Tax Law and International Tax Law

The One Big Beautiful Bill Act transforms the qualified opportunity zone program by removing its 2026 expiration date and introducing enhanced incentives for long-term investments. Investors now face critical decisions about timing their 2026 gains, navigating new zone designations, and structuring funds to maximize tax benefits including a potential 30% basis increase for rural investments.

Proposed IRS regulations would significantly simplify dependent care assistance program (DCAP) nondiscrimination testing by excluding employees who receive no benefits from the 55% average benefits test. This participant-only approach should reduce testing failures and the need for employers to cap highly compensated employees’ elections.

The CHIPS and Science Act's Section 48D offers a 35% tax credit for semiconductor manufacturing investments, but construction must begin by December 31, 2026. Taxpayers can establish construction through physical work or the 5% safe harbor method, with final regulations clarifying that qualifying property on contiguous land may be included if integral to operations.

With the year ending, individuals and married couples have a valuable opportunity to reduce their taxable estates through strategic gifting. Understanding the $19,000 annual gift tax exclusion per recipient, along with unlimited direct payments for medical and educational expenses, can help you maximize tax-efficient wealth transfers before December 31.

The One Big Beautiful Bill Act transforms the qualified opportunity zone program by removing its 2026 expiration date and introducing enhanced incentives for long-term investments. Investors now face critical decisions about timing their 2026 gains, navigating new zone designations, and structuring funds to maximize tax benefits including a potential 30% basis increase for rural investments.

Idaho's newly approved Opportunity Zones offer tax incentives to investors who fund development projects in designated communities across the state. The program connects private capital with real estate and business ventures in areas including Boise, Coeur d'Alene, and Post Falls, potentially bringing new housing, jobs, and economic activity to these regions.

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

While those upward bracket shifts may provide meaningful tax savings on higher-value properties, Washington’s Real Estate Excise Tax (“REET”) structure remains one of the most closely watched elements of transactional planning for commercial and residential property owners and developers. Because Washington applies a tiered, progressive REET rate system for real estate sales, alongside strict rules governing the transfer of controlling interests in entities that own real property, even minor statutory adjustments can drastically alter the economics of a transaction if deal timing or contract mechanics are mishandled.

A New York court has temporarily halted the implementation of New York City's pied-à-terre tax, ruling that the city's notices to homeowners were arbitrary and violated due process rights. The judge ordered the city to restart the entire rollout process while separate lawsuits challenge the tax's legality itself. Despite the stay, property owners who received notices are advised to continue filing for exemptions pending further court guidance.

With the year ending, individuals and married couples have a valuable opportunity to reduce their taxable estates through strategic gifting. Understanding the $19,000 annual gift tax exclusion per recipient, along with unlimited direct payments for medical and educational expenses, can help you maximize tax-efficient wealth transfers before December 31.

The increased federal estate tax exemption under the One Big Beautiful Bill Act may have reduced the number of estates subject to federal estate tax, but for married New York residents, credit shelter trusts remain an important planning consideration.

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.