Tax Law and International Tax Law

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Article
Proposed Nondiscrimination Rule For Private School Admissions, Financial Assistance, And Other Programs
The IRS has proposed new regulations that would impose nondiscrimination requirements on private schools seeking to maintain their tax-exempt status under section 501(c)(3). These regulations would prohibit policies discriminating on the basis of race, color, or national or ethnic origin in admissions, financial assistance, and other school programs. The proposed rules raise important questions about how private schools can structure their programs while complying with federal tax law requirements.
United States Tax
JD
Jones Day
Article
CDFTA Addresses Stakeholder Questions on California’s SB 122 Software and SaaS Tax
California's Department of Tax and Fee Administration held its second meeting to discuss emergency regulations implementing Senate Bill 122, which will extend sales and use tax to prewritten software and SaaS starting January 1, 2027. Stakeholders raised critical questions about sourcing rules, contract transitions, multistate deployment, and administrative provisions that remain unresolved as the implementation date approaches.
United States Tax
GT
Greenberg Traurig, LLP
Article
Are You Also Confused How New York City's Pied-à-Terre Tax Applies To You?
New York City's Pied-à-Terre Tax Law has created uncertainty for homeowners following the Department of Finance's adoption of final rules and mailing of thousands of surcharge notification letters. This comprehensive analysis examines the tax's application to residential properties, clarifies common scenarios involving trusts and business entities, and provides guidance on exemption qualifications and appeal procedures before the October 6, 2026 deadline.
United States Tax
HK
Holland & Knight
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Tax Disputes

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Transfer Pricing

Article
IRS Issues Proposed Regulations Excluding Income From Certain Property Sales From FDDEI Under Section 250(b)(3)(A)(i)(VII)
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.
United States Tax
AO
A&O Shearman
Article
Government Drops Statute Of Limitations Defense In McKesson Cost-sharing Challenge
The US Department of Treasury defends its authority to regulate stock-based compensation in cost-sharing arrangements under IRC § 482, arguing the regulations fall within statutory bounds and are necessary to ensure arm's-length results between related parties. The government's response to McKesson Corporation's summary judgment motion addresses challenges based on the Loper Bright decision and notably abandons its six-year statute of limitations defense.
United States Tax
SR
McDermott Will & Schulte
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Sales Taxes: VAT, GST

Article
CDFTA Addresses Stakeholder Questions on California’s SB 122 Software and SaaS Tax
California's Department of Tax and Fee Administration held its second meeting to discuss emergency regulations implementing Senate Bill 122, which will extend sales and use tax to prewritten software and SaaS starting January 1, 2027. Stakeholders raised critical questions about sourcing rules, contract transitions, multistate deployment, and administrative provisions that remain unresolved as the implementation date approaches.
United States Tax
GT
Greenberg Traurig, LLP
Article
Coming Attractions: California Previews Rules On SaaS And Digital Products Tax
The California Department of Tax and Fee Administration (CDTFA) has released draft regulatory language it is considering proposing, offering its first comprehensive view of how it may administer Senate Bill 122, California's expansion of sales and use tax to software as a service (SaaS) and certain digital products beginning January 1, 2027. CDTFA has not yet formally proposed these regulations through the emergency rulemaking process.
United States Tax
HK
Holland & Knight
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Withholding Tax

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