue Ruling 2026-20 and Notice 2026-62 identify multiple strategies as potentially abusive, signaling increased scrutiny of tax deferral mechanisms used by exchange-traded funds and investment partnerships.

Cyber‑enabled cargo theft is a modern form of freight theft in which criminals use digital impersonation, stolen credentials and system manipulation to fraudulently obtain cargo...

The Autumn Budget contained a range of pensions-related announcements with implications for employers and trustees of all occupational pension schemes.

The Chancellor has today announced her highly anticipated autumn Budget.

When it comes to estate planning, even the rich and famous are not immune to costly mistakes. This examination of celebrity estate planning mishaps reveals how iconic figures have fallen victim to oversights leading to legal battles, unintended heirs, and millions in tax losses, offering valuable lessons for legal professionals and individuals alike.

The U.S. tax landscape has undergone dramatic transformation since the Tax Cuts and Jobs Act of 2018, with evolving rules, expiring provisions, and major legislation during President Trump's second term. This analysis examines the six most significant tax developments of the past eight years, from historic estate tax exemption increases to the growing importance of international taxation, and explores what these changes mean for taxpayers, advisors, and business owners navigating today's more stable but sti

A Connecticut Supreme Court decision demonstrates how a $13 million estate tax dispute reinforces a critical planning lesson: formal declarations of domicile carry limited weight when contradicted by an individual's actual living patterns. The case examines how spending more time in Connecticut than Florida, despite obtaining a Florida driver's license and voter registration, led to a substantial tax liability.