Tax Law and International Tax Law

Companies often grant equity incentives to their executives and key employees in the form of restricted equity.

Washington State has enacted a new 9.9% income tax on individual earnings exceeding $1 million annually, effective January 2028.

Employer-issued recourse promissory notes allow employees to acquire equity without immediate cash outlay, but they create personal liability regardless of stock performance. This analysis examines the strategic advantages, tax implications, and significant risks that both companies and employees face when using this compensation structure.

African governments are rapidly modernising their approach to tax and customs in the resources sector. Fiscal tools, tighter compliance frameworks and procedural reforms are reshaping investment and operational conditions across the continent.

Keith Richardson, the newly appointed Executive Director of the Multistate Tax Commission, discusses his unconventional journey from community banking to leading state and local tax administration in Philadelphia and DC. He shares his vision for the MTC's future, focusing on organizational excellence, expanded engagement with local jurisdictions, and addressing emerging SALT policy challenges including digital goods taxation and wealth taxes.

The Qualified Opportunity Zone program has undergone a major transformation with the passage of the One Big Beautiful Bill, shifting from a temporary framework to a permanent fixture with enhanced incentives and new rural investment categories.

Global families investing in U.S. real estate face critical tax structuring decisions at acquisition that can either preserve wealth or create decades of avoidable exposure. How should international investors structure their U.S. property purchases to minimize estate tax, FIRPTA obligations, and state tax compliance issues before closing the deal?

International tax reform in 2026 introduced structural changes that affect how global income is classified, included, deducted, and limited.

Indirect tax obligations are evolving rapidly as governments modernize their rules for the digital economy. If your organization is working across borders...

Portability of estate and gift tax enables a surviving spouse to inherit any unused portion of their deceased spouse's federal estate and gift tax exemption, potentially doubling the exemption amount. While this powerful mechanism can help married couples preserve unused tax exemptions and minimize transfer tax liability, it is frequently misunderstood, underutilized, or improperly elected. Understanding the statutory framework, mechanics...

Recent tax developments include New York City's new property tax surcharge on high-value pied-à-terre homes and potential changes to IRS Form 1040 that would require disclosure of citizenship status and dual citizenship. These policy shifts reflect growing efforts to address tax equity in luxury real estate markets and enhance transparency in tax reporting for individuals with complex international ties.

Fiduciaries administering estates with revocable trusts face critical income tax decisions that can significantly impact asset availability and tax obligations.