Tax Law and International Tax Law

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

New York City's new pied-à-terre surcharge introduces a "renovation gap" that may unexpectedly impact property owners during major construction projects. Partners Alexandra Wald and Nicholas Kaiser analyze why owners of properties that cannot be legally occupied during renovations may still face the surcharge, and what stakeholders should consider to navigate this complex issue.

This amendment increases the homestead exemption, for all non-school taxes, to $150,000 in 2027, and $250,000 in 2028, and adjusts for inflation thereafter. It requires the legislature to prescribe a uniform procedure for counties and municipalities, for their respective levies, to increase the homestead exemption up to full assessed value, and allows special districts, subject to referendum approval, to do the same.

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.

A recent decision from the United States District Court for the Southern District of Florida offers a cautionary tale for estate planners who rely on Qualified Personal Residence Trusts (QPRTs) and the interplay between state homestead protections and federal estate tax inclusion rules.

The August 2026 Section 7520 rate remains at 5.20% for estate planning techniques. Treasury Decision 10051 targets CRAT abuse schemes as listed transactions requiring disclosure. New guidance addresses Trump Account contributions, charitable LLC arrangements face IRS scrutiny, and Florida introduces streamlined trustee discharge procedures.

A healthcare provider and his spouse discovered a $65,000 tax refund opportunity after switching to a more strategic accounting firm. Through a comprehensive review of prior-year returns, advisors identified an underutilized Qualified Business Income deduction that their previous firm had missed, demonstrating the value of proactive tax planning and responsive advisory services.

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.

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

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.

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.

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.