Worldwide: Tax

HMRC has extended its Structured Risk Review process to charities, introducing comprehensive scrutiny across all operational aspects including governance, fundraising, and subsidiary relationships. The review process involves extensive documentation requests and can result in penalties up to 100% of tax liability for identified errors. Charities must maintain robust tax compliance and governance practices as the SRR cannot be adequately prepared for at short notice.

No IRS relief program is permanent, and the agency rarely gives taxpayers advance warning before one disappears. On July 1, 2026, that lesson repeated itself: the IRS quietly eliminated the Delinquent FBAR Submission Procedures, a program that for over a decade had let taxpayers who missed a Foreign Bank Account Report, but had otherwise paid every dollar of tax they owed, catch up without penalty. 

California's Department of Tax and Fee Administration held its first implementation workshop on Senate Bill 122, which extends sales and use tax to digital software and SaaS starting January 1, 2027. The workshop revealed significant unresolved questions about sourcing rules, the $5 million threshold mechanism, custom versus prewritten software distinctions, and the human-effort exemption that will require emergency regulations and potentially litigation to clarify.

Jared Walczak of the Tax Foundation joins the GeTtin' SALTy podcast to examine the growing movement to eliminate real property taxes in the United States, using Ohio as a detailed case study. The discussion explores the fiscal challenges of replacing property tax revenue, the impact on local government accountability, and alternative policy solutions like levy limits and circuit breaker programs that address taxpayer concerns without dismantling the property tax system.

The forms support the final Section 987 regulations issued in December 2024, which provide guidance for determining taxable income, loss, and earnings and profits for qualified business units (QBUs) that use a different functional currency than their owners. The regulations apply to tax years beginning in 2025.

Something labeled “defective” usually does not work properly. The intentionally “defective” grantor trust, or “IDGT,” however, is a proven workhorse for tax-efficient business succession planning. A carefully planned and executed IDGT transaction enables business owners to transfer significant value in trust for the benefit of younger generations, with remarkable tax efficiency, while retaining control over the business. Two seemingly contradictory tax attributes of the IDGT underlie its tax efficiency.

When US multinational enterprises expand into Europe through a Dutch BV general European company, hiring employees in other jurisdictions before establishing local subsidiaries can create unexpected permanent establishment risks. The tax implications depend heavily on employee activities, decision-making authority, and home-office arrangements, requiring careful assessment before making local hires.

Navigating the complex landscape of US federal income tax rules is crucial for investors and sponsors in private equity, venture capital, and hedge funds. Understanding how different investor categories—from US taxable entities to foreign pension funds—face distinct tax sensitivities can significantly impact investment returns and structural decisions when forming or investing in funds.

The IRS recently released Revenue Procedure 2026-25, which establishes a transfer tax safe harbor for certain contributions to Trump Accounts.

Banking groups are under pressure to transform their operating models due to digitalization, changing customer expectations, and heightened ESG requirements. As AI platforms, data governance, and ESG frameworks reshape value creation and risk allocation, the traditional transfer pricing roles and cost-based remuneration models in banking may need fundamental reassessment to reflect evolving business realities.

When US multinational enterprises expand into Europe through a Dutch BV general European company, hiring employees in other jurisdictions before establishing local subsidiaries can create unexpected permanent establishment risks. The tax implications depend heavily on employee activities, decision-making authority, and home-office arrangements, requiring careful assessment before making local hires.

On the morning of 21 July 2026 at a meeting of the Wall Street Tax Association, officials from the Internal Revenue Service (IRS) and Department of Treasury (Treasury) joined in a discussion with income tax...