Tax Law and International Tax Law

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Article
Proposed Regulations Implement OBBBA Changes To Income Inclusions Resulting From Sales Of Controlled Foreign Corporation Stock
The Treasury Department has issued proposed regulations fundamentally changing how U.S. shareholders calculate their pro rata share of controlled foreign corporation income when ownership interests vary throughout the year. These regulations implement amendments from the One Big Beautiful Bill Act, introducing daily proration methodologies, mandatory year-end closings for status changes, and new elective provisions for significant ownership variances.
United States Tax
HL
Hogan Lovells Cadwalader
Article
Can You Change An Irrevocable Trust In New Jersey?
In New Jersey, irrevocable trusts can sometimes be modified through a process called decanting, which allows trustees to transfer assets into a new trust with different terms. Understanding when decanting is available under common law, what discretion trustees must have, and what tax and fiduciary risks are involved is essential for anyone administering or benefiting from an irrevocable trust in the state.
United States Tax
SH
Scarinci Hollenbeck LLC
Article
The New Pied-à-Terre Tax In New York City: What Domestic And Foreign Owners Need To Know
New York City has implemented a significant annual surcharge on high-value residential properties that don't serve as primary residences, affecting second-home owners, foreign investors, and luxury property holders. The tax, which took effect July 1, 2026, applies graduated rates based on property valuations and is expected to generate approximately $500 million annually. Property owners face tight deadlines to claim exemptions and must navigate complex documentation requirements to prove primary residence
United States Tax
LB
Lewis Brisbois Bisgaard & Smith LLP
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Article
Can You Change An Irrevocable Trust In New Jersey?
In New Jersey, irrevocable trusts can sometimes be modified through a process called decanting, which allows trustees to transfer assets into a new trust with different terms. Understanding when decanting is available under common law, what discretion trustees must have, and what tax and fiduciary risks are involved is essential for anyone administering or benefiting from an irrevocable trust in the state.
United States Tax
SH
Scarinci Hollenbeck LLC
Article
Education Freedom Tax Credit To Take Effect In 2027: Proposed Regulations Expected Soon
The One Big Beautiful Bill Act introduces Section 25F of the Internal Revenue Code, establishing a federal tax credit of up to $1,700 annually for individual taxpayers who contribute to eligible Scholarship Granting Organizations beginning in 2027. States must voluntarily elect to participate and identify qualifying SGOs, which face federal requirements for scholarship distributions, student eligibility verification, accounting practices, audits and reporting obligations. As the U.S. Department of the Treas
United States Tax
HK
Holland & Knight
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Corporate Tax

Article
Proposed Regulations Implement OBBBA Changes To Income Inclusions Resulting From Sales Of Controlled Foreign Corporation Stock
The Treasury Department has issued proposed regulations fundamentally changing how U.S. shareholders calculate their pro rata share of controlled foreign corporation income when ownership interests vary throughout the year. These regulations implement amendments from the One Big Beautiful Bill Act, introducing daily proration methodologies, mandatory year-end closings for status changes, and new elective provisions for significant ownership variances.
United States Tax
HL
Hogan Lovells Cadwalader
Article
Moving Your LLC Out of Washington: What Property Owners Should Know
Property owners considering relocating their Washington LLCs face important decisions about entity formation, real estate transfer tax exemptions, and foreign registration requirements. Understanding the legal mechanics of transferring real property to out-of-state entities while maintaining tax-exempt status requires careful coordination between legal structure and ownership percentages. The choice between statutory conversion and forming new entities carries distinct implications for compliance, privacy,
United States Commercial
SL
Summit Law Group
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Sales Taxes: VAT, GST

Article
Hearing On Proposed Amendment To LAC 61:I.4372 — Sales & Use Tax Obligations Of Persons Constructing, Repairing Or Altering Immovable Property
The Louisiana Department of Revenue has proposed amendments to its regulation governing sales and use tax responsibilities for contractors and their customers, generating significant public interest. A public hearing has been scheduled to address the substantial volume of comments received regarding these proposed changes.
United States Tax
JW
Jones Walker
Article
Virginia Preserves Data Center Tax Incentive, Adds New Electricity Consumption Tax
Virginia has enacted a groundbreaking tax on electricity consumed by data center operators, imposing a charge of $0.011 per kilowatt-hour effective July 2026 while preserving the state's generous sales and use tax exemption for qualifying equipment. This dual approach aims to generate up to $1.2 billion in revenue over two years while maintaining Virginia's competitive position as the largest data center market in the Western Hemisphere.
United States Tax
HK
Holland & Knight
Article
NCDOR Important Notice: Repeal Of Exemptions For Electricity Used At Datacenters
The North Carolina Department of Revenue has announced the repeal of a significant sales and use tax exemption for electricity purchased by Certified Datacenters, effective August 2026. This change will require datacenter operators to pay combined general sales and use tax rates on electricity purchases and comply with new quarterly reporting requirements, while other datacenter-related exemptions remain intact.
United States Tax
YM
Young Moore and Henderson
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