Tax Law and International Tax Law

When US multinationals establish operations in Europe, determining how much profit should be allocated to a permanent establishment becomes critical. The Authorised OECD Approach requires a functional...

The U.S. Treasury Department and IRS have issued proposed regulations addressing two significant changes to the Internal Revenue Code made under the One Big Beautiful Bill Act: the allocation of foreign income taxes following the repeal of the one-month deferral election for controlled foreign corporations, and the new partial foreign tax credit disallowance on certain previously taxed earnings and profits distributions. These regulations introduce four new elections that provide taxpayers with greater flex

A federal court has vacated IRS Notice 2025-42, which eliminated the Five Percent Safe Harbor for establishing "beginning of construction" for wind and solar projects seeking federal clean energy tax credits. With less than a month before the July 4, 2026 statutory deadline and an expected appeal, developers face critical decisions about whether to rely on the restored safe harbor or continue with existing compliance strategies under uncertainty.

The IRS has released updated pension interest rates and August applicable federal rates while intensifying examinations of noncash charitable contributions. Recent Tax Court decisions have invalidated...

Although IRS enforcement efforts have evolved, estate and gift tax examinations remain an area of focus, particularly for high value estates and sophisticated wealth transfer transactions.

The IRS and Treasury Department have issued new guidance addressing how contributions to Trump Accounts are treated for federal gift tax purposes, creating a safe harbor for qualifying donors. Revenue Procedure 2026-25 establishes specific requirements that allow certain contributions to be treated as completed gifts of a present interest, eligible for the annual gift tax exclusion without requiring Form 709 filing. Understanding these requirements is critical for donors to ensure compliance and avoid unnec

The House has passed bipartisan legislation aimed at protecting taxpayers' rights during IRS disputes, including measures to pause refund claim deadlines and prevent the agency from offsetting...

On August 5, 2026, the Tax Court issued its decision in Reed v. Commissioner, T.C. Memo. 2026-64, sustaining most of the IRS’s determinations against Scott L. Reed, a real estate consultant, and Dr. Stacy N. Reed, a physician, for tax years 2012 through 2015.

The Senate advances critical legislative priorities including NLRB confirmations, Russian sanctions, and government funding measures before its August recess, while House Republicans launch investigations into union political spending and President Trump issues executive orders targeting birthright citizenship. The IRS provides new guidance on overtime tax deductions as Washington prepares for a month-long break.

New York City's pied-à-terre tax took effect on July 1, 2026, imposing a surcharge on certain residential properties that do not serve as a primary residence. A critical question for property owners is whether holding title through a trust or other entity can avoid this surcharge, and the answer depends on how the City applies its "look-through" approach to beneficial ownership. Understanding the primary residence exclusion requirements for trusts and business entities is essential for property owners

Jordan Metzger, a real estate attorney, provides expert analysis on New York City's Pied-À-Terre Tax, explaining how this levy on high-value residential properties affects owners who don't use them as primary residences. The discussion covers the tax's far-reaching implications for property owners, prospective buyers, and co-op boards across the city.

A Florida Circuit Court has ruled that the ballot language for Amendment 3, which proposes changes to homestead property tax exemptions, contains multiple defects that mislead voters about its true effects. The court found that the amendment's title and summary use emotional rhetoric, make improper conclusions, and fail to accurately describe how the measure would impact different classes of property owners and local government taxing authority. The Attorney General now has 10 days to prepare revised ballot