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
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
Pennsylvania Decouples From Federal Interest Expense Rules
Pennsylvania's Department of Revenue has eliminated a key safe harbor for consolidated filers, requiring separate-company calculations of federal interest expense limitations under IRC Section 163(j) for Corporate Net Income Tax purposes starting in 2025. The new guidance introduces complex tracking requirements for intercompany interest, third-party debt, and carryforwards while freezing conformity to pre-OBBB rules, creating significant compliance challenges for multistate corporations.
United States Tax
HK
Holland & Knight
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Income 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
Existing Opportunity Zone Investors Must Evaluate Planning Opportunities Before Dec. 31, 2026
The IRS has issued Notice 2026-40 providing transition guidance for investors who deferred capital gains under the original Opportunity Zone program. While December 31, 2026 remains the mandatory recognition date for deferred gains, the guidance reveals a potential planning opportunity that may allow certain investors to continue deferring gains under the new Opportunity Zone regime through strategic pre-year-end transactions.
United States Tax
JM
Jeffer Mangels & Mitchell LLP
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
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Tax Authorities

Article
Pennsylvania Decouples From Federal Interest Expense Rules
Pennsylvania's Department of Revenue has eliminated a key safe harbor for consolidated filers, requiring separate-company calculations of federal interest expense limitations under IRC Section 163(j) for Corporate Net Income Tax purposes starting in 2025. The new guidance introduces complex tracking requirements for intercompany interest, third-party debt, and carryforwards while freezing conformity to pre-OBBB rules, creating significant compliance challenges for multistate corporations.
United States Tax
HK
Holland & Knight
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Corporate 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
Pennsylvania Decouples From Federal Interest Expense Rules
Pennsylvania's Department of Revenue has eliminated a key safe harbor for consolidated filers, requiring separate-company calculations of federal interest expense limitations under IRC Section 163(j) for Corporate Net Income Tax purposes starting in 2025. The new guidance introduces complex tracking requirements for intercompany interest, third-party debt, and carryforwards while freezing conformity to pre-OBBB rules, creating significant compliance challenges for multistate corporations.
United States Tax
HK
Holland & Knight
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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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