Worldwide: Tax

In 2026, the federal tax treatment of export income undergoes a structural shift as FDDEI replaces FDII, eliminating the qualified business asset investment limitation and revising expense allocation rules.

Transfer pricing complexities emerge as artificial intelligence systems increasingly rely on vast training datasets, raising critical questions about how multinational corporations should value and allocate these intangible assets across jurisdictions. The intersection of AI development and international tax law presents novel challenges for determining arm's length pricing when data crosses borders within corporate structures.

Selling an S corporation involves complex tax and legal considerations that can significantly impact after-tax proceeds. This comprehensive analysis examines stock sales versus asset sales, IRC Section 338(h)(10) elections, F reorganizations, and other transaction structures, revealing how different approaches affect both sellers and buyers through detailed tax modeling and strategic planning insights.

The Town of Huntington is reportedly considering a policy that would require developers receiving Payment in Lieu of Taxes (“PILOT”) benefits to make additional contributions intended to offset perceived impacts...

A recent Sixth Circuit decision examines whether property owners are entitled to surplus proceeds when their homes are sold at tax foreclosure auctions for amounts exceeding the underlying tax debt. The case raises fundamental questions about how just compensation should be measured under the Fifth Amendment—specifically whether delinquent taxpayers should receive the fair market value of their property or merely the discounted auction price realized at a forced sale.

For Oklahoma business owners seeking to acquire commercial real estate or long-life equipment, the SBA 504 Loan Program offers fixed-rate financing with as little as 10% down and terms extending up to 25 years.

As family offices across the Middle East continue to grow in both sophistication and ambition, many are increasingly looking to the United States as a destination for capital deployment.

This Legal Update concludes our three-part series on preferred equity in private capital markets, exploring key tax considerations for preferred equity investments. For background on preferred equity’s core features, structural implementation, and use cases...

State tax amnesty programs provide a limited opportunity for taxpayers with unpaid tax liabilities to come forward voluntarily and resolve those obligations with reduced financial consequences.

Cyber‑enabled cargo theft is a modern form of freight theft in which criminals use digital impersonation, stolen credentials and system manipulation to fraudulently obtain cargo...

The Autumn Budget contained a range of pensions-related announcements with implications for employers and trustees of all occupational pension schemes.

The Chancellor has today announced her highly anticipated autumn Budget.