Tax Law and International Tax Law

The Qualified Opportunity Zone program has undergone a major transformation with the passage of the One Big Beautiful Bill, shifting from a temporary framework to a permanent fixture with enhanced incentives and new rural investment categories.

Recent tax developments include New York City's new property tax surcharge on high-value pied-à-terre homes and potential changes to IRS Form 1040 that would require disclosure of citizenship status and dual citizenship. These policy shifts reflect growing efforts to address tax equity in luxury real estate markets and enhance transparency in tax reporting for individuals with complex international ties.

In May, the I.R.S. announced a settlement offer for partnerships involved in disputes concerning "syndicated conservation easements." The key features of the offer include a 10% penalty for gross valuation misstatement, instead of a 40% penalty, and no upfront payment required.