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
IRS Proposes New Nondiscrimination Requirement As A Condition Of Federal Tax-exempt Status For Private Schools
The Treasury Department and IRS have proposed new regulations that would establish an explicit racial nondiscrimination requirement for private schools seeking federal tax exemption under Section 501(c)(3). These proposed rules go beyond existing law by prohibiting all forms of racial discrimination in education regardless of intent, legality, or purpose, potentially affecting admissions policies, scholarship programs, and other school-administered initiatives.
United States Tax
HL
Hogan Lovells Cadwalader
Article
Limited In Name Only – Second Circuit Narrows The Path For Self-employment Tax Partnership Planning
The Second Circuit's ruling in Soroban Capital Partners LP v. Commissioner establishes that a "limited partner" must have both limited liability and no role in running, managing, or controlling the partnership to qualify for the self-employment tax exception. This decision, alongside the Fifth Circuit's revised opinion in Alain v. Commissioner, creates a circuit split with significant implications for fund managers who structure ownership through limited partnerships to minimize self-employment tax
United States Tax
WT
Winston Taylor
Article
City Of New Orleans Announces Sales Tax Amnesty Program
The City of New Orleans Department of Finance has launched a Sales Tax Amnesty Program offering businesses a limited-time opportunity to settle overdue sales tax obligations with significant penalty relief. Through December 31, 2026, qualifying taxpayers can resolve delinquent balances for sales taxes, use taxes, hotel/motel taxes, and other municipal taxes while having all penalties, negligence fees, and half of accrued interest waived.
United States Tax
LL
Liskow & Lewis
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
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Tax Disputes

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Inheritance Tax

Article
A $13 Million Reminder: Domicile Planning Is More Than Paperwork
A Connecticut Supreme Court decision demonstrates how a $13 million estate tax dispute reinforces a critical planning lesson: formal declarations of domicile carry limited weight when contradicted by an individual's actual living patterns. The case examines how spending more time in Connecticut than Florida, despite obtaining a Florida driver's license and voter registration, led to a substantial tax liability.
United States Tax
WD
Wiggin & Dana
Article
A 5% Wealth Tax? Preparing Clients For California's Billionaire Tax Act
California's proposed Billionaire Tax Act would impose a onetime 5% excise tax on individuals and trusts with assets exceeding $1 billion, creating unprecedented challenges for estate planners. The retroactive application and anti-abuse provisions raise critical questions about the treatment of grantor trusts, non-grantor trusts, and beneficiary interests that deviate significantly from established federal wealth transfer tax principles.
United States Tax
WL
Withers LLP
Article
FASB’s New Fair Value Standard May Bolster Marketability Discounts In Estate Planning
The Financial Accounting Standards Board issued Accounting Standards Update 2026-03, Fair Value Measurement (Topic 820): Investment Companies with Equity Securities Subject to Contractual Sale Restrictions, on September 9, 2026. While the update is aimed at investment company accounting, it could benefit estate planners and valuation professionals who regularly defend marketability discounts on closely held and restricted stock.
United States Tax
LL
Liskow & Lewis
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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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Tax Authorities

Article
IRS Proposes New Nondiscrimination Requirement As A Condition Of Federal Tax-exempt Status For Private Schools
The Treasury Department and IRS have proposed new regulations that would establish an explicit racial nondiscrimination requirement for private schools seeking federal tax exemption under Section 501(c)(3). These proposed rules go beyond existing law by prohibiting all forms of racial discrimination in education regardless of intent, legality, or purpose, potentially affecting admissions policies, scholarship programs, and other school-administered initiatives.
United States Tax
HL
Hogan Lovells Cadwalader
Article
City Of New Orleans Announces Sales Tax Amnesty Program
The City of New Orleans Department of Finance has launched a Sales Tax Amnesty Program offering businesses a limited-time opportunity to settle overdue sales tax obligations with significant penalty relief. Through December 31, 2026, qualifying taxpayers can resolve delinquent balances for sales taxes, use taxes, hotel/motel taxes, and other municipal taxes while having all penalties, negligence fees, and half of accrued interest waived.
United States Tax
LL
Liskow & Lewis
See more

Corporate Tax

Article
The Financial Ecosystem Every Content Creator Needs to Manage Growth
As content creators scale their channels and revenue streams, managing multiple income sources, tax obligations, and business decisions becomes increasingly complex. Discover how building a coordinated financial ecosystem—with business management, accounting, tax planning, and advisory support—can provide the visibility and infrastructure needed to transform creative success into sustainable business growth.
United States Accounting
MG
MGO CPA LLP
Article
Limited In Name Only – Second Circuit Narrows The Path For Self-employment Tax Partnership Planning
The Second Circuit's ruling in Soroban Capital Partners LP v. Commissioner establishes that a "limited partner" must have both limited liability and no role in running, managing, or controlling the partnership to qualify for the self-employment tax exception. This decision, alongside the Fifth Circuit's revised opinion in Alain v. Commissioner, creates a circuit split with significant implications for fund managers who structure ownership through limited partnerships to minimize self-employment tax
United States Tax
WT
Winston Taylor
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
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