Tax Law and International Tax Law

Colorado's H.B. 26-1223 represents a major shift in the state's tax landscape, bringing downloaded software, remotely accessed applications, and SaaS offerings under the sales and use tax umbrella. What does this mean for businesses operating in Colorado, and how should they prepare for the changes taking effect in 2027?

Commercial space innovation is accelerating. What once felt like science fiction — orbital data centers, in-space manufacturing, and resource extraction — is quickly becoming part of the business landscape. Venture capital and corporate investment are already flowing into these technologies, with companies planning their first orbital infrastructure deployments as early as 2026.

A federal court has vacated IRS Notice 2025-42, which eliminated the Five Percent Safe Harbor for establishing "beginning of construction" for wind and solar projects seeking federal clean energy tax credits. With less than a month before the July 4, 2026 statutory deadline and an expected appeal, developers face critical decisions about whether to rely on the restored safe harbor or continue with existing compliance strategies under uncertainty.

New York has enacted an annual "pied-à-terre tax" on high-value New York City non-primary residences, effective July 2026, that could impose significant tax burdens on owners of luxury second homes. The tax applies to properties valued above certain thresholds, with rates varying by property type and value, and extends to properties held through trusts, LLCs, and other business entities. Property owners must understand exemption criteria and prepare documentation to challenge assessments before the Dep

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.

Check your mail and respond immediately. NYC mailed Pied-à-Terre surcharge notices to owners of high-value residences without confirming primary vs. secondary status; respond promptly using the notice's web link and PIN to avoid a substantial surcharge.

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...

Although IRS enforcement efforts have evolved, estate and gift tax examinations remain an area of focus, particularly for high value estates and sophisticated wealth transfer transactions.

The IRS and Treasury Department have issued new guidance addressing how contributions to Trump Accounts are treated for federal gift tax purposes, creating a safe harbor for qualifying donors. Revenue Procedure 2026-25 establishes specific requirements that allow certain contributions to be treated as completed gifts of a present interest, eligible for the annual gift tax exclusion without requiring Form 709 filing. Understanding these requirements is critical for donors to ensure compliance and avoid unnec

S corporation shareholders who elected to defer the Section 965 transition tax under the Tax Cuts and Jobs Act face ongoing compliance obligations and potential acceleration risks. Understanding the strict filing deadlines, triggering events, and annual reporting requirements is essential to avoid unexpected tax liabilities and costly penalties that can arise from routine business transactions or estate planning activities.