Tax Law and International Tax Law

The OECD's proposed revision of Chapter VII of the Transfer Pricing Guidelines aims to clarify the framework for intra-group services, with the benefit test emerging as the central analytical principle.

The IRS has intensified scrutiny of partnership basis-shifting transactions that manipulate inside and outside basis rules to generate tax savings. While recent regulations were withdrawn under the Trump Administration, the agency maintains its position through Rev. Rul. 2024-14, which identifies three transaction types that fail the economic substance doctrine.

The U.S. Treasury and IRS have issued proposed regulations addressing a new category of income excluded from deduction eligible income under section 250(b)(3)(A)(i)(VII), which was introduced by the One Big Beautiful Bill Act. These regulations clarify how income from sales of intangible property and certain depreciable assets will be treated under the foreign-derived deduction eligible income regime, with significant implications for software transactions and related party transfers.

The U.S. tax landscape has undergone dramatic transformation since the Tax Cuts and Jobs Act of 2018, with evolving rules, expiring provisions, and major legislation during President Trump's second term. This analysis examines the six most significant tax developments of the past eight years, from historic estate tax exemption increases to the growing importance of international taxation, and explores what these changes mean for taxpayers, advisors, and business owners navigating today's more stable but sti

US corporate executives relocating abroad face complex tax obligations that extend beyond borders. From worldwide income taxation and foreign tax credits to state residency issues and potential expatriation taxes, understanding these planning areas is essential for avoiding costly penalties and optimizing your tax position.

Recent US court rulings have confirmed that foreign tax credits cannot offset the Net Investment Income Tax for American citizens living abroad, creating an additional layer of taxation even when income is already taxed in their country of residence. These decisions raise critical questions about the long-term viability of maintaining US citizenship for entrepreneurs and business owners who have permanently established their lives outside the United States.

A New York appellate court recently ruled on the state's revised P.L. 86-272 regulation, determining it is not facially preempted by federal law but cannot be applied retroactively before December 2023. The decision leaves open the possibility of future taxpayer-specific challenges while providing clarity on how internet-based business activities may affect state tax obligations for out-of-state sellers.

With tax season underway, a critical change to USPS postmarking procedures could put taxpayers at risk of unintended late filings. As of December 24, 2025, mail is now postmarked based on when it's processed at a postal facility rather than when it's dropped off, potentially creating discrepancies between actual mailing dates and official postmarks. This shift has significant implications for anyone relying on postmark dates as proof of timely filing for federal and state tax returns.

The Illinois Department of Revenue has released draft proposed regulations implementing the Illinois Digital Asset Tax Act, a first-in-the-nation tax on certain digital asset transactions that takes effect January 1, 2027, at a rate of 0.2 percent of the value of the digital asset involved in the transaction.

California law treats aircraft as taxable tangible personal property subject to annual appraisal and local property taxation. With counties like Los Angeles increasing enforcement efforts, aircraft owners face significant compliance obligations, potential penalties, and a complex valuation process. Understanding the state's filing requirements, exemptions, and critical deadlines is essential for anyone who owns or operates aircraft regularly based in California.

Florida's proposed constitutional amendment to expand homestead exemptions could fundamentally reshape the state's residential real estate market by altering buyer incentives and development economics. The measure, set for a November 2026 ballot, may eliminate non-school property taxes for up to 90 percent of primary households, creating ripple effects across land values, municipal revenues, and construction feasibility that extend far beyond simple tax relief.

New York City has begun notifying owners of high-value residential properties about a newly enacted annual surcharge on units not used as primary residences. While receipt of a notice doesn't automatically mean payment is required, it does impose response obligations on owners of second homes, investment properties, and trust-held residences. The surcharge faces active litigation, with courts currently permitting collection to proceed despite ongoing legal challenges.